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Oral evidence: Human Trafficking - 07 06 23, HC 1142

Oral evidence, 7 June 2023.

Witnesses

Neelam Patankar, Professor Teela Sanders and Dr Ben Brewster.

Chair

Good afternoon and welcome to the Home Affairs Committee. This is the fourth evidence session in the Committee’s inquiry on human trafficking. This afternoon, we will discuss the role of technology in facilitating trafficking. An important part of the chain of human trafficking is the use of online technology, particularly when it comes to victims of sex trafficking being advertised to potential sex buyers. Evidence given to this inquiry suggests that victims of sex trafficking are commonly advertised for exploitation on pimping websites, also referred to as adult services websites—commercial websites dedicated partly or solely to hosting adverts for prostitution. We have a number of witnesses with us this afternoon. Unfortunately, Dr Ben Brewster is held up in our security line; we expect him to join us shortly. Could I ask our other witnesses to introduce themselves to the Committee? Professor Sanders, would you like to start?

Professor Sanders

Thank you, Chair. My name is Teela Sanders. I am a professor of criminology at the University of Leicester, and I have been working in research on the sex industry for 25 years.

Neelam Patankar

I’m Neelam Patankar. I am representing Vivastreet, where I am the managing director. We are an online classifieds platform that hosts adverts for goods and services, including adult services.

Chair

Neelam, we know there are obvious indicators—red flags, if you like—of trafficking and other criminal activity on these websites. We have been told that those would include: a man placing or paying for a prostitution advert for a woman; an individual paying for or managing the adverts for multiple women; or the same phone number being listed in the adverts for multiple women. Those would be quite obvious signs. Does Vivastreet allow any of those practices?

Neelam Patankar

I think it would help the Committee to understand our entrance into this space, and more importantly, how we tackle some of the areas that you have spoken about. Vivastreet, as I mentioned, is an online classifieds platform. We operate in, I guess, a more traditional sense, but we found sex workers attempting to post adverts in our adult dating category. At the time, we sought legal guidance, and we created what is known today as our escorts and massage category. It was very simplistic to think we could simply create a category and that would be it. We very quickly understood how incredibly complex this area of work is, the enhanced need for safety, and the duty of care that we have as a business. It really embarked us on our mission of ensuring safe, trusted advertising, free from stigma. As you rightly pointed out, this can be exploited, and you have set out some of the indicators. As a business, we have a vast range of measures in place to tackle, identify and disrupt this type of behaviour. If I may, I will talk to you about some of these measures, including on the phone number indications.

Chair

We are limited on time, because we are expecting votes at 4 o’clock, so could you address the question I asked, about men placing adverts and the use of the same telephone number for multiple adverts? That would be helpful.

Neelam Patankar

Yes, I will definitely keep it as concise as I possibly can. As mentioned, this is incredibly complex; you have probably heard several times how complex human trafficking can be. That is also very true of the nature of sex work. Regarding phone numbers being used multiple times, yes, that is an indication of human trafficking, and it is one that we manage and monitor within the business, but it is also true that some people in sex work have multiple phone numbers. We have a safeguarding team in our business that is dedicated to reviewing, exploring and investigating any suspicious behaviours, such as those that you mentioned. This team comprises many different skillsets, ranging from ex-law enforcement and data analysis skills to customer service skills. The team will explore proactively any potential indications of human trafficking, and then work with a law enforcement unit that we refer to as TOEX, which is Tackling Organised Exploitation. They cover a vast range of exploitation, including, thinking specifically of Vivastreet, sexual exploitation and human trafficking. Once we have assessed the indicators that you mentioned, we will provide that data to TOEX, which will manage that request. It will then come back to us through a police request, if appropriate. Those are the areas of information that we provide, but it is really important to understand that this is an incredibly complex space, as we acknowledge, and anyone operating in it must be aware of the risks.

Chair

Are you saying that the indicators that I just asked you about would be identified by your team, and the adverts would not get on to your website?

Neelam Patankar

It would be identified in a number of ways. First and foremost, we have a partnership with the world-leading anti-trafficking software provider, whose work includes them scanning the entire internet for problematic material. That problematic material is then fed back to Vivastreet. We will upload that dataset into our processes and systems.

Chair

I am still not quite clear. I have asked you specifically about men placing or paying for an advert for a woman; an individual paying for a number of different adverts; or the same phone number being used repeatedly. Are you saying to me that those adverts would never get on your website?

Neelam Patankar

A male paying for an advert, we do not allow. That is not something that we accept on Vivastreet. An advertiser who has several phone numbers, however, comes under the complexity of sex work, I am afraid.

Chair

A man placing an advert for lots of different women—

Neelam Patankar

Would not be accepted on the platform today.

Chair

You would not allow that. Yet your modern slavery statement states that you allow men to advertise women for prostitution and suggests that you allow individuals to post adverts of multiple different people. That’s what your modern slavery statement says.

Neelam Patankar

That we allow males to pay for—that’s not correct, no.

Chair

That’s not correct. So your modern slavery statement is not correct?

Neelam Patankar

I can double-check and see if there is a typo. I can ask my team to look at that, but we do not allow males to pay for women, no.

Chair

Oh. Today I had a look at Vivastreet. There are 14,065 adverts listed under the category that you have described, “UK Escorts & Erotic Massage”. I searched for adverts in my own city of Hull and found 59 adverts listed for Hull. Of the 59, 27 raised my concern straightaway: either they shared a phone number with another advert, or they used duplicate text, suggesting to me that someone was copying and pasting. Could you explain to me how those adverts have been allowed to get on to the website?

Neelam Patankar

Yes. As part of Vivastreet and how we operate—on the adverts that you have referenced, it could definitely be true that you have identified adverts that have a shared phone number or a copy and paste of an advert. There are two parts to understand here: one is genuine sex work behaviour, and two is the processes that we have within the business. Said advert would then be vetted through automated moderation, manual moderation and a number of safeguarding processes that our business has.

Chair

So you’re saying that these 59 adverts that I’m concerned about have gone through all your vetting procedures and you’re fine with them—they can go up.

Neelam Patankar

They would have gone through our vetting procedures—correct. If, somehow, there is an instance in which there is an air of suspicion—that would have been managed by the safeguarding team that I was referencing. This safeguarding team will still—if it somehow has missed our automated moderation, if it’s somehow missed by our human, manual, moderation, if it’s somehow missed through various other processes—

Chair

It’s 50%—over 50%—of the adverts in Hull that I was concerned about, so I have sent that information to Humberside police this afternoon.

Neelam Patankar

Excellent. May I just continue? If it has missed all those processes, our safeguarding team will be assessing those adverts, and we have a very—

Chair

So you’re going to go away and assess those, are you?

Neelam Patankar

They already would have. We have an incredibly low threshold.

Chair

Really?

Neelam Patankar

Part of when we refer content and data to the police is that we are asked explicitly by law enforcement to keep these advertisements live on our website. The reason why they would want them to continue to be live on our website is to not disrupt any investigation and alert the people. I understand it’s incredibly uncomfortable to view when you can find adverts that potentially have harmful indicators, but, for law enforcement to conduct their investigations, it’s important that we don’t disrupt that or alert people by removing them.

Chair

So you’re telling me that all the cases that I have referred to, these 27 cases, are all under investigation by Humberside police.

Neelam Patankar

Not at all. It could be that they are under investigation—

Chair

It could be, or it could be that they have just got through the system that you say works so effectively.

Neelam Patankar

Or it could be that they are genuine sex workers.

Chair

We have a number of questions, so I just want to ask you a couple of other things. A BBC “Panorama” investigation into Vivastreet discovered that one phone number had been used in 78 adverts. What do you say about that?

Neelam Patankar

That is a documentary that I obviously have viewed and was incredibly uncomfortable in viewing. On the 78 phone numbers, we did request the data from the BBC to understand how that has managed to happen.

Chair

But you’re the company that allows these adverts to go up. Why are you asking “Panorama”?

Neelam Patankar

We have asked for the data because it is very important for us to learn from anything that has happened incorrectly, and unfortunately we were not provided with that information. When assessing our own dataset, we try to replicate, and the reason we asked the BBC is that we couldn’t replicate the 78 phone numbers. But to be perfectly honest, we should have verified every single phone number—we definitely should have. The business has been so focused on some of the bigger safeguarding items that, if I’m honest, that was completely missed on our side.

Chair

Seventy-eight numbers—really? Last, I want to ask you about this. In 2017, nine men were convicted of trafficking young Romanian women around the north-west of England for sexual exploitation. One of the traffickers was found to have spent £25,000 advertising victims to sex buyers on your website. Police have revealed that this high level of spending by one man on prostitution adverts for multiple women prompted your company not to refer this man to the police, but, to actually give him his own account manager. Could you explain that to me?

Neelam Patankar

Yes. As I said, on our entrance into this space, we operated very naively once upon a time. Unfortunately, the case that you are referring to does exist, and has existed, on Vivastreet. Like I said, it was a time when we operated extremely naively. We do not have account managers today. We have learned, we have understood and we have adapted our processes.

Chair

So there are no account managers now.

Neelam Patankar

We do not have account managers today, no.

Chair

How many adverts would a man have to place on your website in order for you to be concerned?

Neelam Patankar

We do not accept male adverts.

Chair

Despite saying in your modern slavery statement that you do.

Neelam Patankar

I can certainly go away and double-check that; it may be a typo on that statement. But Vivastreet has evolved since first entering this space. We have learned. We have incredibly vast amounts of information. Our work with the Home Office and the National Crime Agency has really informed some of the safeguarding processes we have and accelerated that.

Chair

Okay, I have heard what you have to say about that. I think we will move on, but I just want to say that Dr Brewster is now in the room. Would you like to come and join us, Dr Brewster? We apologise—we have votes at 4 o’clock, so we started a little early. Apologies for that. Would you like to introduce yourself to the Committee?

Dr Brewster

Good afternoon, everyone. Sorry for being a little late. I am Ben Brewster. I am an academic from the University of Nottingham’s Rights Lab, where I lead our work on technology and exploitation.

Chair

Thank you very much.

Carolyn Harris

Let’s stay on Vivastreet. In 2018, the Paris public prosecutor’s office opened a criminal investigation against Vivastreet on charges of aggravated pimping. Shortly after this, Vivastreet suspended the dating section of its French website, which included the erotica advert listings. How far has that investigation gone? What is the latest news on it?

Neelam Patankar

For France, any interaction was prior to my position in post, I’m afraid. I am aware of the same information that you probably are. I cannot really give you anything more than that, unfortunately.

Carolyn Harris

What is your role in the company?

Neelam Patankar

Managing director.

Carolyn Harris

You don’t know what is going on with the public—

Neelam Patankar

This was prior to my position in post.

Carolyn Harris

You have taken on the role, but you have not made any inquiries as to what has happened with a criminal investigation against the work that you are doing.

Neelam Patankar

For France, as I said, it was prior to my position in post. A lot of our work and a lot of our efforts—we are a global marketplace—is very much centred on the UK and ensuring we have robust safety measures.

Carolyn Harris

Who owns Vivastreet?

Neelam Patankar

That is public information.

Carolyn Harris

If it is public information, who owns it?

Neelam Patankar

Mr Pons.

Carolyn Harris

And what companies are connected to it?

Neelam Patankar

In what regard?

Carolyn Harris

Does he own any other companies?

Neelam Patankar

We have many brands. The brand that I am responsible for is Vivastreet, and we have 15 marketplaces across the globe.

Carolyn Harris

Do you allow anonymous payments on your website, or do you have to verify your identity in order to be able to make a payment to Vivastreet?

Neelam Patankar

For every single transaction on Vivastreet, you must use a credit or debit card so that we can catch your digital fingerprint.

Carolyn Harris

So you cannot do it anonymously.

Neelam Patankar

We do have an anonymous payment method, but before you can access that anonymous payment method, it is incredibly important that the user transacts through a credit or debit card so that we can unlock the identification of who is posting.

Carolyn Harris

Why would you want to have an anonymous payment platform?

Neelam Patankar

It comes really to the heart of sex work by genuine, independent sex workers. They have wanted to use an anonymous payment method. Their families may not know what they do, and they do not want their identity to be shared in that way.

Carolyn Harris

Don’t you think that is an opportunity for traffickers to be able to exploit your system?

Neelam Patankar

For anyone seeking to exploit, definitely, which is why we have introduced the first credit card or debit card, so that you are not anonymous when using Vivastreet.

Carolyn Harris

How many people work in Vivastreet?

Neelam Patankar

We have around 75 based in London.

Carolyn Harris

And what do they do?

Neelam Patankar

Traditional business roles. That can go from technology through to our safeguarding hubs, moderation and customer service.

Carolyn Harris

How many moderators have you got?

Neelam Patankar

Twenty-five.

Carolyn Harris

So you have 25 members of staff all moderating. What are they actually moderating?

Neelam Patankar

All content on the platform. For us it is very important. Technology has evolved, so yes, we do leverage a third-party provider to handle the automated side of moderation. But for us it is incredibly important that we balance that also with having humans view the content.

Carolyn Harris

Putting cards up in telephone boxes is illegal. Do you not think that Vivastreet has circumvented that by allowing people to do exactly the same thing as going to a telephone box and looking for women who are advertising, or somebody else who is advertising a woman’s services?

Neelam Patankar

I think the move to sexual services being online has changed the way that sexual services or someone providing sexual services operate. It has made it safer. A sex worker now has a choice. They can decide who they are seeing, when they are seeing them and also have the option to say no, which I am sure we can appreciate is easier to do on a phone call than face to face. We unlock digital tools for sex workers. We have partners that provide a range of safety measures. The UK support services are very fragmented, especially for sex workers. If you are an advertiser or—

Chair

Can I stop you there? We are not talking about sex workers; we are interested in women who have been trafficked, so let’s just get that clear, please.

Carolyn Harris

I would argue that the majority of women whose services are advertised on your site are women who have been trafficked, maybe not from another country to this country, but trafficked by a person into selling their bodies, and they themselves are probably not making any money from this. This is exploitation. Do you not accept that Vivastreet facilitates that through it being a pimping organisation?

Neelam Patankar

We are not a pimping organisation; we are an online classifieds website, first and foremost. You are correct that there is an avenue that can be exploited here, and I think any business that operates within this space needs to acknowledge that and understand the risks involved, because once you acknowledge and understand the risks involved within this space, you can have the right measures. For us, it all comes back to being a safe, trusted advertiser.

Carolyn Harris

Okay, so the women who are being advertised for sale, what work are you doing with them? Are you actually contacting those women and asking them whether they are aware, happy, prepared? Have they made the decision to be on your site as a commodity? Have they personally made that decision, or has the advert come in from a third person who you have done your verification checks with?

Neelam Patankar

We have a vast number of measures in place. For the example you are giving, we have incredible partners on the platform. We have worked with Justice and Care and STOP THE TRAFFIK to support our knowledge and awareness and understand how we can support better within this space.

Carolyn Harris

Do you do interviews, cold calls, whatever, with the women who are being advertised on your site as a commodity to be sold for sex? Are you as an organisation doing those welfare checks with the individual women, or do you just follow the advert, and if the advert passes, it goes on your site?

Neelam Patankar

We outreach to our community constantly.

Carolyn Harris

Do you do interviews with—

Neelam Patankar

If I may, we outreach to the community regularly. It is a big ethos of the business to understand our customers better, so yes, we do conduct regular surveys; yes, we do have phone calls to our customers; and yes, we do speak to the customers who are independent sex workers on our website to better understand what their needs are. It is very much how this business has evolved from where we were to who we are today of simply opening a category to working with the National Crime Agency, the Home Office and industry partners, such as National Ugly Mugs and Unseen, the modern-day slavery helpline. We have a vast number of partners in place that have helped inform us and improve and accelerate the measures we have while we operate here.

Carolyn Harris

No more questions, Chair.

Chair

I have just checked the modern slavery statement I referred to. In it, you have a case study that you use to reference your approach. Can I read this to you? It is case study 2. It says, “A male customer phoned Vivastreet’s customer service team regarding an issue with an online adult escort advertisement that he had placed on the platform.” You are using that as an example of a case, so that completely contradicts what you have told this Committee that you do not allow men to place adverts.

Neelam Patankar

The nature of trafficking, as I think has been established prior to this session, is generally towards the females. In that instance, no, a male cannot post or pay for an advert. If it is a male sex worker, yes.

Chair

It is a case study—it is your case study in your modern slavery statement referring to a man who has placed an advert on behalf of a woman, and you have just told the Committee that that is not allowed.

Neelam Patankar

It is not.

Chair

But it is in your statement. This is your modern slavery statement. It is a case study that you are referring to.

Neelam Patankar

Yes, so it is not permitted. Historically, once upon a time, yes, did we and have we learned from that? Yes.

Chair

But this is dated 24 March 2023.

Neelam Patankar

I would need to double check that statement in case there was a typo or something of that effect. I am incredibly sorry if I can’t—

Chair

It is signed by two directors of the company. Did you sign this?

Neelam Patankar

I would need to double check that.

Chair

You do not know whether you signed the modern slavery statement, and you are the chief executive, are you?

Neelam Patankar

I am the managing director.

Chair

You are the managing director, and you don’t know whether you have signed a statement.

Neelam Patankar

Where a male has been referenced—I would need to double check that. I am incredibly sorry. As I have said, the nature of sex work is incredibly complex. I appreciate that we are here to talk about exploitation, but it is important that we understand that this is an area—

Chair

It is very important that you do not mislead the Committee. I asked you a specific question. I have referred to a document that your company produces that contradicts what you have told this Committee.

Tim Loughton

I was not aware of the site, so I am interested in getting a better understanding of what it does. What was your turnover last year?

Neelam Patankar

Our accounts are publicly reviewed. We have disclosed our profit.

Tim Loughton

I am not aware of your company, so I have not looked at your public accounts. What was your turnover last year?

Neelam Patankar

£25 million.

Tim Loughton

How much of that turnover came from adult services advertising?

Neelam Patankar

We are a global brand. As I said, we have 15 markets across the globe. Adult services advertising is not something we specifically break down in our accounts, I am afraid.

Tim Loughton

Why don’t you break it down? Why wouldn’t you produce that as a public figure? You must know that figure, yes?

Neelam Patankar

Unfortunately, as there are other operators in this space—larger and bigger operators than us—due to commercial sensitivity that is not something that we disclose publicly. In answer to your question, to give you some idea, it is fair to say that it is the majority.

Tim Loughton

So over half of your revenue comes from adult services advertising?

Neelam Patankar

That would be fair to say.

Tim Loughton

Indeed, looking at your website, 18-plus or adult services are top of the list of what you do. The majority of your income comes from adult services. That is your priority area, effectively.

Neelam Patankar

Because of the risk and the need to be able to manage this, it is an area that we focus on heavily.

Tim Loughton

To give me some understanding, what can I advertise on your website under adult services?

Neelam Patankar

You are able to advertise yourself as an escort or a provider of massages within the adult section.

Tim Loughton

What detail could I go into on the nature of the services that I offer?

Neelam Patankar

We have our posting guidelines and rules that must be applied. You can describe yourself, and you can describe the nature of your service. We do not allow fully explicit content, but you can describe the nature of your service.

Tim Loughton

If I were an adult woman, the fact that I was offering sex services would be made very clear in the advertising. Okay. On the basis that you know that the majority of sex services are offered online in this country, and a substantial part of those services are offered by women who have been trafficked, you will be aware that this is not a complex area, as you constantly say it is, but a deeply problematic area. There is a high likelihood that the people advertising on your site, who may or may not be women, may be the victims or beneficiaries of trafficking. Is that fair to say?

Neelam Patankar

I think it is fair to say that there is a problematic area in this—100%.

Tim Loughton

What safeguards do you have? The minute somebody inquires about advertising on your website, what safeguards are there to ensure that the person is advertising of their own free will, for legitimate and legal reasons, as they see it, and not under duress from a pimp or a trafficker? What safeguards do you institute?

Neelam Patankar

Our safeguarding team is probably the most relevant thing to discuss here. First, as has been mentioned, we work with the world’s leading anti-trafficking technology and software company. Where they have identified, with high probability, highly problematic material, it will not be allowed or permitted on our website.

Tim Loughton

What is highly problematic material?

Neelam Patankar

Where they have assessed that it is highly probable that the data provided to us is from a human trafficking or organised crime group. Those details cannot then come on to Vivastreet. In the first instance, there is a barrier to entry.

Tim Loughton

What information would you then cap?

Neelam Patankar

I cannot go into too much detail because this is a public forum, but the main identifier is the phone number. It is the phone number.

Tim Loughton

Let’s do some role play; that might get to the nub of what we are doing. I am an Albanian criminal trafficker. I have several Albanian women in their 20s whom I have trafficked to this country, and I am profiting from their activities in the sex trade. I approach Vivastreet to put up an advert, pretending to be a 23-year-old Albanian woman offering sex services. How would you reveal me as not being the person in that advert?

Neelam Patankar

First and foremost, we stop any high-risk human trafficking countries from accessing Vivastreet. Let’s say that you’re in the UK and you’ve managed to access Vivastreet. We have a number of processes in place. The scrutiny you would be under would be dependent on the behaviours you demonstrate. If you were to demonstrate some of the indicators—if you do not speak English, or show some of the indicators just mentioned by Dame Diana—we will contact you and ask you for ID and proof of address. We will verify you in some way, shape or form. There are various layers—

Tim Loughton

I am an Albanian citizen who is legally in the United Kingdom. I speak good English and I am profiting from trafficking Albanian women who are here illegally and who will be in the sex trade. How do you identify me?

Neelam Patankar

It still depends on the behaviours you demonstrate. Yes, you speak good English, but there could be a number of indicators. In your instance, you would be a male payer, and that would not be accepted and would be stopped.

Tim Loughton

How do you know that I am a male payer?

Neelam Patankar

When you input your details to pay for the advert.

Tim Loughton

I use a false name. I have a name that could be a woman’s or a man’s name.

Neelam Patankar

Unfortunately, there is a loophole there. You are completely correct, and that can be bypassed.

Tim Loughton

If I described myself as “Nic”—so, I could be Nicholas or Nicola—you would accept that?

Neelam Patankar

We would still assess it. It would still come up to the team as a gentleman’s name, so that would be assessed and blocked.

Tim Loughton

Hold on. I could be using a woman’s name. I could be Lesley. How would you automatically know that I am not a woman and how do you know that I am not using a false payment card?

Neelam Patankar

If you came through just as “Nic”, as you mentioned, it would still come back to the team for intervention and to be checked up on. That is why having a human safeguarding process is so important to us. On stolen cards, a number of processes go behind fraudulent payments. We have a payment process, and we have payment processing systems in place, and we have a huge number of velocity rules. As a business, our mission is: safe, trusted advertising, free from stigma. Every process is centred on being as safe as we possibly can.

Tim Loughton

You say that, but I am trying to work out what it actually means in practice. I am an Albanian, in the United Kingdom legally. I have a debit or credit card that I have obtained legally that may be in the name of a woman, and I am seeking to place this advert. How do you stop me?

Neelam Patankar

As I said, there are a number of known behaviours you would have to demonstrate. Language we have identified—

Tim Loughton

We have dealt with every behaviour so far and you have not trapped me on any of them. How are you going to trap me?

Neelam Patankar

We have identified language.

Tim Loughton

I speak English very well.

Neelam Patankar

The fact that you are male has been identified. If you were to use multiple phone numbers, there is—

Tim Loughton

I am using one phone number for one woman, or one phone number for one woman who could turn out to be a whole team of women if I get multiple calls back to me.

Neelam Patankar

Again, it is very much dependent on the behaviour you demonstrate on the platform.

Tim Loughton

You keep saying “behaviour”. I am giving you examples of a person who is trying to commit criminal activity as a trafficker. I am trying to work out how you would identify and therefore prevent and report me. So far, I am getting away with it. Where would I get caught?

Neelam Patankar

So far, you would have had to pass the world’s leading anti-trafficking technology. You would have had to pass the payment team. You would have had to pass some moderation. You would have had to go—

Tim Loughton

Passing your moderation, okay. What is the moderation that I may get stuck on?

Neelam Patankar

As I mentioned, we operate through a combination of automated moderation and manual moderation. Our automated moderation tool understands through volume what we accept and what we do not. That very much scans and looks at the text you are putting in your advert. Let’s say that you have passed our automated moderation, and you have somehow passed our manual moderation and our safeguarding team. On every single advert Vivastreet has, there is a button to get you through to Unseen, the modern-day slavery helpline. I understand from the example you are giving—

Tim Loughton

There is a button to get you through to—

Neelam Patankar

To report an advert that you have seen—so that you can get through to Unseen, our modern-day slavery helpline.

Tim Loughton

Why would I report my own advert that I am trying to place?

Neelam Patankar

Well, it is for anyone else who may think it is problematic.

Tim Loughton

Okay. At what point in my trying to place an advert—I might actually be a trafficked woman—are there warning signs on your site saying, “If you are doing this under duress, or if you are not a legitimate person, here is the trafficking helpline,” or whatever it may be? Where do those warning signs appear?

Neelam Patankar

They sit in two areas. One is front-facing: there is a safety centre on every single advert that talks about the signs of exploitation and who you can speak to. There is an also an area within our membership area. Once you have created an account and created an advert, there is log-in access, and there is signposting there, too. If you will forgive me, I think the point that you are trying to get to is, “Is it possible?” Unfortunately, there is risk, and there is an area of exploitation that can be had in this space. That is why we have invested so much time in deeply trying to understand and work with the Home Office and the National Crime Agency to accelerate our measures and ensure that we operate as a responsible operator in this space.

Tim Loughton

I am sure you want to say that, but how many potential traffickers or pimps have you actually identified and then reported?

Neelam Patankar

First of all, I would hope there are not any on Vivastreet, but—

Tim Loughton

No, no—hold on. We have just gone through this whole exercise in which I am a genuine trafficker who is finding it very easy to evade all your safeguards—your wonderful safeguarding teams and your moderation and everything else—but I eventually get caught, somehow. How many people like me have been caught and subsequently reported to the National Crime Agency?

Neelam Patankar

We work with law enforcement. I think it may help to talk about how we work with law enforcement and some of the reports that we do.

Tim Loughton

How many people like me have been reported to the National Crime Agency?

Neelam Patankar

We don’t know—

Chair

You don’t know?

Neelam Patankar

In the scenario that you are providing of being a human trafficker, I would hope to say there aren’t any on Vivastreet. Unfortunately, we know this space can be exploited. It is why we work with the National Crime Agency and with law enforcement.

Paula Barker

How many has your company reported to—

Chair

Order.

Tim Loughton

Those two statements do not go together. You say that your site is vulnerable to being exploited by people like me, by its very nature, and it is all very complex. We agree with that. Then you say you hope that people like me don’t use your site. Well of course people like me use your site. If your systems, your safeguards, your checking, your moderation are worth a penny, then you will have caught some people, and hopefully those people have been reported to law enforcement agencies on suspicion of being traffickers and criminals. You should know, therefore, how many your organisation have referred to the police. It is a simple question. It may be that they are found to be not guilty, ultimately, but how many have you tracked and then referred to the police?

Neelam Patankar

In terms of our work with TOEX, the Tackling Organised Exploitation unit—that work where our safeguarding team proactively refers to that unit—it is very important to understand that we have an extremely low threshold. I would like to make that very clear. We do proactively report areas of information. Last year, we reported 1,000 proactively. That does not mean 1,000 cases of human trafficking; it is 1,000 cases where we have had some suspicion of some of the behaviours that you mentioned, and ensured that it has gone to the right unit and the right people to—

Tim Loughton

Okay. I don’t see why it was so hard to get that figure. You have reported 1,000 people. How many adverts have been placed in the last year in this area?

Neelam Patankar

On average, in the adult section, we have around 13,500 live adverts.

Tim Loughton

How many different adverts is that throughout a year? Obviously, they will not be there for the whole year.

Neelam Patankar

It was roughly 300,000 last year.

Tim Loughton

Okay, so last year you reported as suspicious 1,000 people trying to place an advert out of a potential 300,000-plus who did place adverts. That is a 0.3% interception rate. Do you think that is a fair reflection of the number of people who are using your website illicitly and are involved in trafficking?

Neelam Patankar

I think it is a reflection of us having a low threshold and reporting that amount of users, yes. I appreciate we are here to talk about exploitation. I don’t know if any of the academics—

Chair

Yes, we are going to come to them. Tim, are you okay for us to move on?

Tim Loughton

Well, I’m not okay, but let’s carry on.

Chair

Can I ask that we keep our answers and our questions quite short?

Alison Thewliss

Ben, may I ask you for a bit more information on technology and online platforms? Can you tell me a bit more about the type of technology that traffickers are using? Is the Government’s Online Safety Bill keeping pace with the different ways in which they operate?

Dr Brewster

Generally, evidence—when I say “evidence”, I mean strong, systematic reporting data—on the extent to which trafficking is facilitated through online platforms is incredibly anecdotal. Specific cases that get brought to the attention of the media or the public tend to be the focus of our attention. On the nature and extent of this, we do not really have any numbers, but we see anecdotal examples cropping up from every platform that would spring into your head. They cover recruitment to all types of exploitation, from sexual exploitation to child criminal exploitation through, say, county lines, and deceitful recruitment ads into exploitative employment and labour. Although we do not have a great understanding of the exact scale and nature of this, it is happening everywhere you think it is and would expect it to be. There are a lot of promising things in the Online Safety Bill, in terms of reducing reliance on the self-regulation of platforms when it comes to their duty to report, and to notify of issues, including trafficking. There is no one country that I would say is really leading on that.

Alison Thewliss

In this country, there tends to be lots of emphasis put on laws and not enough on enforcement of them. Would you agree that that is likely to be the case with the Online Safety Bill?

Dr Brewster

Absolutely. Enforcement in this domain is incredibly difficult because of the volume of content that we are talking about when it comes to large-scale platforms such as Meta and Twitter. There is the question of the capacity needed in order to enforce. That applies to the platforms and their moderation and protection mechanisms, and to the follow-up, once reports have come through to law enforcement and other services. Take the example of child sexual exploitation and abuse material—a lot of the promising work in this area comes from there. One of the huge issues it deals with is volume. In the US, there is a mandate on US-based electronic service providers to report CSE material to the National Centre for Missing and Exploited Children. It deals with millions of reports every year, and so few of those are triaged and followed up by law enforcement, because the capacity just does not exist. You can imagine that if a similar model was replicated here, we would have similar issues.

Alison Thewliss

Would it be worth putting more money into that side of things?

Dr Brewster

Absolutely, yes.

Alison Thewliss

Have the Government taken account of that and budgeted for it, do you think?

Dr Brewster

I am not aware of the current status on that, unfortunately.

Alison Thewliss

Professor Sanders, you were nodding.

Professor Sanders

Yes, definitely, on the huge amount of data that is coming to law enforcement. I am reporting on a project that is still live in which 23 police forces, including TOEX, are being interviewed on how they engage with ASWs on these investigations. It is very much the tip of the iceberg. They have a huge amount of data sent to them. One of the reasons why they want ASWs to be kept open is that they are a window into exploitation, so police can see what is happening. Lots of strong reporting comes from the main ASWs to the police, who can then investigate. Those investigations often take two years; they are very long term and intensive, and are cross-country, or cross-nation. It really is a resource question to get to the bottom of some of these very complex OCGs.

Alison Thewliss

Would you say the traffickers really have the advantage here?

Professor Sanders

Most definitely, in many ways, because they are hidden. They are often not in this country, or are being controlled from outside this country. There are concerns about when you should disrupt activity so as not to put people in harm’s way; how welfare checks for individuals can be done; and when it is right to collect evidence, and what the right amount is. It is very difficult for law enforcement. A point repeated by all the forces we spoke to was on the real difficulty in using the Modern Slavery Act in prosecution, because there is such a high threshold for evidence. Often, other types of legislation are used, particularly the Sexual Offences Act 2003, or even money laundering legislation, because of their much lower levels of evidence gathering. While there is a real lag, and not many things are coming to court—prosecutions are very low in this area, as we know—I think the police felt that some of their activities were about disrupting offenders rather than prosecuting and going through the criminal justice system—that lots of their investigative work and their surveillance of what was going on did more to disrupt than lead to prosecution. The tip-of-the-iceberg issue, particularly if we are thinking about the Online Safety Bill codes of practice that are to come out, is where is that huge amount of data going to go to? If it is mandatory that websites have to report information, which seems like a very good idea, where is that information going to go to, and how is it going to be looked at? What are the real operational issues here? What are the challenges here to get to the bottom of such huge amounts of data?

Alison Thewliss

One of the many aspects of the Illegal Migration Bill that trouble me is that victims of trafficking will be removed from the country unless they are able to help the police with their inquiries. From your experience, how much knowledge are victims likely to have? Would they meet that threshold of being able to stay?

Professor Sanders

That is a really good point, which has been repeated to us before. Our partner on this project is Unseen, the modern slavery helpline. The police and practitioners in the study said that most investigations and cases that are brought to court are victimless prosecutions, because victims do not want to engage; they do not want to give evidence. They want to leave the situation they were in and move to a safer situation, often staying in sex work; they just want to leave the context in which they were in. There is therefore a real issue with victimless prosecutions. There is also lots of criticism about the national referral mechanism. The police are saying that often it took 500 days for a decision, and that the Crown Prosecution Service will not look at a case until the national referral mechanism has had its look, so this is really long term and victims have just gone—gone into worse situations, returned home, or just cannot be found. There is that real issue of what is happening to the victims.

Alison Thewliss

Do victims know very much about the operation that has held them?

Professor Sanders

There is really good partnership work from the police, which was discussed—there are lots of really great examples of partnership work across the country—but the numbers of people that they are actually engaged with and of cases are really quite small. It is hard to keep in contact with victims as victims want to move away, so it not particularly a success story on that side, despite the efforts from the police and NGOs.

Simon Fell

Neelam, I am really interested in understanding the relationship between your organisation and law enforcement and what the process of making a report from Vivastreet to law enforcement looks like. I am also interested in whether you get feedback the other way as well—the police sending new alerts about people on your platform.

Neelam Patankar

Yes, we have always co-operated with law enforcement. In the most basic form, that could be on inbound requests. As I mentioned, we have a dedicated team—our safeguarding team—and a dedicated email address and a dedicated phone line for police. What that could look like is that the DPA or DPO is received requesting information. Our team then provides that information, and the individual who has conducted that report will be on hand, by phone or email, to follow up and talk to throughout that investigation. Our work goes from the basic reporting all the way through to training. We have received training from the National Crime Agency—and STOP THE TRAFFIK, but law enforcement specifically—and we have also provided training in terms of what information we have and can see. Our collaboration has then involved the National Police Chiefs’ Council, which holds a conference every single year. We present to that to talk about what we do as a business, how they can see indicators of things and what is publicly available within the business. We also talk about what information we hold, because sometimes it can be confusing, and what information can really help them. Feedback is incredibly important to us. We ask law enforcement for feedback continuously, for any interaction that we have. The feedback loop, which needs to come back into the business so that we can improve our systems and processes, has improved in the time that we have been working with the police. We receive more feedback now than we did a few years ago. Could it be better? Yes, certainly. That is something that we would agree with. However, we appreciate that, as Teela mentioned, cases can go on for a very long time.

Simon Fell

Thank you. Perhaps I did not express the second part of my question that well. What I was trying to get at is this: if a law enforcement agency has concerns about a particular individual or a group of individuals, does it send that information to you directly for you to look through your site and identify them?

Neelam Patankar

Yes.

Simon Fell

In that case, or in a case where your moderation team or a user of your site identifies someone who they are concerned about and reports, what happens then? Do they stay on your platform? Do they get de-platformed?

Neelam Patankar

It would go to two areas. If they came directly through to us and not Unseen, through the button that I mentioned, the first thing that the team would do is contact the police immediately. They would find out the relevant force and speak to TOEX, now that we have TOEX to speak to, and understand how they want us to act. As I mentioned, although we would love to take the advert down, unfortunately they request us to keep it live, because they do not want to disrupt the criminals and alert them to the fact that they have been monitored.

Simon Fell

Thank you. What is your level of dialogue with your commercial rivals? I imagine that many people advertise across multiple platforms. I do not know what your rival site is, but if your main rival identifies someone that they are concerned about—or perhaps law enforcement has approached them—do they share that information with you, and vice versa?

Neelam Patankar

Unfortunately not. It is incredibly important that we do not have dialogue with any other operator. Part of the work with the Home Office and the National Crime Agency involved a code of conduct for how the industry should be lifted to a better standard. We therefore have many good practices in place. The only dialogue has been in those working groups, not one to one.

Simon Fell

Is that because of legal barriers to sharing, police policy—they do not want you talking to each other—or is it a commercial decision?

Neelam Patankar

No, not at all. It is incredibly important, but many of these operators are international operators that, unfortunately, do not want to communicate. That is the biggest challenge faced by a lot of people in this space, or who have an interest in this space. We are always open to collaboration—it is a key ethos of the way we operate. Unfortunately, we do not see that with other operators.

Simon Fell

Thank you. Professor Sanders, I know you have done research about these sites being used to disrupt and prevent. Can you give us a bit more detail on what you found and whether you identified any good practice?

Professor Sanders

For sure. Our partners are the NCA, the NPCC and we work with Unseen as well. I want to flag how difficult it is to research in this area. We work closely with the NCA, but even with them as gatekeepers to ASWs, we managed to engage only five out of around 260 that operate in this country. That demonstrates the real underground nature of the operation. Obviously, Vivastreet are here and are very much part of the good practice model that we have been looking at, and how to enhance—

Simon Fell

Sorry to interrupt. The five you have identified—

Professor Sanders

Five we interviewed.

Simon Fell

Sorry, the five you interviewed. Do you have any idea of what percentage of the market they hold?

Professor Sanders

The main one—the biggest ASW out there—has not engaged with us. I do not think they are engaging with much law enforcement at all. That is problematic. I imagine that the percentage is probably 40%, perhaps 50%. The 260 or so that we have done scoping around fluctuate—they close, they open, they change. There is obviously a lot of surveillance at the moment, so it is very hard to track and see what is happening. We did reviews of about 17 to look at the types of things that they have that can assist people who are putting on adverts as independents, and to see whether there is customer service, reporting buttons through to Unseen, or information about red flags and exploitation. About half of the 17 we looked at have that, so there is emerging good practice on trying to raise standards. The NCA has worked with a small group of voluntary, willing ASWs, including Vivastreet, to come up with some gold standard practice. What is coming out is the need for much more stringent verification of who is putting on the profiles. Verification is a big issue for the Online Safety Bill—Ben might be able to say more about that. For example, is the person who is putting in the advert the real person in the verification process? A lot more could be done there; it could be more mandatory. At the moment, in many ASWs, there is a one-time verification. That is probably not enough; verification needs to be much more frequent. Stringent verification is a key thing. That needs to happen more, as well as proactive AI moderation, and human moderation because of the nuanced nature of that. There are ways that customers or sex buyers can be made more responsible, such as by not being anonymous and by making sure payment details are there. One of the really interesting things we heard from the police was the vast amount of financial data that ASWs hold—a bit like the banking sector, the finance sector, where, as we know, to check for money laundering they have various red flags and they have to report it. A similar type of process could be used for ASWs: if these things are flagged, there is a mandatory reporting process. Obviously, that will generate millions of reports every year, so what do you do with that? But we heard really great examples from the police, who would often do fraud investigations. We could see similar processes being applied to ASWs to really increase the level of responsibility, which would include not having anonymous customers or sex buyers. So that was some of the good practice there. I think there are real concerns from the police that if there was an approach to try to ban ASWs, that would just push this underground. They would not be able to find victims and do these investigations. There is real concern that any approach in terms of regulation must have the safety of individuals at the fore. Some of those types of suggestion came through on recommendations.

Simon Fell

That is really helpful; thank you. I will ask just one more question if I may. You touched on fraud, and the Committee has heard repeatedly that capability in that space is really limited. It varies between forces; it’s the luck of the draw as to whether you get a force that has the capacity to deal with it. What is your experience of law enforcement capability in this space? Does it differ around the country? Where is there good practice? And do you have any recommendations for what a dedicated police force could perhaps do?

Professor Sanders

That is a really great question. Everyone generally has a modern slavery unit and various amounts of law enforcement attached to modern slavery. Often, the police forces where there is a major transport hub, like an airport, or in a city centre tend to have much bigger and much more experience. We had really great examples from around the Gatwick area and the Manchester area. But then there are other, rural police forces that have not really addressed modern slavery in their area, because there is much less of it. There is a spectrum of good practice, or practice, across the country. The main thing is that we have TOEX, which I think is a five-year-funded Home Office set of law enforcement measures across the nation, divided into various regions. TOEX is a really important way of having an overview of what is happening nationally, because often this is all about moving around the country. I think TOEX is the really good practice that is coming out of here.

Simon Fell

Thank you very much.

Chair

Could I just clarify one thing? You said that if adult services websites were abolished—not allowed, made illegal—that would be a problem because it would force everything underground and it would be very difficult for the police to investigate. I don’t quite understand that, because if you are selling sex, you need men to find you, so how can it be more difficult if we get rid of these websites? They are going to have to find a way of—

Professor Sanders

The dark web—

Chair

But if punters can go on to the dark web, the police must be able to go on to the dark web.

Professor Sanders

They would, but it’s a resource question. At the moment, they can see everything; it is visible and available. You don’t need huge numbers of crime analysts to get into these spaces. We saw with SESTA-FOSTA legislation in the US in 2018 that when those websites were shut down, various other types of online technology basically just replaced them.

Chair

So it’s a matter of the police and their resource. That is the issue that needs to be addressed.

Professor Sanders

That is the issue, but not for consensual sex workers, obviously, who are the majority of people who use—

Chair

Sorry—"who are the majority of people”?

Professor Sanders

Who use these websites, yes. I did a previous project, called Beyond the Gaze, in 2018 in the UK. We did a huge amount of work surveying sex workers, police and so on, about consensual sex work and the various practices. That has obviously gone up since covid, with many, many people moving online to sell sex.

Chair

I would be interested if you could provide some information about what you describe as consensual sex work and what your indication is of the numbers of trafficked people.

Carolyn Harris

Yes, how do you know?

Professor Sanders

I could give you some information here now.

Chair

We have to move on, but if you could provide it, that would be helpful.

Paula Barker

Before coming to Dr Brewster, I want to ask Ms Patankar a question. How do your organisation and your safeguarding team verify the age of those selling sexual services?

Neelam Patankar

We have a third-party provider that we use. It is a specialist in that form of verification, obtaining that data and the encryption of that data. It is available. Again, it depends on some of the behaviours and on how rigorous we are with those checks. So it would be a case of a sex worker, or whoever is being verified, needing to upload their identification document, whether that is a passport, driving licence or national ID card, to the third-party provider we use. That would then be verified. The reason we used this third-party system is because they are the experts, and they ensure that the documents they receive are legitimate and cannot be falsified. So yes, we do have it, and we use a third-party tool.

Paula Barker

Surely passports and other forms of identification can be acquired fraudulently, so what particular system does your third-party provider use to ensure that it is not a fraudulent piece of documentation?

Neelam Patankar

That is exactly why we have used a third-party provider. I am not aware of the details of how they get to that place, but I can certainly try to follow it up and confirm with you. It is worth knowing that this third-party provider is also being leveraged by social media in some countries. It is used by Sainsbury’s and by the Post Office, so it is quite a credible provider.

Paula Barker

Are you able to share the name?

Neelam Patankar

Yes, it is Yoti.

Paula Barker

Throughout the course of Vivastreet being in operation, have there been any referrals to the police for anyone who has fallen through the net and has been found to be a child? Is there anyone who failed the verification checks?

Neelam Patankar

Prior to verification checks, unfortunately, there was one incident, which sparked us to introduce age verification. There was one incident, but we now have verification in place to ensure that we have measures.

Paula Barker

And how old was that child in the first instance?

Neelam Patankar

I am not completely sure. They were underage.

Paula Barker

Thank you. Dr Brewster, in relation to the human trafficking of children, what needs to improve in how the police use technology in this area and in trafficking investigations as a whole?

Dr Brewster

I am not too sure about the police’s use of technology, but the use of technology to detect potential issues is an issue across the board. You need collaboration between electronic service providers like those mentioned, the police and third sector who have expertise in things such as child sexual exploitation and abuse material. I think we need attention on broader forms of trafficking and exploitation involving children, not just on the dissemination of exploitative materials, which is the focus of policy and energy in this agenda at the moment.

Paula Barker

In respect of trafficking victims, we know that 75% of victims trafficked for sexual exploitation are advertised via adult services websites. Do you have any indication of how many of those are children?

Dr Brewster

I do not know. I don’t have that evidence.

Professor Sanders

Where does that statistic come from? I have not heard that.

Paula Barker

The OSCE.

Professor Sanders

That does not correspond with what we have from Unseen, which is the modern slavery helpdesk. This is some of the information that I wanted to give. We did some historical analysis of their data from 2017 to 2021. They had just over 8,000 reports of modern slavery in that time; 1,236 were cases of sexual exploitation and only 130 were connected to adult service websites. So from the Unseen perspective, it is relatively low, but it is increasing. In the data for ’21-22, they saw a 66% increase in this, among sexual exploitation. However, the main areas of increase were labour exploitation and, surprisingly, exploitation in the care sector, which was really surprising—reports to the helpline have gone up over 1,000%. From our perspective around shape and nature, it is very, very difficult to get numbers on extent. Obviously, with the impact of covid and most things moving online, there is an increase in reporting around how all technology is being used, but the extent is very difficult to know, so I am really going to look into that 75%.

Paula Barker

Thank you.

Marco Longhi

Ms Patankar, to what extent are you concerned that vulnerable people could come to harm because of the use of your website for sexual purposes?

Neelam Patankar

Incredibly. It is part of our mission: safe, trusted advertising free from stigma.

Marco Longhi

So you are very concerned.

Neelam Patankar

It informs all of our practices, to ensure that we do provide a safe space.

Marco Longhi

Right. If I could perhaps come back to you, could I ask the two academics—if I may address you in that way—to what extent you believe that either Vivastreet, if you have done that detailed analysis company by company, or companies such as Vivastreet online could be platforms that are enabling harm to vulnerable people?

Dr Brewster

I would be careful about using language like “enabling” and “facilitating”. Platforms have—

Marco Longhi

What other language would you use?

Dr Brewster

I think there is a lot more work that platforms could and should be doing. We have got to a point where the horse has bolted away from the cart a little bit: the technology has led, and issues around safeguarding, exploitation and harm have taken a back seat. Things like security, privacy and safety-by-design principles have not been integrated into these services, so that when we get to points where we have issues, features are already in place that would have been able to prevent and detect many of them. A lot of things are being retrofitted based on the fact that bad incidents have happened and we have gone back to rectify them. I think we need to change the model of thinking around how, when new technologies are introduced—we see all the time that new technologies are coming through, such as virtual reality; dark web has been mentioned earlier today—we get out ahead of issues emerging before we go back to fix them. State regulation, rather than relying on the technology sector itself to self-regulate, has got to be the trajectory moving forward.

Marco Longhi

Self-regulation?

Dr Brewster

At the moment, the sector is essentially self-regulating on these issues, so a shift away from that is what I am suggesting.

Professor Sanders

I agree. We are at the point where ASWs are all self-regulated. Only a very, very small percentage of them come to the table to work with enforcement and with the gold standards that the Home Office and the NCA have tried to develop. It is only a small percentage, because there is no mandatory requirement yet, so I think the OSB does provide an opportunity to catch up in some ways—although with the code of practice that will be written, again, it is about “How is this going to be policed? How are websites going to be held accountable? Who is going to operationalise the huge amount of data that they might have to mandatory-report?” It is very much catch-up. On prevention, in terms of how we stop people being harmed, we really need to think more clearly about how digital technologies can help us.

Marco Longhi

Actually, I think that was my angle on this. Ms Patankar, you acknowledge that you are incredibly concerned. If concern is that high, would it not be a logical conclusion that either more restrictions, or even stopping trading in this marketplace—as you might put it—would be the best option? It seems apparent to me and to the rest of the Committee that it is almost impossible that self-regulation or the types of scenarios that my colleague Mr Loughton explained could be robust enough to stop harm from happening.

Neelam Patankar

I have a few things on this, if I may. As I think both academics have mentioned, it should not rely on operators to self-regulate, because many do not—we do, but many operators do not—so I think some form of regulation, holding the standards that the Home Office, the NCA and the working group have developed, should come into force. I know that the Online Safety Bill carries a lot of the spirit in which we worked on the code of conduct. So, first and foremost, we cannot continue to rely on self-regulation; we need this space regulated. In terms of not trading, if any law is passed, we will comply and we will follow—we are a responsible operator—but I think we need to be very mindful of unintended consequences. Yes, the aspect of genuine independent sex work and being online makes people safer. Like I said, it gives them choice—it allows them to choose who they are seeing and go through a vetting process of whoever is purchasing sex—and it unlocks many digital tools. But more importantly, there will be a continuation of operation through international players. If ceasing existing or operating as an adult service website seems to be the answer, yes, Vivastreet will comply, but unfortunately how do we deal with the problem of international operators that do not have to succumb to UK law? They will continue to operate.

Marco Longhi

Okay. I am coming to the end of my questions. I suppose that this is less important to me, but to what extent are you and the leadership team of your company concerned about the reputation of your company?

Neelam Patankar

I think any business would be. One of the things that we have accepted with operating within this space—again, it is very true to our mission of safe and trusted advertising free from stigma—is that the more we collaborate and communicate with law enforcement, the Home Office and so on, and the more we proactively report through TOEX, the more visible we are. Unfortunately, there are some things, such as the issue around exploitation today, that a business tends not to want to be very visible for, but we have accepted it. It is part of us living to our mission.

Marco Longhi

Unlike my colleague, and I mean no disrespect, I was not aware of your company before, so I typed it into Google here—I hope I am not going to get into trouble with the Parliamentary Digital Service. The first sponsored site is Vivastreet, because that is what I searched for, and immediately below it is justshags.co.uk. Now, I thought that I had understood your platform to be a marketplace for the trading of all sorts of things. Why do you think that that comes up immediately after your company?

Neelam Patankar

Because of the association with the adult space.

Marco Longhi

You are associated with all sorts of trade. Why would that one come up?

Neelam Patankar

We are indeed. There has been a particular focus in the adult space over recent years to develop so many of the measures. Like I said, it is very important if you are operating in this space that you understand the complexity, but you also understand the risk that is associated. As a business, we do understand that. It is why we have implemented so many processes and we talk with so many people, to ensure that as a business we are operating responsibly and can put in the measures that we are comfortable with.

Marco Longhi

Finally, could I ask something particularly to the academics here? I hope you don’t mind my addressing you in that way. I am particularly concerned about the human trafficking element of this, because that is what the scope of this Committee is. To what extent do you believe that Vivastreet and other such companies are contributing to human trafficking, either within the UK or from outside the UK with people being brought into the UK? Do you have any data that might suggest how that might be playing out?

Professor Sanders

The data element is really difficult. I would not want to put a number on it, just because it is underground and it is hidden. It is probably a question for the NCA particularly and the NPCC. Again, I think it is difficult to make blanket statements: I would not say that all car washes or all nail bars are hugely contributing to human trafficking, but we know that those are spaces where labour exploitation happens. In the same vein, some ASWs, particularly those that do not engage with law enforcement, are clearly letting their platforms be open and inviting to traffickers and criminals. That is not some of the key ones, but then there are lots and lots out there, and because there are no mandatory requirements, they are just left to the market. So yes, it is clearly some, because there are no other ways of regulating, but it is not all.

Dr Brewster

Just to add to that, I think the websites are seen from a trafficker’s perspective as a way of increasing their anonymity, distancing themselves from the criminality that they are perpetrating. I think in some ways the ecosystem of the internet and the way we interact with it—to look for work, to buy and sell goods and services—creates this environment where those who are looking to do harm and profit from criminality can do that with an added level of anonymity, and with potentially a greater reach and scope for what they are doing in terms of profitability.

Marco Longhi

Would you agree—sorry, Chair; I did think of something else to ask—that the very existence of these companies and the ability to trade in such a way as they do today, with seemingly very little control, is actually contributing in some significant degree to human trafficking?

Professor Sanders

I don’t think there is the evidence to say “significantly”.

Dr Brewster

We just do not have the numbers. It is hard to put an adjective to it; I think we just do not have the numbers.

Marco Longhi

Okay.

Chair

But we do acknowledge that they are facilitating and enabling the trafficking, don’t we? Dr Brewster indicated assent.

Lee Anderson

Just a couple of questions from me. I think, Ms Patankar, you said that there was a turnover of £25 million.

Neelam Patankar

Last year it was £21 million.

Lee Anderson

How much is actually reinvested into safeguarding, and how many safeguarding workers have you got?

Neelam Patankar

There are different avenues of safeguarding, but it is within the DNA of the business. Everyone, in some way, shape or form, will have that as a priority. Our safeguarding team is a team of five. Our moderation team, like I said, is a team of 25, and we have customer service staff as well.

Lee Anderson

Just one more question, about these services that you offer online. I would imagine that most reputable companies, whether that be a supermarket or whatever, have some sort of mystery shopping—this is not going where you think it is going—where the staff, services and product will be checked out by an employee of the company. Have any of these workers actually had a visit on site—obviously not to provide the services they are offering, but so that somebody from your company can sit in a room with that young person to decide whether or not they are vulnerable, injured, a drug addict or, indeed, a child? Does that ever happen?

Neelam Patankar

Yes. Our safeguarding team, as I mentioned, has a combination of skillsets, but also—

Lee Anderson

Are they booking as a client when they do that?

Neelam Patankar

It is ex-law enforcement. They have been within this space, and they have seen some of the horrific things that can take place. I myself have been on site; I have been jointly with the NCA on a site visit to understand the other aspect and the other area of this exploitation that can take place.

Lee Anderson

Just to be clear, then, you have staff who will actively book an appointment to see a sex worker for services under the guise of a punter.

Neelam Patankar

No.

Lee Anderson

No?

Neelam Patankar

The direct answer to your question is no.

Lee Anderson

Why not?

Neelam Patankar

But have we experienced being on site? Yes. Have we mystery-shopped—

Lee Anderson

Would you say that it would be fair to actually mystery-shop these services properly, where the sex workers are unsuspecting and you can actually get into a room with them and have a proper conversation about their safeguarding? Wouldn’t that be a better way to do it?

Neelam Patankar

I understand that you are looking through the lens of exploitation, but the reason we would not do it is that that would be a genuine sex worker believing that she was about to have a visit and expecting to take a booking for that day. If we then turn up and we are not a genuine customer, unfortunately it may put her in more harm, to take a riskier booking later on.

Lee Anderson

If you genuinely had the best interests of these people at heart, would you not just ignore what you have just said and actually go into these places on a random basis just to check that among the people subscribing to your website and paying you all this money, there are no children? Surely you would do that.

Neelam Patankar

I think it comes back to the point I was making about if we were to mystery-shop in this way. Have we visited a site? Yes: I have even visited a site, and I have people within my team who have. That is the way we have chosen to do it, because we do not believe in mystery shopping in the way you are suggesting. When you understand the independent sex worker’s perspective, taking a booking that is not actually a booking is not beneficial to a customer.

Lee Anderson

Has anybody ever tried mystery shopping? Has anybody ever tried it in this industry?

Neelam Patankar

No. Like I said, we don’t.

Lee Anderson

So how do you know that it doesn’t work, then?

Professor Sanders

If I may come in, law enforcement does do this. They do it in relation to welfare checks, particularly if ASWs would give red flags.

Lee Anderson

So it does work.

Professor Sanders

It does work in terms of checking that this person is legitimate, okay, needing help or not. Welfare checks do happen as part of—

Lee Anderson

If it can work in law enforcement, why can’t it work with your company doing it?

Professor Sanders

I think it works because ASWs give the information to law enforcement saying, “There may be a red flag here. Can you check this?”, and then law enforcement will do the checks.

Neelam Patankar

Also, as I mentioned, I have been on site. That was through a mystery shopping visit through law enforcement. It is not something that we would do ourselves.