96th GLAA Board Meeting

1

Welcome and apologies

The Chair welcomed all attendees to the meeting.

Apologies noted as above.

PG appointed as Board Conscience.

2

Declarations of interest

None.

3

Minutes of the previous meeting

The minutes were not approved as concerns were raised regarding the inclusion of sensitive content. It was agreed the minutes would be reviewed and redacted before publication, following an internal sign-off process.

Action BM96(1)

The minutes from 19th May 2025 to be reviewed reflecting the Board’s feedback and sent to JM for final approval before being circulated out of committee for approval.

4

Outstanding Actions

Outstanding Actions:

BM94(9)

BM94(10)

BM95(2)

BM95(5) – see action BM96(2)

Closed Actions:

BM94(13) – Content to close.

BM95(1) – Content to close.

BM95(3) – Content to close.

BM95(4) – Content to close.

BM95(6) – Content to close.

Action BM96(2)

KO to cross reference the P&C paper on HR policy schedule to ensure the Whistleblowing policy review is included.

5

CEO Update, Elysia McCaffrey

Meeting with Minister Madders:

JM and EM met Minister Madders on 9th July. The meeting was supportive and positive; the Minister demonstrated a strong interest in the GLAA. He expressed a clear commitment to workers’ welfare and recognised the GLAA’s performance improvements. The discussion included issues such as financial pressures and the need to appoint senior roles for the FWA. The Minister indicated openness to further engagement. GLAA would wish to discuss the future fee structure at the next opportunity.

Meeting with Permanent Secretary:

EM thanks HO for supporting the set-up of the upcoming meeting with the Permanent Secretary. The upcoming meeting will focus on the GLAA’s financial instability as it transitions to the FWA. The Board plans to raise concerns about unsustainable funding, unaffordable pay awards, and the need for urgent clarity and support to ensure operational viability.

Victim Navigator Programme:

A project has been put in place to support formal accreditation of the Victim Navigator Programme, led by the Independent Anti-Slavery Commissioner. The GLAA is part of the steering committee. Internally, efforts are underway to strengthen the programme’s integration into the organisation ahead of the transition to the FWA, including developing new KPIs to better measure its impact and ensure its long-term sustainability.

NAO:

Ahead of the upcoming audit, the GLAA reported a positive and cooperative relationship with the NAO. The GLAA has already provided 95% of the required documentation for the Annual Report and Accounts, and the NAO is expected to return with their sample selection shortly. Discussions have taken place with the NAO auditors regarding the complexities of income regularity, and the GLAA has offered additional training to support their understanding. The internal audit by GIAA is also underway, focusing on the new income regularity process. Overall, preparations for the audit are on track and progressing smoothly.

6

Home Office Update

HOSU: Niall Donnelly

Arm’s-Length Body Review:

An expected announcement on the review of government arm’s-length bodies never materialised. While the GLAA is transitioning to the FWA, it may still be referenced in future updates.

Business Plan Approval:

The GLAA’s business plan has been approved by the Minister, allowing the organisation to proceed with publication and implementation.

Framework Agreement:

The updated framework agreement between the GLAA and the HO is with the Treasury for approval. No major issues are expected, and the document has also been shared with DBT to support their preparations for the FWA.

Spending Review and Budget Transfer:

There is uncertainty around how the GLAA’s funding will be handled as it moves to DBT. HO acknowledged concerns about the lack of a clear process for determining the budget transfer and whether recent fee increases would count toward efficiency savings. HO committed to pushing for clarity and ensuring DBT is fully engaged in the financial planning process.

NED re-appointment:

KR has now been reappointed.

Board Effectiveness Review: Megan Bethell

The GLAA Board Effectiveness Review is being conducted with a light-touch approach and independent oversight provided by Heather Baily, Chair of the Security Industry Authority (SIA). The Board has received the approved terms of reference and has been sent a questionnaire developed by the NAO, with responses requested by the end of July. Heather will start her review in August. She will review relevant Board documents and a recording of a previous Board meeting to inform her assessment. The review will evaluate the Board’s performance against the agreed scope and is expected to conclude with a formal report presented to the Board in November.

HO Modern Slavery Unit: Krutika Sharma

Victim Identification Review:

A public call for evidence was launched on 16 July 2025 to improve the identification of modern slavery victims. This 12-week consultation, closing on 8 October, seeks input on definitions and decision-making processes within the National Referral Mechanism. Workshops will be held with stakeholders including survivors, NGOs, police, local authorities, and the GLAA.

Support for Victims:

The Home Office is procuring a new contract for the Support for Victims of Modern Slavery (SVMS) service, currently held by the Salvation Army. The new contract aims to improve long-term outcomes for adult survivors, helping them achieve stability and reduce the risk of re-exploitation. The tender closes on 5 September 2025.

DLME Strategy:

The Director of Labour Market Enforcement’s 2025–2026 strategy is set to be published shortly. This will be the final strategy from the current DLME.

Trade and Business Conduct Review:

DBT has launched a new trade strategy that includes a review of responsible business conduct. The GLAA is encouraged to participate in the upcoming Forced Labour Forum to discuss these developments.

Employment Rights Bill:

The Employment Rights Bill is currently progressing through Parliament and is at the report stage. It is expected to receive Royal Assent in the Autumn 2025. The DBT is aiming for the FWA to launch in April 2026 and is exploring stakeholder engagement strategies to support implementation planning.

Concerns were raised about the certainty of the GLAA’s abolition on the proposed date. There was also discussion about whether the FWA would initially be a rebranded version of the existing organisations. It was clarified that while the FWA will incorporate existing enforcement bodies, it will also include new powers and functions—such as tribunal enforcement and statutory sick pay enforcement—making it more than just a name change.

The Board acknowledged the importance of maintaining momentum and clarity around the transition. They also recognised the need for careful planning and communication to ensure a smooth and meaningful shift to the new agency.

7

Finance and Performance

a)    Financial Position – Justin Rumball

Retention and Fragility:

A key point of contention was the language used in financial reporting, particularly the framing of staff retention as a financial problem. One Board member strongly challenged the notion that retaining staff longer than expected should be seen as a negative. They argued that modelling based on high turnover is not only unrealistic but also contrary to good organisational practice, as it implies that financial balance is achieved by expecting or even relying on people to leave. This was described as a flawed and potentially damaging narrative, especially when viewed by staff or external stakeholders.

The Board agreed that this language needs to be revised to reflect the reality: the budget is inadequate for the current operating model, and the organisation is only managing due to underinvestment in people and infrastructure. There was consensus that the narrative should shift to highlight the structural funding gap, rather than implying that staff stability is a financial burden.

Action BM96(3)

The Board has recommended that this matter be formally documented and escalated at the planned meeting with the Permanent Secretary, noting this is the culmination of a longstanding issue that has now become critical.

Dilapidation:

It was noted that the issue of dilapidations—costs associated with restoring leased property to its original condition—remains outstanding and could carry over to the DBT if not resolved before the GLAA is dissolved.

EM recently met with the Chief Executive of the GPA to stress the urgency of resolving the matter, warning that the GLAA would cease to exist after the transition to the FWA. This was intended to prompt action, as there is a risk that the GPA may not recover the funds if the issue is not addressed in time. Despite this, there had been no follow-up from GPA at the time of the meeting.

It was also discussed that the GLAA still does not have a formal lease in place for Loxley House, which further complicates the situation. DBT has been made aware of the situation and is copied into all correspondence. The matter has also been escalated internally for further support and resolution.

b)    Strategic Performance – Sam Ireland

The strategic performance of the GLAA was presented as broadly positive, with the organisation demonstrating strong delivery against its key performance indicators despite ongoing financial constraints. The Board was informed that the average time to process licence applications had been significantly reduced to 24 working days, well below the 50-day target, reflecting effective leadership and streamlined processes. Enforcement activity was also highlighted, with 41 investigations into unlicensed gangmasters initiated to date—indicating substantial progress toward the annual target of 65. This was achieved without compromising the volume of modern slavery investigations, which remained stable.

Further, the GLAA exceeded its target for internally generated intelligence, reaching 62.5% against a 40% benchmark, and reported a 14% rate of investigations leading to criminal or civil outcomes, just shy of the 15% target. These achievements were acknowledged as mitigating key strategic risks, particularly those related to the organisation’s role as a regulator and enforcement partner. However, the Board also recognised the fragility underpinning this performance. It was noted that delivery is being sustained through considerable staff goodwill, limited resources, and operational pressures, raising concerns about long-term sustainability.

The Board’s discussion underscored a critical and increasingly visible link between the GLAA’s financial position and its operational performance. While the organisation continues to meet or exceed many of its strategic performance targets, this success is being achieved under considerable strain. The Board acknowledged that the current level of performance is not indicative of financial health, but rather a reflection of short-term resilience, staff commitment, and operational efficiencies that are not indefinitely sustainable.

The fragility of this performance was highlighted through several examples. Key operational areas, such as compliance inspections and licensing, are heavily dependent on a small number of staff. The absence of even one team member due to long-term sickness can have a measurable impact on the organisation’s ability to meet targets. Similarly, the lack of capacity to invest in backfilling roles or strengthening infrastructure has left the organisation vulnerable to disruption. This fragility is compounded by the fact that the GLAA is operating beyond its financial envelope, relying on goodwill, and temporary workarounds to maintain delivery.

The Board expressed concern that without a clear and honest narrative linking financial constraints to operational risk, there is a danger that external stakeholders may misinterpret the GLAA’s performance as evidence of financial adequacy. In reality, the organisation is making difficult trade-offs—postponing investment in systems, limiting staff development, and deferring strategic initiatives—in order to maintain core service delivery. These compromises, while effective in the short term, pose long-term risks to the organisation’s resilience, staff wellbeing, and ability to adapt to future demands.

It was therefore agreed that performance reporting must be contextualised within the financial reality. The Board recommended that the Finance and Performance Committee take forward work to ensure that performance data is accompanied by narrative that accurately reflects the pressures and risks underpinning delivery. This would support more informed decision-making and ensure that the GLAA’s strategic achievements are not viewed in isolation from the precarious conditions in which they are being delivered.

Decision

The Board agreed the Finance and Performance Committee take forward work to ensure that performance data is accompanied by narrative that accurately reflects the pressures and risks underpinning delivery.

8

GLAA Documentary Involvement – Sam Ireland

The Communications Team put forward a paper that set out requests for the GLAA’s participation in documentaries. The Board was asked to consider whether this was a strategic opportunity to increase public trust, strengthen stakeholder engagement, and reinforce the GLAA’s reputation as a leading authority in its field.

While the potential advantages of such a documentary were acknowledged, the Board expressed a number of substantive concerns. Among these were the risks associated with relinquishing editorial control, the potential for reputational harm, and the possibility of retraumatising victims. Members also raised questions regarding the timing and feasibility of the project, particularly in light of the organisation’s limited remaining operational lifespan and the ongoing transition to the FWA. Concerns were further compounded by the anticipated strain on financial and human resources. It was also emphasised that any such initiative would require prior consultation with the Home Office and, potentially, ministerial approval to ensure alignment with broader governmental communications protocols.

The Executive clarified that the proposal was exploratory in nature and intended to gauge the Board’s receptiveness before committing further resources. It was noted that the idea emerged from a broader effort to adopt a more ambitious and innovative communications strategy, particularly in response to recent improvements in digital engagement. Nevertheless, the Board expressed reservations regarding the internal capacity required to manage a project of this scale. It was suggested that the communications team should instead prioritise the development of a comprehensive content strategy and focus on enhancing the quality and impact of existing digital communications.

In conclusion, the Board determined that while the documentary concept held strategic merit, it was not appropriate to pursue at the present time. It was recommended that the proposal be considered as part of a longer-term communications strategy for the FWA. The discussion underscored the importance of aligning communications initiatives with organisational capacity, strategic timing, and governance oversight, while also recognising the initiative and creativity demonstrated by the communications team.

Decision

The Board did not agree the documentary proposal at this time and directed the communications team to prioritise enhancing existing digital channels.

9

Board Conscience Feedback

The meeting held was widely regarded by participants as a well-managed and inclusive session, particularly commendable given the challenges inherent in virtual formats. Board members expressed appreciation for the chairing of the meeting, noting that it facilitated open dialogue and ensured that all voices were heard. The meeting was described as spirited and focused, with members able to articulate their views candidly and constructively. Despite the complexity of the topics discussed—such as the documentary proposal and strategic communications planning—the meeting maintained a clear structure and pace, allowing for thoughtful contributions without digression. The transition toward discussions on the FWA was handled with sensitivity, balancing current operational concerns with forward-looking perspectives.

Overall, the meeting was seen as effective, inclusive, and purpose-driven, reflecting a strong commitment to collaborative governance and respectful engagement among Board members.

10

AOB

Stakeholder webinar:

During the recent stakeholder webinar, there was a high level of engagement and numerous questions raised, reflecting strong interest from participants. Stakeholders expressed a clear desire for greater involvement and more inclusive activities moving forward. DBT delivered a presentation on the FWA, which prompted significant interaction; however, attendees noted a lack of clarity and called for further consultation.

Next Meeting: 25th September 2025