Prison Reform Trust submission Consultation for the second Mayoral strategy on violence against women and girls (2013-17) The Prison Reform Trust is an independent UK charity working to create a just, humane and effective prison system. We have a longstanding interest in improving criminal justice outcomes for women and are currently pursuing a three year strategy, supported by the Pilgrim Trust, to reduce the unnecessary imprisonment of women. We welcome the opportunity to respond to this consultation and are very pleased to see the links between women’s imprisonment and their experience of sexual abuse and/or domestic violence acknowledged in the consultation paper. Reducing the incidence of violence against women and girls is key to reducing the risk of their involvement in offending. We have chosen to respond only to those questions that fall within our criminal justice remit and on which we have expertise. We also enclose with this response our response to the MOPAC Police and Crime Plan. Violence against women and girls and women’s offending Research as well as experience among a wide range of service providers, indicate that women’s exposure to coercive and abusive relationships is a major driver of their offending. • More than half of the women in prison (53%) report having experienced emotional, physical or sexual abuse as a child, compared to 27% of men.1 A similar proportion report having been victims of domestic violence, though this is likely to be an underestimate. Women can become trapped in a vicious cycle of victimisation and criminal activity. Their situation can be worsened by poverty, substance dependency or poor mental health.2 The charity Women in Prison report that 79% of the women who use their services have experienced domestic violence and/or sexual abuse.3 • Women’s offending is more likely than men’s to be prompted by their relationships or by financial concerns. Nearly half of women prisoners (48%) questioned for the Surveying Prisoner Crime Reduction (SPCR) longitudinal survey reported having committed offences to support someone else’s drug use, compared to 22% of male prisoners.4 A Cabinet Office study found that 28% of women offenders’ crimes were financially motivated, compared to 20% of men’s.5 Earlier research on mothers in custody found that 38% attributed their offending to ‘a need to support their children’, single mothers being more likely to cite a lack of money as the cause of their offending than those who were married.6 • Many foreign national women in prison have been trafficked or coerced into offending. This is particularly true for Holloway Prison where 29% of the women are 1 foreign nationals, nearly double the national average of 16% of women in prison.7 A significant proportion of foreign national women in prison are known to have been coerced or trafficked into offending.8 • Care-leavers are hugely over-represented in custody – while less than 1% of all children in England are looked after, nearly a third of women prisoners spent time in care as children (and nearly a quarter of men).9 Domestic violence and sexual abuse are contributory factors to the family breakdown behind this, and much can be done to prevent care being a stepping stone to custody.10 • HMP Holloway is the largest women’s prison in Western Europe and ‘holds some of the most vulnerable female prisoners in the prison system.’11 Importance of an integrated, multiagency approach We welcome the commitment in the second VAWG strategy to ensuring an integrated joined-up approach. This was a key recommendation of the Women’s Justice Taskforce report, which highlighted the importance of early intervention and the need for close cooperation between criminal justice and health and social care services.12 Local strategic leadership is also recognised as vital by the President of the Directors of Adult Social Services (ADASS) in a briefing on the role of adult social care services in supporting vulnerable offenders.13 That briefing emphasises the opportunity that Joint Strategic Needs Assessments provide for local authorities to draw together a range of local organisations and agencies to improve outcomes for vulnerable individuals. The Prison Reform Trust therefore strongly supports the call for all London local authorities to play their part in this through their local Community Safety Partnerships, Safeguarding Children Boards and Health and Wellbeing Boards. Achieving the proposed pan-London approach requires clear direction and leadership which the Mayor and his deputy in charge of policing is well-placed to both provide and then showcase the benefits to the rest of the UK. Q7: What more can MOPAC do to raise awareness of VAWG and encourage reporting? Public awareness-raising of the prevalence of violence against women and girls is an important means of tackling the stigma associated with domestic and sexual violence which continues to act as a barrier to disclosure for many victims. We welcome the work done by MOPAC to increase awareness and responsiveness among family members, friends and neighbours and to encourage victims to disclose their experiences and seek help. However, it is equally important to ensure that when victims do report their experience to police and seek help from them and other services that they receive the protection they need. This will encourage other victims to come forward. There is much that MOPAC and the MPS can do in this area including: ‐ targeting police training, to ensure frontline staff have the skills needed to identify and support victims and potential victims; 2 ‐ provide strategic leadership to address the culture of disbelief many women experience when reporting crimes of sexual or domestic violence; ‐ deploy specialist female officers to incidents of domestic violence; ‐ coordinate a database of specialist London-wide service provision to which women can be signposted; ‐ trialling the domestic violence disclosure pilot scheme; ‐ pilot a police ‘diversion scheme’ that provides alternatives to prosecution for vulnerable women, including women who have experienced sexual or domestic violence. The Prison Reform Trust is concerned that an increasing number of female victims of domestic violence are being prosecuted, and sentenced, for retaliatory offences committed against abusive partners. At present the evidence of this is largely anecdotal and we recommend that the prevalence of such cases be investigated. We also recommend that the Metropolitan Police Service (MPS) and Crown Prosecution Service (CPS) work together to introduce safeguards to ensure that if a decision is taken to arrest, charge and prosecute a woman for such offences, the possibility that she may have been a victim of domestic violence herself be given full consideration. Given the particular dynamics of abusive relationships, and the complex factors which prevent victims from disclosing, we are concerned that women who have been serially abused over a period of time but have not (for a variety of complex reasons) disclosed this to the police, or whose complaints have not been taken seriously, are being criminalised whilst their abusers go unpunished. We also recommend that measures be implemented to ensure that women with learning disabilities and learning difficulties are given the information and support they need. They remain a neglected group whose needs are often not identified and whose problems can be exacerbated as a result. The Prison Reform Trust has considerable expertise in this area and would be happy to provide further resources and advice.14 Q9: What should a pan-London exit service for women wishing to exit prostitution look like? A good model for the development of a pan-London strategy that would provide routes out of prostitution can be found in the Ipswich/Suffolk Prostitution Strategy 2007-2012, sparked by the murders in Ipswich of women working as prostitutes in 2006. Developed in partnership between the police, probation, health, borough and county council, it combines action to reduce demand with the creation of a multiagency ‘Make a Change’ team “with the specific remit of providing interventions to develop routes out of prostitution for women”.15 Interventions, which draw on needs assessments carried out by social care practitioners are targeted at those involved in both on-street and off-street prostitution, and aim to provide support across all aspects of an individual’s life to facilitate long-term change. Supporting women into safe and secure accommodation is a key element. 3 An evaluation of the strategy found that it had been successful in removing prostitution from the streets; deterring kerb crawlers; supporting women to move on from street working; making effective inroads into prevention; and keeping the local community informed and on board.16 Recent research, published by Drugscope and AVA, on the needs of women involved in prostitution and substance use, has called for “a range of support, from harm reduction and treatment services to services to help them exit prostitution and support their ongoing recovery”. Services specifically aimed at facilitating exit will need to take account of women’s needs, understand that “the process of change and recovery is likely to take a long time” and offer flexible, non-judgmental support. Services should be prepared to provide aftercare for those women who may require ongoing support to sustain their exit. We would welcome London-wide action to prevent women from getting caught up in the criminal justice system as a result of their involvement in prostitution. As we note in answer to question 25, we would support a pilot scheme introducing a presumption against prosecution for prostitution-related offences. Where women involved in prostitution do end up in the criminal justice system, we would welcome an extension of the court diversion scheme offered at Camberwell Magistrates’ Court to cover all London boroughs and magistrates’ courts. The scheme, delivered in a unique partnership between the Crown Prosecution Service (CPS) and the Trust Women’s Project, offers women who have been arrested for street prostitution an opportunity to be diverted from court. Those who agree to attend two sessions with the Trust’s specialist court worker will have the case against them dropped. Sessions “focus on improving the women’s immediate situations, as well as providing them with the opportunity and the support to make lasting changes to their lives”.17 Whilst we believe that every woman wishing to exit prostitution should have access to individualised support services, it is also essential that those women who do not wish to engage with exit services should have their support needs met. Outreach services that link women with statutory agencies where applicable (e.g. health, housing and benefits) must be available and accessible. This means providing nonjudgemental, women-only services delivered by female professionals at a time and place that suits service users.18 The street outreach service provided by Anawim women’s centre in Birmingham, for instance, provides a safe place for women involved in street-based prostitution, where they can speak to support workers, have a shower, food or simply a cup of tea. Q10: What role can MOPAC play in reforming the way the criminal justice system responds to women offenders in London? The Prison Reform Trust believes that MOPAC can play a critical strategic role in improving criminal justice responses to women, including the development of alternatives to prosecution for women with complex needs and/or with primary care of children, an expansion in court-based liaison and diversion projects, and an increase in the use of community sentences for women offenders who pose no risk to the public. Our analysis of sentencing data for London shows a worrying increase in the use of custodial sentences. In 2011, 1,766 custodial sentences were given to women in the 4 Metropolitan police force area, accounting for one in five of all custodial sentences given to women in England and Wales that year. This was an increase of 11% since 2009, despite a fall in the number of custodial sentences given to women nationally over the same period. The overwhelming majority (88%) of these prison sentences were for non-violent offences, with theft and handling alone accounting for more than four in ten (728). Indeed, between 2009-2011 there was a 29% increase in the number of custodial sentences given to women in London for theft and handling offences, going from 563 (2009) to 728 (2011). The increase nationally over the same period was just 6%.19 In this context, we welcome the intention in the MOPAC’s strategy of “improving and expanding community-based support” for women who offend. It is clear from the continued use of custody for women who have committed non-violent offences that there is significant scope for improving community services available as alternatives to prosecution and imprisonment. Most of the solutions to women’s offending lie outside prison walls in treatment for addictions and mental health problems, protection from domestic violence and coercive relationships, secure housing, debt management, education, skills development and employment. Community sentences enable women to take control of their lives, care for their children, and address the cause of their offending. Whilst we accept that many of these solutions, when taken in isolation, are not directly within MOPAC’s remit, the Mayor and Deputy Mayor for Policing and Crime are uniquely placed to drive the improvement and expansion of community-based provision for women offenders. Women’s centres provide an evidenced20 model for delivering such provision, though there are only three such centres in London - Women at the Well (Kings Cross), Jagonari (Whitechapel) and Advance Minerva (Hammersmith) - and funding is uncertain due to changes to the delivery, and commissioning, of probation services outlined in the Government’s Transforming Rehabilitation programme. In keeping with the recommendations of the Corston Report and recent House of Commons Justice Committee report21, the time is now right to develop a pan-London strategy on women offenders which places gender-specific community service provision at its heart. This is a period of significant change in the criminal justice system: reductions in central government funding to local authorities are impacting on the configuration and delivery of those local services which are best placed to meet the needs of women offenders. There are nevertheless opportunities for MOPAC to influence and lead at a regional level. We envisage MOPAC taking a strategic lead to bring together all partners (statutory, private sector and voluntary) with an interest in preventing offending and reoffending by women; straddling the divide between centrally and locally commissioned services and agencies to make the case for funding and services that meet local need; and commissioning services and providing grants with a view to closing gaps in provision for this vulnerable group. With expertise in tendering, procurement, contracts, and evaluation, and in working across statutory and voluntary agencies, and with strategic authorities like the GLA, London Councils and LGA, the London Mayor and MOPAC could support statutory agencies, London Borough’s and others 5 to commission services for women in the criminal justice system. Facilitating a consortia-approach to Borough-level provision would ensure that the costs involved in the tendering process and in and drawing up contracts, for example, and the risks associated with commissioning services, were shared. The Prison Reform Trust was encouraged by the Mayor’s statement of intent on youth violence, outlined in the Time for Action programme, and would welcome a similar focus on the drivers to women’s offending. Project Daedalus and its resettlement-focused successor, for example, could provide an innovative model for funding and delivering women’s community provision. Proposed changes to the supervision of offenders, and to the commissioning framework, risk fragmenting existing provision so the priority must be to ensure that pan-London alternatives to custody for women are available to sentencers sitting in all Boroughs. The Prison Reform Trust would also like to see the MOPAC take the lead in developing gender-specific police liaison and diversion schemes that provide more effective responses to minor offending by women with multiple and complex needs. We are a member of the Women Offenders Forum convened by the Home Office that is fostering the development of such initiatives. There are already a number of pilot schemes operated by for example Manchester Police, Hull Police and Darlington/Durham Police that provide for women apprehended for minor non-violent offences to be assessed for alternatives to prosecution. These schemes, sometimes called police triage, operate in partnership with local women’s services. Prosecution is suspended on the basis of a woman’s engagement with support services that enable her to address the factors leading to her alleged offence. We will be publishing a briefing on these initiatives, and on the essential elements of effective diversion schemes for women in the Autumn, and would be pleased to provide further information in the meanwhile if that would be helpful. We would welcome an innovative approach to policing those offences which act as primary drivers to women’s imprisonment. As referenced above, theft and handling offences account for four in ten of all custodial sentences given to women. Many of these will be shoplifting-related. A survey of prisoners found that nearly half of all women (48%) reported having committed crimes to support someone else’s drug use22 whilst other research found that women’s offending was more likely to be financially motivated than men’s.23 There is scope, therefore, to tackle such offending by offering female suspects access to services with expertise in addressing substance abuse, supporting women out of coercive relationships and providing debt management advice as an alternative to arrest. We would also like to see an expansion in the operation of court-based schemes such as those supported by the London Probation Trust who commission the services of Together for Mental Wellbeing to provide specialist mental health court liaison schemes for women in a few London magistrates courts.24 Many of the women they work with have experienced sexual abuse and/or domestic violence, and their interventions help to ensure that women are not further victimised by the criminal justice system. They work closely with HMCTS and have good relationships with the judiciary. 6 Q19: What role can MOPAC play to ensure that gang-associated young women and girls have access to specialist provision to enable them to exit/escape gang violence? We support the findings of the Centre for Mental Health’s recent report A need to belong - what leads girls to join gangs which recommended that Police and Crime Commissioners, alongside clinical commissioning groups, children’s services and schools, “invest jointly in holistic, evidence based and gender-specific interventions for children and young people of all ages to prevent violence and gang membership.” The research findings, based on evidence drawn from point-of-arrest health screenings, demonstrate the value of such schemes as “young women involved in gangs had a threefold greater risk of health and social difficulties compared with average youth justice entrants and over double the number of vulnerabilities of other females being screened”.25 Given this accumulation of factors amongst girls in gangs, it is essential that prevention services are geared towards known risks such as parental imprisonment, experience of victimisation (particularly sexual and physical abuse) and engagement in sexually harmful behaviour, poor school attainment (including periods of exclusion), and early-onset behavioural and mental health problems. Importantly, researchers found that girls identified as being in gangs were receptive to offers of support, and with “nine out of ten of those…offered further support staying in touch with…services”26, it is clear that such services have the potential to provide permanent routes out of gangs for vulnerable girls and young women. The interim report of the Office of the Children’s Commissioner Inquiry into Child Sexual Exploitation in Gangs and Groups has also made a number of important recommendations to improve practice in this area, especially in relation to cooperation and intelligence-sharing between police and other agencies, which we support.27 We note that the MOPAC consultation paper draws on the research of Carlene Firmin, who has been centrally involved in the OCC Inquiry. She is also on the Board of the Prison Reform Trust and involved in developing our strategy to reduce women’s imprisonment. The Mayor of London and the Deputy Mayor for Policing have the funding and strategic capacity to collaborate in the commissioning of services aimed at prevention, can determine policing practice, and ensure that policing priorities on the ground reflect those set at a strategic level. We would welcome a greater focus on, and investment in, gender-sensitive policing, including training for female police officers in identifying and supporting girls and young women who may have been sexually exploited. Given the high-level of health-need identified by the Centre for Mental Health’s research, health-funded liaison and diversion schemes, currently being rolled out nationally, provide another route out of the criminal justice system and into appropriate health services for gang-affected girls and young women, and should be supported by wider-triage schemes aimed at diverting low-level offenders from prosecution. 7 Q25: How can MOPAC ensure that the MPS improves its performance on prostitution-related offences with a focus on those who exploit women and girls involved in or exploited through prostitution? We welcome the Mayor’s commitment to targeting the demand side of prostitution and confirmation that criminalising those involved in prostitution is not the aim of his policy. Sentencing statistics show that, nationally, more people (387 women and 2 men) were proceeded against at the magistrates’ court for the offence of prostitution than for the offences of kerb crawling, aiding and abetting an offence of prostitution, exploitation of prostitution and trafficking for sexual exploitation combined.28 Whilst data specific to the MPS is unclear,29 we are concerned that London accounts for a significant proportion of the women directly involved in prostitution who end up in court each year. To ensure that the Mayor’s strategic objective of targeting those who exploit, rather than those who are exploited, translates into policing practice on the ground, we recommend the introduction of a presumption against prosecution for those directly involved in prostitution, and/ or a pilot scheme offering sex workers access to services aimed at supporting them out of prostitution, instead of prosecution. We do not support the use of Anti-Social Behaviour Orders as a tool to sanction women involved in street-based prostitution, given that ASBOs are prohibitive, rather than supportive, orders. Women involved in prostitution need targeted interventions to support them to exit (see answer to Question 9 above). We would also caution against use of the new anti-social behaviour toolkit for such offences once introduced. Between June 2000 and December 2011, 364 ASBOs were issued to women in the Greater London criminal justice system area. Of these, 159 were proven to have been breached, although court statistics show that the number of occasions on which breaches over the same period were proven was significantly higher, at 721.30 Research has highlighted the complex, multiple drivers to involvement in prostitution31 and it is essential that support services are designed to meet the specific needs of this vulnerable group (see answer to Question 9 above). Viewing involvement in prostitution as a public health, rather than criminal justice, issue and taking a harm-reduction approach to drug use where it is a clear driver to engagement in sex work, would ensure that such individuals are not criminalised for their health and welfare-related needs. The Ipswich/Suffolk Street Prostitution Strategy (discussed above) provides a model that could be adopted in London. The aims of the strategy include: ● To develop routes out and assist children and adults out of prostitution and sexual exploitation; and ● To tackle the demand for sexual services and identify those who are controlling and profiting from sexual exploitation and those who are coercing individuals and prosecute where appropriate.32 A recently published evaluation of the strategy, and its multi-agency delivery, found “it had had clear and sustained success” in eliminating kerb crawling, providing routes out of prostitution and embedding prevention services, including for children 8 and young people at risk from sexual exploitation. This has been achieved without an apparent displacement of prostitution activity to neighbouring areas. The study estimated significant savings to the criminal justice system through reductions in crime, arrests and time spent in custody. We support the commitment to focus policing efforts on identifying traffickers who profit from the trade in women and girls, but it is vital that victims of trafficking remain at the forefront of policing considerations where trafficking is suspected, and are formally identified as victims at the earliest opportunity to enable them to access support. As a designated First Responder with the authority to refer to the National Referral Mechanism (NRM), the MPS is central to ensuring that victims receive the help and support they are entitled to, and are in turn empowered to help bring their traffickers to justice. Despite the existence of this framework, research published last year found that instead of being identified and referred for processing through the NRM, many potential victims of trafficking (nearly half of whom were trafficked specifically for sex work) ended up in custody for offences they had been coerced into committing. Based on interviews with 103 foreign national women in prison or immigration removal centres, researchers gathered evidence indicating that whilst more than a third (43 women) were victims of trafficking, only 11 were processed through the NRM. The research highlighted the following problems that the MPS need to address: ‐ the culture of disbelief many women encountered when disclosing their experiences; ‐ a lack of understanding of the complex factors (coercion; threats of violence to family members; confiscation of identity documents etc) which were factors in many of the victims’ offending; ‐ the failure as First Responders to accurately identify potential victims; ‐ failure to respond to victims’ disclosures with a full police investigation into the actions of traffickers; ‐ women’s fear of police, confusion and lack of awareness of their rights on arrest often exacerbated by language barriers and lack of access to interpreters. One victim of sex trafficking, arrested for false documentation, described her experience thus: “At the police station I was confused. They spoke quickly. They never asked if I needed an interpreter. I did not understand what was going on. I was crying…I just wanted to tell them everything – I wanted them to listen and understand. The solicitor just said ‘say no comment, no comment, no comment’. The only thing the police told me I could do was to make a phone call. Did they not see I was a foreigner and very frightened? No one would let me talk to them.”33 9 In instances where victims of sex trafficking were open about their experiences, police interview notes demonstrate the standard response to such disclosures: “What you’ve told me today does not make a great deal of sense and I’ve pointed to the fact that you come across quite sensible and you are trying to tell me that for seven years you‘ve been basically held, held captive for seven years.” “If this is what happened to you, why did you not come to the police for help when you got away?”34 Researchers also found three dominant offence categories for which the women they interviewed had been charged and sentenced: offences relating to the production of cannabis; importation of Class A drugs; and use of false instrument with intent and other offences of fraud and possession of false documents. In light of this pattern of offending, the report authors called for an exploration of “different ways of increasing awareness of trafficking indicators by the police…when making arrests for offences…where the incidence of links between the offence and trafficking is highest”.35 One way of doing this might be to design a checklist for use by arresting officers in cases involving foreign national women who meet the offence criteria to probe indicators of victimisation. We also note the recent decision by the Lord Chief Justice and the Court of Appeal affirming that where there is evidence that an offender is a victim of trafficking then the individual should not be prosecuted but should be referred for support and assistance in accordance with the UK’s international obligations. This case involved five victims of trafficking, including a Ugandan woman who had endured “prolonged exposure to involuntary prostitution and enforced control” and whose offence of using a forged passport was directly linked to this.36 We recommend that MPS guidance and training should be reviewed and steps taken to improve the identification of and responses to victims of trafficking. Prison Reform Trust 9 August 2013 1 Ministry of Justice (2012) Prisoners’ childhood and family backgrounds, London: MoJ Janet Loveless (2010) Domestic Violence, Coercion and Duress, Criminal Law Review, pp. 1-3 3 House of Commons Justice Committee, Women Offenders: after the Corston Report, HC 92, 15 July 2013 para 207, p.78 4 Light, M. et al (2013) Gender differences in substance misuse and mental health amongst prisoners London: MoJ 5 Cabinet Office Social Exclusion Task Force (2009) Short study on women offenders London: Cabinet Office 6 Caddle, D. & Crisp, D. (1997) Imprisoned women and mothers Home Office Research Study 162 London: Home Office 7 Table 1.6, Ministry of Justice (2013) Offender Management Caseload Statistics Quarterly Bulletin, October – December 2012, London: MoJ. 8 Hales, L. & Gelsthorpe, L. (2012) The criminalization of migrant women Cambridge: Institute of Criminology 2 10 9 Ministry of Justice (2012) Prisoners’ Childhoods and Family backgrounds, London Blades R et al, Care - a Stepping Stone to custody? Prison Reform Trust, London, 2011: includes a 7-point plan for policy makers and practitioners to improve outcomes for children in the care system 11 Independent Monitoring Board, Annual Report on HMP/YOI Holloway, 2012 12 Reforming Women’s Justice, Final report of the Women’s Justice Taskforce, Prison Reform Trust 2011 13 Making the Difference: the role of adult social care services in supporting vulnerable offenders, joint briefing by ADASS, Centre for Mental Health, Prison Reform Trust, and Revolving Doors, Prison Reform Trust, London, 2013 14 Talbot J, Prisoners’ Voices, Experiences of the criminal justice system by prisoners with learning disabilities and difficulties, No-one Knows, Report and Final Recommendations, Prison Reform Trust, 2008. 15 Poland, F. et al (2012) EVISSTA 2: Evaluation Research Study of Ipswich/Suffolk Street Prostitution Study Norwich: UEA 16 http://www.suffolk.police.uk/newsandevents/newsstories/2012/may/prostitutionstrategysuccess/idoc. ashx?docid=aa28f25f-c38e-4b60-af2f-05b640fd052b&version=-1 17 http://www.trust-london.com/whatwedo.html 18 Singleton, N. (2013) The challenge of change: Improving services for women involved in prostitution and substance use London: Drugscope 19 All data provided by Ministry of Justice Analytical Services 20 Radcliffe, P. & Hunter, G. (2013) The development and impact of community services for women offenders: an evaluation London: ICPR 21 House of Commons Justice Committee, Women Offenders: after the Corston Report, HC 92, 15 July 2013 22 Light, M. et al (2013) Gender differences in substance misuse and mental health amongst prisoners London: MoJ 23 Cabinet Office Social Exclusion Task Force (2009) Short study on women offenders London: Cabinet Office 24 Breaking the cycle for defendants and offenders with emotional and mental health needs, London Probation Trust and Together for Mental Wellbeing; See also A common-sense approach to working with women with health and wellbeing needs in the criminal justice system, Feb 2013 www.togetheruk.org 25 Khan, L. et al (2013) A need to belong: What leads girls to join gangs London: CMH, pp. 2 26 Ibid. pp 3 27 “I thought I was the only one”, Inquiry into Child Sexual Exploitation in Gangs and Groups, Interim Report, Office of the Children’s Commissioner, November 2012 http://www.childrenscommissioner.gov.uk/info/csegg1 28 Table S1.1A, Ministry of Justice (2013) Criminal Justice Statistics Quarterly Update to December 2012 MoJ: London 29 Hansard HC, 16 July 2012, c550W 30 Justice Statistics Analytical Service, Ministry of Justice 31 Drugscope (2013) The challenge of change: Improving services for women involved in prostitution and substance use London: Drugscope 32 http://www.suffolk.gov.uk/assets/suffolk.gov.uk/Emergency%20and%20Safety/Community%20Safet y/2011-10-11%20Suffolk%20Prostitution%20and%20Sexual%20Exploitation%20Strategy.pdf 33 Hales, L. & Gelsthorpe, L. (2012) The criminalisation of migrant women Cambridge: Institute of Criminology, pp 58 34 Ibid. pp 59 35 www.crim.cam.ac.uk/people/academic_research/loraine_gelsthorpe/criminalreport29july12.pdf 36 http://www.bailii.org/ew/cases/EWCA/Crim/2013/991.html 10 11
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