Complex Safeguarding

Complex Safeguarding is a term used to describe criminal activity (often organised) or behaviour associated with criminality, involving children and adults, where there is exploitation and/or a clear or implied safeguarding concern.

The MSP context for Complex Safeguarding is that children and adults are targeted and subjected to serious harm, which is primarily, although not exclusively, outside the family.

This might include individuals planning, coordinating and committing serious offences – individually, in groups and/or as part of transnational networks – that involve activities such as:

  • sexual exploitation and abuse
  • illegal drugs use
  • illegal firearms
  • modern slavery and human trafficking.

Radicalisation and serious youth violence, including knife crime, are also strongly linked to organised crime and criminality. Geographical borders are increasingly eroded, with individuals and networks operating across regions, countries and in cyberspace.

Much of this activity remains hidden or under reported, the true scale and complexity is likely to be greater than we currently know. Evidence and intelligence is continually emerging from a local, national and international context.

Complex Safeguarding is one of the key priorities for the MSP and signals our continuing commitment to leading the way in tackling the exploitation of children and adults, whilst ensuring  services are joined up across the region.

Services will be delivered in a coordinated, trauma informed and consistent way, working with children, families and adults, that builds on their strengths, finds joint solutions and improves outcomes

Evidence informed approaches are core to our approach – the Centre of expertise on child sexual abuse  is working alongside the Greater Manchester (GM) Complex Safeguarding Hub and partner agencies to improve practice with young people who are at risk of harm and exploitation external to the family home (sexual exploitation, criminal exploitation, gangs, modern slavery and county lines).

Transitional Safeguarding is a term used by Research in Practice to highlight the need to improve the safeguarding response to older teenagers and young adults in a way that recognises their developmental needs and in Manchester we support and work with this approach.

In Manchester we are currently focusing on:

  • sexual exploitation of children or adults
  • criminal exploitation of children or adults
  • modern day slavery including trafficking
  • missing children and young people.

Manchester Complex Safeguarding Strategy

In Manchester we have one overarching Complex Safeguarding Strategy for children and adults.



Child Sexual exploitation
Child sexual exploitation is a form of child sexual abuse. It occurs where an individual or group takes advantage of an imbalance of power to coerce, manipulate or deceive a child or young person under the age of 18 into sexual activity


  • in exchange for something the victim needs or wants, and/or
  • for the financial advantage or increased status of the perpetrator or facilitator.


The victim may have been sexually exploited even if the sexual activity appears consensual. Child sexual exploitation does not always involve physical contact; it can also occur through the use of technology.  (Department for Education, 2017)


Adult sexual exploitation
Adult sexual exploitation is when acts are

  • in exchange for basic necessities, such as food, shelter or protection or for something that is needed or wanted
  • an individual has felt frightened of the consequences if they refuse (coercion)
  • the person who is exploiting stands to gain financially or socially.


It is important to remember that there are a number of scenarios that fall under this definition and sometimes sexual exploitation can be hard to identify.


Both men and women can be sexually exploited. It can take place in a domestic, commercial (workplace) or public settings. Crucially, the individual that is, or has been, subject to sexual exploitation may not realise it, which makes it all the more important that practitioners are able to offer clear concise explanations and advice.


It is also worth being mindful of identified factors that increase the risk of sexual exploitation in adulthood including:

  • homelessness
  • use of drugs or alcohol
  • lack of mental capacity to consent to sexual activity
  • human trafficking
  • sexual abuse during childhood.


The Care Act 2014 places a duty on local authorities to make enquiries if there are concerns that an adult with care and support needs is experiencing or at risk of abuse or neglect, and, as a result of those needs, is unable to protect themselves. This applies, for example, where an adult discloses sexual exploitation / organised abuse or if a member of the public or parent expresses concerns about an adult.


Child Criminal Exploitation (CCE)
There is no legal definition of CCE; the current Home Office Definition (2018) is – this occurs where an individual or group takes advantage of an imbalance of power to coerce, control, manipulate or deceive a child or young person under the age of 18 into any criminal activity

  • in exchange for something the victim needs or wants, and/or
  • for the financial or other advantage of the perpetrator or facilitator and/or
  • through violence or the threat of violence; the victim may have been criminally exploited even if the activity appears consensual.


Child Criminal Exploitation does not always involve physical contact; it can also occur through the use of technology.


There is growing evidence that vulnerable children and young adults are specifically targeted for criminal purposes, although any child can be at risk. Known direct targets are those that:

  • do not have strong support networks
  • have no previous criminal record
  • are unlikely to be stopped by the police
  • may have emotional and mental health problems or learning disabilities
  • are not UK citizens or do not have immigration status
  • are looked after in children’s homes or out of area
  • may be living in poverty.


(Home Office, 2017: Youth Justice Legal Centre, 2018; Violence and Vulnerability Unit, 2018).


Methods include, but are not restricted to:

  • violence and coercion
  • sexual assault and threat
  • psychological manipulation
  • the promise of cash and drugs
  • creating a type of ‘bondage’ through a debt of ‘gratitude’ or for money ‘owed’ by being supplied mobile phones/drugs.


(Home Office, 2017:The Children’s Society, 2018; Youth Justice legal Centre, 2018; Coomber and Moyle, 2018; Stone, 2018; Robinson et. al. 2019).


‘Cuckooing’ describes a common feature of exploitation, in which adults at risk become entrenched in gang (or other) activity in the local community and their homes are taken over for the purposes of drug dealing and other criminal activity (NCA, 2018: Violence and Vulnerability unit, 2018).


These relationships are characterised by a power imbalance. Targeted children and adults should not be viewed as ‘choosing’ a lifestyle, or making an informed choice to engage in criminal behaviour. In many cases they may not see themselves as victims. Those being exploited for criminal purposes are victims and should be safeguarded (Youth Justice Legal Centre, 2018)


The most effective intervention is likely to be based upon longer-term, relationship building, and a trauma informed, child-led approach. Children and adults at risk are likely to be extremely fearful of the repercussions of ‘snitching’ and are likely to take considerable time and patience to engage (Coomber and Moyle, 2018; Stone, 2018; McNeish et al, 2018; Robinson et. al. 2019).

  • The Greater Manchester ‘Trapped’ campaign aims to raise awareness of all forms of criminal exploitation – find out more at
  • For more information see our Cuckooing resource.


Modern slavery & human trafficking
Modern slavery is the recruitment, movement, harbouring or receiving of children, young people or adults through the use of force, coercion, and abuse of vulnerability, deception or other means for the purpose of exploitation.


Individuals may be trafficked into, out of or within the UK, and they may be trafficked for a number of reasons including sexual exploitation, forced labour, domestic servitude and organ harvesting.


Someone is in slavery if they are:

  • forced to work – through coercion, or mental or physical threat
  • owned or controlled by an ‘employer’, through mental or physical abuse of the threat of abuse
  • dehumanised, treated as a commodity or bought and sold as ‘property’
  • physically constrained or have restrictions placed on their freedom of movement.


The Modern Slavery Act 2015 defines offences of Slavery, Servitude and Forced or Compulsory Labour and Human Trafficking. These crimes include holding a person in a position of slavery, servitude forced or compulsory labour, or facilitating their travel with the intention of exploiting them soon after.


Although human trafficking often involves an international cross-border element, it is also possible to be at risk of modern slavery within your own country. It is possible to be a exploited in this way even if consent has been given to be moved. Children cannot give consent to being exploited therefore the element of coercion or deception does not need to be present to prove an offence.


An Adult at Risk as defined by the Care Act 2014 states that Local Authorities must make enquiries, or cause others to do so, if it believes an adult is experiencing abuse or neglect. An enquiry should establish whether any action needs to be taken to prevent harm or stop abuse or neglect and if so by whom.


Victims of modern slavery may not necessarily have the impairment or injury that would meet the eligibility for care and support under the act.


Victims may be survivors of modern slavery who are subsequently identified via local safeguarding processes; and there may be victims of modern slavery who are subsequently identified as having care and support needs, and thus entitled to support under current legislation.


National Referral Mechanism
The National Referral Mechanism (NRM) is the framework for identifying and referring those at risk of modern slavery and ensuring they receive the appropriate support.

  • First Responders – a ‘first responder organisation’ is, in England and Wales, an authority that is authorised to refer a potential victim of modern slavery into the National Referral Mechanism
  • Children (aged under 18) – if the potential victim is (or may be) under 18, an NRM referral must be made (duty to notify under S.55 Modern Slavery Act); child victims do not have to consent – they must first be safeguarded and then referred into the NRM process
  • ICTG Service – in Greater Manchester the first responder must notify the ICTG service:
  • Adults – consent is required for an adult to be referred to the NRM; if an adult does not consent to a referral the First Responder should complete a Duty to Notify referral.


NRM Process
The NRM decision making process is in two stages:

  1. ‘reasonable grounds’ decision – the threshold for this is low: ‘I suspect but cannot prove’ that the individual is a victim of trafficking
    • this should be received within five days
    • a positive decision triggers a minimum 45-day recovery and reflection period during which time agencies should update the Single Competent Authority with any new relevant information (including any changes in allocated workers)
  2. ‘conclusive grounds decision’ – the threshold for this is a balance of probabilities: ‘It is more likely than not’ that the individual is a victim of trafficking
    • the Conclusive Grounds Decisions should be shared with relevant professionals working with the young person, including immigration and / or criminal legal representatives and social care.


Missing from home or care
There are particular concerns about the links between children running away and the risks of sexual and criminal exploitation. Missing children may also be vulnerable to other forms of exploitation, to violent crime, gang exploitation, or to drug and alcohol misuse.


MFH Panels provide an opportunity for multi-agency information sharing and review of arrangements to reduce missing incidents and promote diversionary positive activities for young people. There is a focus on an early response to avoid concerns escalating.


There are a range of interventions available to offer young people at this stage including: access to local youth services; one to work with The Children’s Society; and referrals into the Unity Radio project which aims to build aspiration and self-esteem for young people through developing skills to enable them to create and produce their own radio show at Unity Radio Station based at Media City.


The current definition of missing from home and care across Greater Manchester is split into two categories:

  • Missing – anyone whose whereabouts cannot be established and where the circumstances are out of character or the context suggests the person may be the subject of crime or at risk of harm to themselves or another
  • Absent – a person not at a place where they are expected or required to be and where the circumstances and context suggest there is a lower level of risk.


The reasons why a child or young person may be running from or to a situation can be broad and varied. However, where the root cause for this behaviour is not addressed, the underlying issues can continue to grow, placing that child or young person at increased risk when they do go missing. There are complex safeguarding issues that can be both the cause and consequence of going missing frequently.


Children Missing Education
Children missing education are those who are of compulsory school age who are not registered pupils at a school and so are not receiving a suitable education otherwise. Children missing education are at risk of underachieving, being at risk of of harm, exploitation or radicalisation and becoming NEET (not in Education, Employment or Training) later in life.


Local Authorities have a duty under the Education Act 1996 to make arrangements to establish the identities of children in their area who are not registered pupils at a school and are not receiving a suitable education otherwise. In September 2016, the Department for Education issued statutory guidance setting out some key principles to enable Local Authorities to fulfil this duty.


Those children identified as not receiving a suitable education should be returned to school or alternative provision.


Manchester has a number of policies and procedures in place to ensure that it meets this statutory duty and also discharges other duties and powers to support work in relation to children missing education, these include:

  • ensuring children are offered a school place following a school admission application in line with DfE guidelines, including having fair access arrangements in place for children with more complex needs
  • issuing school attendance orders to parents who fail to satisfy the Local Authority that their child is receiving a suitable education
  • knowing how many children in the city at any one time are missing education and how many children are missing with whereabouts unknown
  • ensuring children attend school regularly including prosecuting or issuing penalty notices to parents who fail to ensure their child attends school regularly
  • knowing how many children are accessing alternative provision and arranging education for children who are permanently excluded from school
  • knowing how many children are being home educated and processes for assessing whether children are accessing a suitable education offer at home and how this is monitored


Manchester also has a dedicated email contact to report information about children who are thought to be missing education –

Manchester’s Adult Safeguarding Hub

Adult MASH (MLCO) and integrated teams undertake the initial assessment of Adult Safeguarding concerns and work proactively in the community to safeguard adults from harm or abuse.


The Adult MASH (MLCO including health) and integrated teams have referral routes into and out of the Complex Safeguarding Hub (Children Services, GMP, Health) to respond to concerns relating to exploitation.


An Adult Social worker (Adult MASH) is based in the Complex Safeguarding Hub to provide an Adults perspective and signposting in regard to outcome focused solutions in regard to exploitation (Complex Safeguarding).


The aim is to develop a robust response to Sexual Exploitation, Modern Slavery and Human Trafficking, Honour Based Abuse, Organised Crime in the City of Manchester. Our purpose is to ensure that children and adults  are safeguarded in the City of Manchester.

Our response to Complex Safeguarding

Achieving Change Together (ACT)
Achieving Change Together is a critical intervention that will help to achieve our response to complex safeguarding issues. ACT was developed in Rochdale and Wigan in 2015–2016.


The evidence base for ACT identified seven key principles that should underpin effective practice; these include:

  • keeping the child, their developmental needs and strengths at the centre
  • understanding the importance of safeguarding in context
  • understanding the complexity of exploitation
  • knowing the importance of a non-linear, collaborative multi-agency response
  • effective use of evidence and evidence informed practice
  • considering families and community as assets and requiring support
  • equipping a highly resilient workforce.


ACT is a strengths and relationship based, trauma and evidence-informed model for working with young people at risk of exploitation.


The model is built around a trained practitioner, working to ACT principles, who takes the time to build a meaningful and trusting relationship with a young person to help them identify their strengths, goals and build a plan. Young people deliver the service working in close partnership their ACT worker to co-produce plans for the future.


Manchester has introduced the Achieving Change Together (ACT) model and several young people are currently receiving intensive and bespoke support. The recent addition of a Clinical Psychologist in the hub is already having a positive impact by utilising case formulation to enable social workers both in the hub and locality to review and reflect on the current plan and effectiveness of the intervention.


Contextual Safeguarding
In Manchester we recognise the importance of a contextual safeguarding approach and have a number of ways in which this is considered. We have seen the benefit of taking this approach and there are a number of examples where we have been able to identify emerging issues, often of a significant nature, and respond much more effectively as a result of looking beyond individual young people.


We are increasingly mapping peer groups and the next step here would be to develop a more structured and consistent approach as to how we do this and how we understand and assess risk across peer groups. This is an opportunity to build on activities we already are engaged in to ensure they are having as much impact and are as meaningful as they can be. The work with team around schools also offers an opportunity to bring a contextual safeguarding approach into work that is already taking place to support schools where there are particular concerns.


Transitional Safeguarding
Transitional Safeguarding is a term used by Research in Practice to highlight the need to improve the safeguarding response to older teenagers and young adults in a way that recognises their developmental needs.


There are several reasons why a more fluid and transitional safeguarding approach is needed for young people entering adulthood; these are:

  • adolescents may experience a range of distinct risks and harms, and so may require a distinctive safeguarding response (as highlighted in both Complex Safeguarding and Contextual Safeguarding)
  • harm, and its effects, do not stop at the age of 18
  • many of the environmental and structural factors that increase a child’s vulnerability persist into adulthood, resulting in unmet needs and costly later interventions
  • the children’s and adults’ safeguarding systems are conceptually and procedurally different, and governed by different statutory frameworks, which can make the transition to adulthood harder for young people facing ongoing risk and arguably harder for the professionals who are trying to navigate an effective approach to helping them
  • young people entering adulthood can experience a ‘cliff-edge’ in terms of support, exacerbated by the notable differences between thresholds / eligibility criteria of children’s and adults’ safeguarding.


Disrupting Exploitation Programme
The Children’s Society Disrupting Exploitation programme is being funded by the National Lottery Community Fund for three years in Greater Manchester, London and Birmingham. The programme started in October 2018 and is focused on driving long-term, sustainable systems change that better responds to exploitation and provides the best possible outcomes for young people.


In Greater Manchester the team are focusing on disrupting Child Criminal Exploitation and recognise that this is a complex safeguarding issue that cannot be tackled in isolation and that it is also difficult to address solely by working with young people on an individual basis.


The programme allows the team to work systemically and contextually, in partnership with professionals, young people and the community to challenge and adapt the ‘systems’ that we work in to ensure they are set up in the best way to effectively safeguard young people.


The systems change work consists of completing ‘tasks’ which fall under four different categories;

  • contextual
  • culture and training
  • policy and practice
  • information and intelligence.


The Disrupting Exploitation Team are in the process of developing approaches to understand and respond to young people who are in debt due to their exploitation, ensuring young people’s experience is recognised and understood by professionals to improve safeguarding responses, and ensuring children and young people’s needs are met in school, in order to reduce school exclusions and are also completing investigative work around good practise and innovations to how we capture and improve ‘intelligence’ to support safeguarding interventions as well as community responses to Anti-Social Behaviour across several local authorities.


The team also work directly with young people ‘at risk’ of exploitation providing an early intervention approach.


Wythenshawe was identified as the first pilot area, and the team have been working intensively with young people in this area since January 2019. In March 2019, this expanded to reach to North Manchester thanks to additional funding received through Early Intervention Youth Fund (EIYF). This allowed the team to work with young people at escalating risk of exploitation who were not meeting thresholds for complex safeguarding.


The project workers have a reduced caseload due to working intensively with young people and to allow capacity for ‘systems change tasks’. The team have worked with a combined number of nine young people so far.

MSP Complex Safeguarding Subgroup

In Manchester the Complex Safeguarding Subgroup oversees Partnership activity in this area.


The subgroup is made up of informed senior officers designated to represent and authorised to make decisions on behalf of their respective organisation or strategic lead with responsibility for the delivery of key strategies/plans as determined by the Safeguarding Partnership Executive.

The purpose of the Complex Safeguarding subgroup is to act on behalf of the MSP to ensure partnership members are actively engaged in and participate in coordination and delivery of identified strategies/plans relating to:

  • sexual exploitation of children/adults
  • criminal exploitation of children/adults
  • modern day slavery including trafficking
  • missing.

The subgroup will work in partnership with the Community Safety Partnership and seek assurance as to the effectiveness of the approach and arrangements relating to:

  • Domestic violence and abuse
  • Female genital mutilation (FGM)
  • Honour based violence
  • Radicalisation
  • Serious and Organised Crime.


We are determined to protect children, young people and adults at risk of exploitation and to help them get the help they need.


If you have any concerns about these issues or you know someone who is being exploited in this way, please contact Greater Manchester Police on 999 if there is an immediate threat to a person or people.

Sources of further help and support:


Manchester Safeguarding Partnership also offers online learning via Virtual College