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Rt Hon James Cleverly MP

Home Secretary

Home Office

2 Marsham Street

London  SW1P 4DF

2nd February 2024

HMICFRS inspection of the effectiveness of the police and law enforcement bodies’ response to group-based child sexual exploitation in England and Wales

I am writing to you in response to the above HMICFRS report published on 8th December 2023. The national inspection focused on establishing how well the police and law enforcement bodies understand and respond to group-based child sexual exploitation (CSE). Through the inspection activity, HMICFRS identified one area for improvement and made nine recommendations; four of which were for Chief Constables.

Preventing and tackling serious organised crime including sexual exploitation, and improving responses and outcomes around sexual violence are two central tenets of my Safer West Mercia Plan.  As such, I welcome the national focus on tackling group-based CSE. Below I set out progress underway by the Chief Constable in West Mercia to address the recommendations and the wider support provided in my role as Police and Crime Commissioner (PCC). This activity compliments a comprehensive programme of work undertaken by the force and my office over the last 18 months in response to the findings of the Independent Inquiry into CSE in Telford (IITCSE; report published July 2022).

Recommendation 2: By 31 December 2024, all chief constables should make sure that their forces have problem profiles for child sexual exploitation, each of which should include an assessment of the nature and extent of group-based child sexual exploitation. This should include relevant data from local partner agencies and should be updated frequently, at least annually.

West Mercia Police already produces problem profiles for CSE as part of the serious organised crime tasking process. These products will be reviewed to ensure compliance with the recommended focus on group-based CSE. This recommendation is also reliant on the provision of specific data from both safeguarding partners and third-party agencies. A force wide review of all partnership data sharing agreements is ongoing and this recommendation will be amalgamated into the existing HMICFRS recommendations regarding the provision of data and information to support problem profile building and updates. Progress with partnership data sharing is subject of oversight and scrutiny at my Crime Reduction Board, attended by various statutory agencies and Community Safety Partnership (CSP) Chairs.

Complimentary work in understanding trends related to CSE are already underway in force. This includes bespoke reporting and analysis linked to ongoing partnership IITCSE recommendations in Telford; and wider development of West Mercia wide management information through the development of a Child Sexual Abuse and Exploitation dashboard. These products were subject of scrutiny and discussion through my Assurance and Accountability meetings with the Chief Constable in 2023-2024.

Understanding the nature and scale of CSE in West Mercia is not only integral to inform operational policing and partnership activity, but also the commissioning of prevention, early intervention and support services for those who may be at-risk exploitation or are victims and survivors. As a result, I have commissioned a West Mercia wide CSE Needs Assessment to assist in shaping and informing the future direction of commissioning / grant processes within my office. The needs assessment is anticipated to be finalised in March 2024 and will include group-based CSE.

Recommendation 4: By 31 December 2024, all chief constables and the relevant business user groups for police record management systems should make sure there are sufficient measures in place to identify group-based child sexual exploitation.

West Mercia police have integrated this recommendation into the Gold child protection plan to ensure compliance. The force has agreed to adopt a national definition of group based CSE for the avoidance of any doubt in this area. The current CSE flag used to identify relevant intelligence / offences will be adapted to ensure compliance with this recommendation and this has been confirmed with the business user group for the crime recording system used in West Mercia. Whilst this work is in train, I am reassured that current use of broader CSE markers (not limited to group-based CSE) are subject of audit and findings show they are being used appropriately.

Recommendation 8:  By 30 June 2024, all chief constables of forces that are yet to receive the Hydrant Programme’s continuing professional development offer should arrange it.

I am pleased to report that West Mercia Police have and will continue to engage with the Hydrant Programme’s continuing professional development offer to ensure officers and staff have the necessary skills and understanding to work in this complex area. The force has additionally engaged the programme to review activity in this area.

Recommendation 9: With immediate effect, all chief constables should take effective steps to eradicate victim-blaming language in their forces.

Given the far-reaching nature of this recommendation, the force is taking a cross-departmental approach to ensure compliance.  This will include audits of activity logs, investigations and communications alongside other measures to ensure intentional or unintentional victim blaming language is identified, with feedback being provided to those individuals or departments. This recommendation is also being reviewed by the Learning and Development department to ensure it is incorporated into existing investigative material.

Outside of this specific recommendation, the force continues to work closely with Lived Experienced Consultees to shape activity linked to recommendations from the IITCSE in Telford. These individuals have broad experience of working within the field of CSE and trafficking; being recognised nationally in respect of the work they do with survivors, delivering training across a range of statutory organisations, advising national agencies including the Home Office on matters relating to trafficking and supporting NGOs in their efforts to combat CSE and trafficking. This relationship emphasises the importance of understanding the victim experience and using this to improve the local response to CSE.

My office is engaged in ongoing dialogue with the Lived Experience Consultees to see how we can better work together to ensure those with lived experience are able to help inform and shape PCC commissioning and governance activity.  

Area for Improvement: All chief constables should work with their statutory safeguarding partners to review, promote and make sure that relevant group-based child sexual exploitation disruption and prevention initiatives are implemented effectively in their forces. This should include consideration of options such as the advice given in the Home Office disruption toolkit and an Operation Makesafe (a national police initiative to raise awareness of child sexual exploitation in the business community) type of approach.

The force already shares a comprehensive range of information with statutory partners in relation to CSE concerns and activity, however this will be reviewed in light of the recommendations set out above, with a specific focus on group based CSE to ensure continuity and compliance. Police forces are reliant on the provision of the Home Office disruption toolkit to enable compliance with the second point in this recommendation.

I have regular oversight and scrutiny of the force’s disruption activity related to organised criminality (including CSE) through quarterly serious organised crime briefings. These briefings cover disruption activity undertaken by local and regional law enforcement bodies across all 4Ps (Pursue, Prepare, Protect and Prevent).


As the PCC, I also directly commission and support local funding of initiatives and services focused on prevention, early intervention and support for those at risk of, or affected by CSE (including group-based CSE). A number of examples are set out below:

  • CSP funding for Taxi Marshal and Street Pastor schemes (inc. in Telford & Wrekin, as recommended by the IITCSE) and a CCTV pilot in licensed taxis;
  • Funding for Exploitation and Vulnerability trainers who provide training to organisations across a range of sectors to spot the signs of exploitation. To date, the trainers have trained more than 30,000 people across our communities to look out for the signs of exploitation and vulnerability.
  • Development of the online West Mercia Survivor Pathway; a resource to provide information about sexual violence support services across West Mercia. The aspiration is to include information and resources about online and face-to-face CSE.
  • Commissioning of sexual violence special support contracts (to the value of over £1.4m in 2023/24). This provision includes Independent Sexual Violence Advisor (ISVA) advocacy and CSE provision made up of Branch, Purple Leaf and Purple Leaf expansion services. I also provide separate funding towards counselling services provision.
  • The Branch project delivered by West Mercia Rape & Sexual Abuse Support Centre (WMRSASC) offers tailored 1:1 support to children and young people aged 5 to 18 who are at risk of or who could be experiencing CSE in whatever context that presents across Herefordshire, Worcestershire, and Shropshire. A Branch Plus worker has also been funded to support adults affected by CSE.
  • The Purple Leaf early intervention and prevention programme is an educational resource, run by WMRSASC and where required supported/co-delivered by partner providers to increase children and young people’s (CYP) awareness of sexual abuse, to equip them with the skills, knowledge, and tools to be able to identify uncomfortable feelings, and to know where to go for help and support. It is often delivered in tandem with the Bystander training intervention. Additionally Purple Leaf has just received uplifted funding to provide two ‘Dual Experience’ Workers who are able to work with CYP who may have dual experience, in that presentation of risk or suspicion of presenting a risk to others, whilst also being at risk of sexual abuse themselves.

Whilst the above is not an exhaustive list of initiatives and services I commission in this space, I hope it provides assurance that prevention and support related to group-based CSE is prioritised through my Safer West Mercia Plan and commissioned activity.

Although West Mercia was not specifically inspected as part of the report, I welcome the continued national focus on group based CSE. I will utilise the recommendations set out to inform future activity within my office including assurance and accountability activity with the Chief Constable. This will compliment existing governance arrangements already in place specific to the IITCSE in Telford & Wrekin and the force’s response to the recommendations made.

John Campion

Police and Crime Commissioner

West Mercia

cc       West Mercia Police Chief Constable