March 31, 2014

II. Abuses against Domestic Workers in the UK

Criminal Abuses

Human Rights Watch has documented a range of abuses against migrant domestic workers which constitute criminal offenses under UK law, including forced labour and physical and psychological abuse. The majority of those interviewed who were under the new tied visa said their passport had been confiscated by their employer, which is not specifically criminalized under UK law but constitutes an indicator of forced labour and trafficking.

Forced Labour

Most of the migrant domestic workers interviewed by Human Rights Watch for this research described at least some of the elements that constitute forced labour under international law. Under European and international law, the UK must protect people on its territory from forced labour whether the actions are committed by public officials or private individuals. However, there is no mechanism in place in the UK to check whether employers are respecting the rights of migrant domestic workers and for those working in the UK under the new visa.[45] The risk of becoming undocumented if they leave their employers can deter them from reporting this treatment to the police.

In 2009, the UK parliament passed the Coroners and Justice Act 2009. The act, which entered into force in April 2010, criminalizes slavery, servitude, and forced or compulsory labour and applies where there is no element of trafficking.[46] Trafficking people for exploitation, including slavery and forced labour, is a crime under a separate law of 2004.[47]

The Crown Prosecution Service (CPS) has issued guidance on the section of the Coroners and Justice Act which deals with forced labour, slavery, and servitude. It informs prosecutors that behavior that can indicate that a person may be held in servitude or be a victim of forced or compulsory labour includes:

[…] violence or threats of violence by the employer or the employer’s representative; threats against the worker’s family; threats to expose the worker to the authorities, for example because of the worker’s immigration status or offences they may have committed in the past; the person’s documents, such as passports or other identification, being withheld by the employer; restriction of movement; debt bondage; withholding of wages.[48]

The guidance also states that other indicators of forced labour include excessive working hours imposed by the employer, poor accommodation, and isolation from contact with others. Thirty domestic workers interviewed by Human Rights Watch described at least one of those elements.

Andrea N., a Filipina domestic worker, went to London with her employer, a diplomat, and his family from a Gulf country on a new visa. Andrea N. looked after his children, cooked, and cleaned, seven days a week, with no day off. She started at 6 a.m. and worked until 10 or 11 p.m. every night. She said:

Before we came here, the contract said my salary would be £1,000 [per month], but they paid me £200. They locked me up in the house in London and when we went outside sometimes they didn’t give me food. I didn’t have a sim card, I didn’t have money. My boss sent my salary to the Philippines.[49]

Ira A., a 38 year-old domestic worker from the Philippines, decided to work abroad as a domestic worker, due to the difficulty of finding work in the Philippines and the need to support her son, who lives there. For two-and-a-half years, Ira A. worked for her former employers in Saudi Arabia, caring for their baby in a UK hospital. Ira lived in the hospital in the baby’s room, working constantly with no day off. She cared for the baby like a nurse, waking every two hours during the night to give him his medicine.

She was forbidden by her employers to leave the ward except when her employers visited once per month. Ira’s salary was 800 Saudi Riyals (about £130) per month, which her employers sent directly to her family in the Philippines. But they did not pay the money consistently. Ira said her family did not receive any money for the first four months and only received her monthly salary four times in two years. Ira was not allowed to have a mobile phone.

“Every year the boy checked in here at [a London] hospital,” Ira A. told Human Rights Watch. “In September 2012, I came with the mother, father, and the boy. We stayed for two-and-a-half months. I stayed in the hospital with the boy and the parents stayed in an apartment. They told me I couldn’t speak to nurses. I didn’t have pounds.”[50]

Many of those interviewed for this report described abusive living conditions, including lack of adequate food and privacy. Some were only given leftovers to eat by their employer, or sometimes not provided with food at all. For those whose employers did not pay them in the UK, this meant they could not buy any food. Many were not provided with their own bedroom. As noted, poor living conditions are recognized, by the ILO and the CPS, as possible indicators of forced labour.

Ana V., a Filipina domestic worker who went to the UK with her employer from Qatar on a new visa, said she lost 4 kilograms in 11 days because her employer’s sister, for whom she was caring in London while she received medical treatment, measured the food Ana V. cooked for her and her employer and did not allow her to eat any. Ana V. said that in 11 days she only ate rice four times, and the rest of the time she ate bread and hummus, and sometimes an egg in secret. Ana V. had asked her sister’s employer if she could go and buy food for herself from a store nearby, but she did not allow her. Ana V. did not have any British pounds. She only had EUR 190 her female employer had given her in Qatar before she left, but her male employer did not allow her to exchange the money in the UK. Ana V. told Human Rights Watch she slept on the floor in her employer’s sister’s room and worked from 7 a.m. until 10 p.m. or 12 p.m., with one hour’s rest during the day.[51]

Maria D., a Filipina domestic worker who went to work in the UK with her employer from Kuwait, told Human Rights Watch she was expected to eat the leftovers from her employers’ meals. She said when they went out to eat in a restaurant there was sometimes only bread for her to eat. Her employers paid her £50 for the three weeks she spent working in London.[52]

Several migrant domestic workers interviewed by Human Rights Watch said they had to eat quickly before getting back to work. “I had no time to eat,” said Sudeewa B., a domestic worker from Sri Lanka.[53] “We ate in the kitchen, standing only because it didn’t have a table … quick, and back to work after finishing,” said Raquel E.[54]

Six of the domestic workers interviewed by Human Rights Watch who arrived since the visa rules changed said they had their own room in London. Nine said they slept in a storage or utility room, with a child, in the living room, or in a room they shared with their employer. One domestic worker said she had her own room but that she was not allowed to use the heating, and that she suffered from the cold as all she had was a small blanket she had brought from Saudi Arabia.[55]

Verbal, Physical, and Psychological Abuse

Assault and harassment are criminal offenses punishable by imprisonment in the UK.  The British government has a duty to protect migrant domestic workers from being abused by their employer and to ensure that they have access to justice if they are.

Comfort S., a domestic worker who arrived in the UK on an old visa, told Human Rights Watch her employer often hit her. “Every little thing, she raised her hand,” she said. “She slapped me once when I was holding the baby.”[56] Zahia M., a Moroccan domestic worker on a new tied visa, said her female employer hit her, shouted at her and insulted her while she worked for her in the UK.[57]

Several domestic workers told Human Rights Watch their employers shouted at them, called them abusive names such as “stupid,” “animal,” or “dog,” or threatened to harm them.

Linda S., a Filipina domestic worker whose employer in Qatar brought her to the UK to work as a domestic worker for their adult son, told Human Rights Watch: “Sometimes he was tired and he said, if I made a mistake, [or] there wasn’t a food he liked [because] the market was closed, ‘I can kill you and throw you to the sea.’”[58]

Saleema R., a Filipina domestic worker who came to the UK and worked under the  old visa rules for three years before escaping in December 2013, said: “It was very hard. The five children always said ‘give me this,’ ‘give me that.’ Madam and the children shouted, they said ‘you have no brain,’ ‘you’re stupid.’”[59]

Maria D., a Filipina domestic worker who came to the UK with her employer from Kuwait under a new tied visa rules, said her employers’ children threatened her: “The children said if you run away the police will bring you to jail. They scared me already.”[60]

Confinement and Restricted Contact with Others

I decided to leave them…. If I stay here I don’t know what would happen to me because they always locked me in the house. If there’s a fire what will my son’s future be? How will I help my mother?
—Andrea N., a Filipina domestic worker who went to the UK with her employer, a diplomat from a Gulf country, London, September 8, 2013.

Both the UK’s Human Rights Act and the International Covenant on Civil and Political Rights (ICCPR), ratified by the UK, guarantee the right to liberty.[61] False imprisonment and kidnapping, both relevant to forced labour under UK law, are crimes punishable by life imprisonment.

Most domestic workers on new visas whom Human Rights Watch interviewed said they were not allowed to go out freely. Some were only permitted to go out with their employer, or with the children, or for short trips to the supermarket. Two domestic workers on the new visa, one working in a private household the other working for a diplomat, told Human Rights Watch their employers locked them in the house when they went out.

Cherryloi M., a Filipina domestic worker who arrived in the UK in May 2013 with her employers for whom she had worked in Qatar for one year before that, described how her employers treated her in Qatar, where she slept on a mattress on the floor:

I slept in one room, a storage area. They didn’t let me keep my clothes in the room, they said they were dirty. They treated me not like a human, like an animal. Other maids had left before me, it wasn’t just me.[62]

Cherryloi M. told Human Rights Watch that in London her employers locked the apartment door preventing her from leaving the apartment. “I had a room with a bed. But at 5 a.m. I woke up and made tea for my Madam. She told me not to go to my room again until midnight…. I sat with them in restaurants, looking at them eating.” she said. One day, a week after arriving in London, Cherryloi M.’s employers forgot to lock the door. She ran away, without her passport or money.[63]

Comfort S., a Nigerian domestic worker who was employed under the old visa rules, described how her employer told her to mistrust people in London, contributing to her feeling of isolation: “I didn’t know people [in London]. My aunty [employer] told me people here are wicked, don’t tell them your business, they’ll use it against you, so I was scared to tell people about myself.”[64]

Catherine Kenny, a case-worker at Kalayaan, told Human Rights Watch she had seen about 35 migrant domestic workers on the new visa and all reported some kind of confinement. “I haven’t seen anyone on the new visa who can go out freely,” she said. “Some are locked in, some told they can’t go out. Some can go out with a child.… Another way is they don’t have any money. They can’t even get a bus. They’re also told they’re not allowed to speak to people locally.”[65]

Seven domestic workers who arrived in the UK on the new visa told Human Rights Watch they were not allowed a mobile phone or did not have enough money to top up the credit on their phone. Isolating a person from contact with others is an indicator of forced labour under the CPS Guidance on Slavery, Servitude and Forced or Compulsory Labour.[66]

According to the ILO indicators of forced labour, which include isolation, “workers may be isolated […] by being kept behind closed doors or having mobile phones or other means of communication confiscated, to prevent them from having contact with their families and seeking help.”[67]

Elissa I., an Indonesian domestic worker, told Human Rights Watch she did not  call her family during her first six months in London. “I called them before I left,” she told Human Rights Watch. “I told them I’m going to London with my employer. If you don’t hear from me, I’ll call you when I get back.” Elissa I. came to the UK with her employer from Saudi Arabia in 2012 and then in 2013. She ran away the second time.[68]

Maria D., a Filipina domestic worker who went to the UK on a new tied visa, told Human Rights Watch that she once asked her employer permission to speak to her family back home in the Philippines. “She gave me her phone, maybe for ten minutes, and then I had to translate what I said to my family,” Maria D. said.[69]

For Sudeewa B., a Sri Lankan domestic worker who went to the UK on an old visa with her former employer from Kuwait, calls home were strictly limited. “She [my employer] gave me the telephone to call Sri Lanka one time per month. Very quick, just “hello, how are you?” I asked for a mobile but she said no.”[70]

Several domestic workers told Human Rights Watch their employers told them not to talk to people in London, apparently as a means of controlling domestic workers by preventing them from having contact with other people.

Retention and Withholding of Passports

Thirteen of the 15 domestic workers interviewed by Human Rights Watch who arrived since the visa changes said their employers retained their passports. Withholding a domestic worker’s passport is a means of control, and while it is not a specific offence under UK law it is listed by the CPS as a means of coercion which can indicate forced labour.[71] The retention of identity documents is also described in the ILO Convention as an indicator of forced labour. The UK Visas and Immigration information sheet for overseas domestic workers states that “You, not your employer, should retain your passport,” but it does not give any information as to what they can do if their employer retains their passport against their will.[72]

While some domestic workers said they held their passport during their journey to the UK, others told Human Rights Watch their employers even retained their passport while going through the UK border at the airport.[73]

It is common for employers to hold their domestic workers’ passport in the Gulf, where most of the domestic workers interviewed by Human Rights Watch worked before going to the UK with their employer.[74]

Elissa I., an Indonesian domestic worker who went to the UK with her Saudi employers in January 2012 for six months on an old visa, and again in January 2013 on a new visa, told Human Rights Watch that when she travelled to the UK her male employer held all the family’s passports, including hers. She said border officers asked questions but her employer answered.

Some migrant domestic workers told Human Rights Watch they had wanted to leave their employer, but they didn’t want to leave without their passport.

Rita C., a domestic worker from Uganda, who left her employers in September 2012 having worked with them in the UK since 2009 and before that in Uganda, told Human Rights Watch: “I didn’t like the way they treated me, it wasn’t good. So I wanted to run away but I didn’t want to run away without my passport. They locked it in the safe. They told me if a letter arrives in your name don’t open it.”[75]

Raquel E., a Filipina domestic worker, told Human Rights Watch how in November 2013 she called the police to ask how she could get her passport back from her employer who was withholding it. Police officers came to her employers’ flat the same evening. She said they didn’t enter the flat. They spoke to her employer in the hall, but didn’t speak separately to her. Her employer, she said, told the police that she had her own room and one and a half days off. Then, she said, her employer turned to her and told her, in front of the police officers: “I’m holding your passport because I’m your employer, you’re my employee.” The police, she said, simply apologized to her employer and then left. According to Raquel E., after the police left her employer told her: “I won’t give you your passport. I’ll give it to the Home Office. You can’t find another job. I’ll tell the police to find you and send you to the Philippines.” The following day, Raquel E.’s employer dismissed her without returning her passport. Raquel had not received her passport back at the time of writing.[76]

Labour Abuses

The main labour abuses documented in the research for this report were excessive working hours and low wages or non-payment of salary. The overwhelming majority of interviewees said their employers did not pay them the minimum wage in the UK, despite the fact that a written agreement specifying that the worker will be paid UK national minimum wage is a requirement for visas to be issued, as well as a requirement under UK employment law.[77]

Excessive Working Hours

The majority of migrant domestic workers interviewed by Human Rights Watch, under both the old and the new visa system, said they worked excessively long hours, on average from 6 a.m. or 7 a.m. until 10 or 11 p.m. Some said they started at 4 a.m., some finished at 12 p.m. In families with small children, especially, they were expected to be on call day and night and to attend to the children if they woke up.

Some said they also had to get up at night if their employer requested something, for instance food, whatever the time. Some domestic workers said they had to wait until their employers finished eating before cleaning up, and some had to work late into the night if their employer had a party, but they were not paid extra. Of those interviewed by Human Rights Watch under the new visa system, only two said they had days off in the UK and one of these two said it was not consistent.

Excessive overtime, which can include being denied breaks and days off or being on call 24 hours a day, 7 days a week, is an indicator of forced labour according to the ILO and the UK Crown Prosecution Service.[78]

Farah Y., from Morocco, said she was the only domestic worker in the house of a diplomat that had nine bathrooms, nine bedrooms, three living rooms, a garden, and a swimming pool. Almost every day she would have to change the sheets, even if there was no one staying in the room, cook, clean, and iron. She said:

I told them I start at 9 [a.m.] and finish at 5 or 6 [p.m.]. He [the employer] said, “No, I need my breakfast at 7 [a.m.], and you finish when you finish.” … I didn’t sleep until 11 or 12 [p.m.].[79]

Zahia M., a Moroccan domestic worker who arrived in the UK under the new visa rules with her employers from Saudi Arabia, told Human Rights Watch she worked day and night, sometimes only sleeping for one or two hours. She started to make breakfast at 6 a.m., sometimes earlier. Her employers and their children each wanted something different to eat. She spent the rest of the day cooking, cleaning, and picking up after them. She said sometimes she started ironing her employers’ clothes at 1 a.m. because she did not have time to do it during the day.[80]

Several domestic workers, who are practicing Christians, said they would have liked to have gone to church but they were not allowed to. With very few exceptions, the domestic workers interviewed by Human Rights Watch said they had no breaks during the day and no days off.

Andrea N., a Filipina domestic worker, told Human Rights Watch about the reaction of her female employer when she asked for a day off:

[She] said: “You can go out and pack your things if you want a day off. The police can take you.” I said to the husband, why is your wife shouting at me when I ask about a day off? He said: “We can’t give you a day off. I’ll take you to church for one hour and pick you up.” But he didn’t.[81]

Domestic workers are excluded from the provisions of the UK’s Working Time Regulations that limit weekly working time to 48 hours and night work to 8 hours for each 24 hours.[82] However, they are entitled to an uninterrupted rest period of at least 11 hours every 24 hours, an uninterrupted rest period of 24 hours each seven day period, a rest break if the working day is longer than 6 hours, and 4 weeks’ annual leave per year.[83]

Low or No Salary

Along with employers withholding their passports and excessive working hours, insufficient wages was the most common abuse described by the domestic workers interviewed by Human Rights Watch. Most of those staying in the UK under both the old and the new visa rules said they were paid extremely low salaries, if at all. At least those in the UK under the old visa rules were allowed to look for and take on another, better paying job. Those coming to the UK under the new rules have little realistic option but to accept the wages offered.

Of the 15 migrant domestic workers working in the UK under the new visa system whom Human Rights Watch interviewed, 9 said they were not paid in the UK. They were paid back in the country where they had worked before, or their employer sent their salary directly to their family, or they were not paid at all. While some said they had consented to their employer sending their wages directly to their families back home, in practice they had little choice if they wanted to send the money home themselves given the restrictions many employers placed on their movements. Several domestic workers working in the UK under the new visa rules told Human Rights Watch they had signed documents with information about their salary and time off in the UK which their employers never followed. In some cases, employers explicitly told them to lie if they were asked questions at the British embassy during their visa interview.[84]

As of October 2013, the National Minimum Wage for workers over 21 years old was £6.31 per hour. In 2012 it was £6.19 and in 2011 it was £6.08.[85] Employers can only charge up to £4.91 per day, or £34.37 per week for accommodation, which includes rent, gas and electricity, and laundry.[86] The majority of the domestic workers interviewed by Human Rights Watch for this report were not paid anything like the minimum wage.

Elissa I., an Indonesian domestic worker, said the first time she went to the UK with her Saudi employer in 2012, she stayed for six months.[87] Her salary continued to be what it was in Saudi Arabia: 1,000 Saudi Riyals (about £160) per month, which Elissa I.’s employers sent to her family in Indonesia as she had agreed with them. “I never took my salary here.… They only gave me £150 two days before leaving.… Whenever I need shampoo or cream they bought it for me. They didn’t give me money.” The second time Elissa I. came with her employers, under a new visa in 2013, she left after two weeks. The only money she had were the £150 her employers gave her before she left.

Neha R.,a domestic worker employed by a diplomat, told Human Rights Watch she worked seven days per week looking after her employer’s children, cooking, and cleaning. She said her employer paid her £150 per month and that she had not had a salary increase since she started working for her employer 12 years ago. “What can I do?” she told Human Rights Watch. “My family is very poor…. I send them £100 every month.” Neha R. said she supported her mother, father, sister, and her sister’s two children back home.[88] 

Anita L, an Indian domestic worker who arrived in the UK under the old visa system, said her employers didn’t pay her for three years, including the three months she spent working for them in the UK. She said she worked from 6 a.m. to 11 p.m. or 11:30 p.m. with no breaks and no days off. She was not allowed out alone and slept in a room with the children. “They said they would transfer money to my account but they didn’t,” she said. “I called home in India once per month, I wasn’t allowed a mobile.”[89]

Zahia M., a Moroccan domestic worker in the UK under the new visa rules, said her Saudi employers paid her £250 per month to work day and night, with no days off. She told Human Rights Watch her employers had increased her salary from 1,000 to 1,200 Saudi Riyals (just under £200) shortly before leaving for the UK. However, even though she was working in the UK for her employer’s convenience, she said she had to pay her employers £500 for her own plane ticket to the UK.[90]

Phoebe D., a Filipina domestic worker who went to the UK with her Saudi employer under the old visa rules, said she was not paid during the three weeks she worked for them in the UK (nor had she been paid for one month in Saudi Arabia prior to leaving for the UK). “The woman [my employer] said if they pay us we might think of running away,” she said.[91]

Saleema R., a Filipina domestic worker who escaped from her employers after working for them for three years in London, told Human Rights Watch: “For two years I didn’t get paid. The third year, Sir went to the bank and sent money [$200]  to my family in the Philippines. At Christmas and Ramadan, they gave me £10 or £20.”[92]

The UK Home Office information sheet issued to overseas domestic workers informs those going to the UK that they are entitled to the National Minimum Wage and that if they have worries about their work situation or think their employer is not respecting their rights, they can contact the Pay and Work Rights Helpline[93] or the ACAS Helpline. The information sheet does not specify what the acronym ACAS (Advisory, Conciliation and Arbitration Service) stands for, nor does it tell domestic workers what the National Minimum Wage in the UK is or to how much time off they are entitled.

[45] Human Rights Watch meeting with UK Home Office officials, London, January 29, 2014.

[46] Section 71 of the Coroners and Justice Act 2009 provides that a person commits an offence of slavery, servitude or forced or compulsory labour if a person (D) “holds another person in slavery or servitude and the circumstances are such that D knows or ought to know that the person is so held” or “(D) requires another person to perform forced or compulsory labour and the circumstances are such that D knows or ought to know that the person is being required to perform such labour.”

[47] Asylum and Immigration (Treatment of Claimants, etc.) Act 2004, Section 4.

[48] The Crown Prosecution Service, “Legal Guidance: Slavery, Servitude and Forced or Compulsory Labour,” April 2010.

[49] Human Rights Watch interview with Andrea N. (not her real name), London, September 8, 2013.

[50] Human Rights Watch interview with Ira A. (not her real name), London, October 27, 2013.

[51] Human Rights Watch interview with Ana V. (not her real name), London, January 26, 2014.

[52] Human Rights Watch interview with Maria D. (not her real name), London, December 8, 2013.

[53] Human Rights Watch interview with Sudeewa B., London, December 1, 2013.

[54] Human Rights Watch interview with Raquel E. (not her real name), London, December 3, 2013.

[55] Human Rights Watch interview with Zahia M. (not her real name), London, January 19, 2014.

[56] Human Rights Watch interview with Comfort S. (not her real name), London, October 25, 2013.

[57] Human Rights Watch interview with Zahia M. (not her real name), January 19, 2014.

[58] Human Rights Watch interview with Linda S. (not her real name), London, September 8, 2013.

[59] Human Rights Watch interview with Saleema R, (not her real name), London, February 9, 2014.

[60] Human Rights Watch interview with Maria D. (not her real name), December 8, 2013.

[61] Human Rights Act. Schedule 1, Article 5 and International Covenant on Civil and Political Rights (ICCPR), Article 9.

[62] Human Rights Watch interview with Cherryloi (not her real name), London, August 31, 2013.

[63] Ibid.

[64] Human Rights Watch interview with Comfort S. (not her real name), London, October 25, 2013.

[65] Human Rights Watch interview with Catherine Kenny, London, December 6, 2013. Some of the domestic workers referred to by Catherine Kenny were also interviewed by Human Rights Watch for this report.

[66] The Crown Prosecution Service, “Legal Guidance: Slavery, Servitude and Forced or Compulsory Labour,” April 2010, http://www.cps.gov.uk/legal/s_to_u/slavery_servitude_and_forced_or_compulsory_labour/

[67] International Labour Organization, “ILO indicators of Forced Labour,” October 1, 2012, http://www.ilo.org/sapfl/Informationresources/Factsheetsandbrochures/WCMS_203832/lang--en/index.htm(accessed January 14, 2014).

[68] Human Rights Watch interview with Elissa I. (not her real name), London, December 13, 2013.

[69] Human Rights Watch interview with Maria D. (not her real name), December 8, 2013.

[70] Human Rights Watch interview with Sudeewa B., December 1, 2013.

[71] The Crown Prosecution Service, “Legal Guidance: Slavery, Servitude and Forced or Compulsory Labour,” April 2010, http://www.cps.gov.uk/legal/s_to_u/slavery_servitude_and_forced_or_compulsory_labour/

[72] UK Visas and Immigration, “Overseas domestic worker information sheet,” https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/265823/dworkers-informationsheet.pdf (accessed February 24, 2014).

[73] Human Rights Watch interviews with Raquel E. (not her real name), December 3, 2013; Maria D. (not her real name), December 8, 2013; Elissa I.(not her real name), December 13, 2013; Ana V. (not her real name), January 26, 2014; and Sharmaine A. (not her real name), London, January 26, 2014.

[74] Human Rights Watch, South Asia: Protect Migrant Workers to Gulf Countries, December 18, 2013, http://www.hrw.org/news/2013/12/18/south-asia-protect-migrant-workers-gulf-countries;; Walls at Every Turn:  Exploitation of Migrant Domestic Workers Through Kuwait’s Sponsorship System, October 2010, http://www.hrw.org/news/2010/10/06/kuwait-abused-domestic-workers-nowhere-turn; ’As If I am Not Human’: Abuses against Domestic Workers in Saudi Arabia, July 2008, http://www.hrw.org/en/reports/2008/07/07/if-i-am-not-human-0.

[75] Human Rights Watch interview with Rita C. (not her real name), London, October 27, 2013.

[76] Human Rights Watch interview with Raquel E. (not her real name), December 3, 2013. Raquel had previously escaped from the employer with whom she arrived in the UK and was able to take her passport and change employer, though she arrived in the UK after the visa changes.

[77] Immigration Rules – Part 5, undated, Paragraph 159A. (v), https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/285093/Immigration_Rules_Part_5.pdf (accessed February 24, 2014).

[78] International Labour Organization, “ILO indicators of Forced Labour,” http://www.ilo.org/wcmsp5/groups/public/---ed_norm/---declaration/documents/publication/wcms_203832.pdfThe Crown Prosecution Service,” Slavery, Servitude and Forced or Compulsory Labour,” http://www.cps.gov.uk/legal/s_to_u/slavery_servitude_and_forced_or_compulsory_labour/

[79] Human Rights Watch interview with Farah Y. (not her real name), London, December 7, 2013.

[80] Human Rights Watch interview with Zahia M. (not her real name), January 19, 2013.

[81] Human Rights Watch interview with Andrea N. (not her real name), September 8, 2013.

[82] The Working Time Regulations of 1998, regulation 19.

[83] The Working Time Regulations of 1998, regulations 10, 11, 12, and 13. Regulation 11 allows for two uninterrupted rest periods of at least 24 hours each or one rest period of 48 hours per 14 day period instead of a rest period of 24 hours every seven days.

[84] Human Rights Watch interviews Ira A. (not her real name), October 27, 2013; Lisa J. (not her real name), London, September 8, 2013; Raquel E. (not her real name), December 3, 2013; Raheema F. (not her real name), London, November 12, 2013; Cherryloi M. (not her real name), August 31, 2013; and Ana V. (not her real name), January 26, 2014.

[85] Home Office, “National Minimum Wage rates,”, undated, https://www.gov.uk/national-minimum-wage-rates (accessed January 16, 2014).

[86] Home Office, “National Minimum Wage: accommodation,”, undated, https://www.gov.uk/national-minimum-wage-accommodation (accessed February 2, 2014).

[87] Human Rights Watch interview with Elissa I. (not her real name), December 13, 2013.

[88] Human Rights Watch interview with Neha R. (not her real name), London, December 15, 2013.

[89] Human Rights Watch interview with Anita L. (not her real name), London, December 1, 2013.

[90] Human Rights Watch interview with Zahia M. (not her real name), January 19, 2014.

[91] Human Rights Watch interview with Phoebe D., London, November 23, 2013.

[92] Human Rights Watch interview with Saleema R. (not her real name), February 9, 2014.

[93] While the helpline is available in over 100 languages, a survey by the government Department for Business, Innovation and Skills in 2010 found that only 1 per cent of calls to the helpline went to language line: Ian Rutherford and James Achur, “Survey of Pay and Work Rights Helpline callers,” September 2010, p. 7, https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/32140/10-1128-employment-relations-research-series-survey-pay-work-rights.pdf (accessed February 26, 2014).