Introduction – Ginny Smith, Co-ordinating Editor, Sussex Bylines
Two weeks ago, I chaired a Bylines Network webinar on Women, Justice and Equality. On the panel were two survivors of the Mohamed Al-Fayed Harrods abuse, and an Epstein survivor.
The courage of the women who had agreed to take part and share the account of their fight for justice was extraordinary. A fight which, in the case of the Harrods survivors, has been taking place over four decades, with powerful institutions blocking progress at many turns, and the women involved being put through the agonising experience of repeating their accounts of the original abuse time and again to different agencies. And getting nowhere.
In this article for Sussex Bylines, No One Above (NOA) explains why it is so essential for the Al-Fayed abuse cases to be investigated as trafficking crimes – and queries why the Metropolitan Police appear so reluctant to do so.
At least 500 women have alleged sexual exploitation by a criminal network centred on Al-Fayed, operating over more than four decades across London, Paris, Scotland, the French Riviera and beyond. Harrods was the primary recruiting conduit. Victims were groomed, medically tested, isolated and trafficked using private aircraft, vehicles and secure properties. 154 survivors have reported offences to the Metropolitan Police. French authorities have launched a parallel investigation explicitly framed as one into aggravated human trafficking. The UK authorities have so far failed to follow their example.
There is a mechanism in UK law called the National Referral Mechanism (NRM) that is designed to show, officially, that trafficking happened.
By law, police must refer consenting potential trafficking victims to the NRM where there are reasonable grounds for suspicion – or if they do not consent, file a Duty to Notify with the Home Office. The Independent Anti-Slavery Commissioner, in direct correspondence with NOA, has been explicit: where trafficking is suspected, “the duty to identify and refer applies from the point of identification, regardless of when the exploitation took place”.
Without a referral, exploitation on any scale – however documented, however extensive – exists in a legal and institutional no man’s land. No formal recognition. No pathway to specialist support. No state acknowledgement that the crime occurred at all.
When the state refuses to name trafficking as trafficking
For survivors of trafficking linked to Mohamed Al-Fayed, that is precisely where the Metropolitan Police chose to leave us. And when the state refuses to name trafficking as trafficking, it becomes harder for the media to do so too – and the silence compounds.
The NRM is not bureaucratic form-filling. It is the gateway to formal victim recognition, specialist support, and the legal protections the Modern Slavery Act 2015 was designed to deliver. It is also the mechanism by which the state is required to investigate a case through a trafficking lens – to name it for what it is.
Over the past year NOA has battled to have the Al-Fayed Harrods cases recognised as trafficking and for the police to refer those who reported to them to the NRM.
Throughout the autumn of 2025 NOA pushed through every available channel. Evidence submitted to the Home Office’s Call for Evidence on victim identification was ignored. The Home Affairs Committee rejected offers of lived experience evidence three times.
Freedom of information requests were denied
In December 2025, after multiple freedom of information requests were denied, NOA asked the All Party Parliamentary Group for Victims of Al-Fayed and Harrods to write to the Home Office with questions about NRM referrals in the case.
In a written response in February 2026, Safeguarding Minister Jess Phillips confirmed that only two NRM referrals had been received by the Home Office’s trafficking decision-making body across the entire Al-Fayed case. The inference was that these referrals had been made by the police. In fact both referrals were made by survivors themselves, through NOA’s campaign, via the charity Unseen UK.
The number of self-referrals via Unseen UK has now risen. The number referred by the police remains at zero.
Jess Phillips went on to suggest that the absence of further referrals was not a problem requiring examination. Referrals had been received, therefore the question of why more had not been made did not arise.
Making the legal and institutional failures visible
NOA has spent the past year establishing why this reasoning fails – and why the NRM gap matters enormously. It has done so as survivors – women who have relived their own experiences at every stage of this campaign in order to make the legal and institutional failures visible.
Facing closed doors in the UK, NOA submitted evidence to international oversight bodies, requesting scrutiny of Britain’s failure to fulfil its duties to victims under international law. The failures NOA documented are now part of the formal international record.
Through all of it, we kept going. When the Met failed to act, survivors travelled to Bristol, to Unseen UK’s offices, to make self-referrals to the NRM. We sat in interview rooms and told our stories again, in detail, to strangers, because the police had not done what the law required.
What we found there stands in stark contrast to everything that preceded it. Unseen’s staff immediately recognised the trafficking red flags in our accounts – the grooming, the medical testing, the movement, the coercion – and responded with the kind of informed, trauma-aware support that we had never once received from the Metropolitan Police. That a charity had to provide what a police force was legally obligated to deliver is not a minor administrative failure. It is an indictment.
A case involving 500 survivors
The stakes are not abstract. The Metropolitan Police is currently investigating what happened to survivors when they were in Al-Fayed’s presence – the assault, the individual acts, what happened in one room. It is investigating four individuals in a case involving 500 survivors, multiple named perpetrators, and four decades of documented abuse. It is not even looking at wider perpetrators. That is the frame – and it is a choice.
It is not looking at how victims came to be in that room, or how they were systematically silenced after they left. A formal trafficking investigation is not about one man in one room. It is about the entire apparatus – corporate, financial, legal, logistical, medical, and institutional – that made the room possible, made it repeatable and ensured that no one who entered it could easily leave or speak.
Without trafficking recognition, the network goes unnamed, the wider perpetrators and enablers unexamined, the apparatus intact. Under the current investigation, the guilty walk free. A formal trafficking investigation changes that. Trafficking recognition is the mechanism that forces the state beyond the room. The Met knows what happened beyond that room. It has always known. It has chosen to stay inside it.
Questions put by a survivor to the Met in August 2025 had produced confirmation that they recognised her case as one of trafficking, but that they were investigating it as indecent assault only, apparently due to a misinterpretation, wilful or otherwise, of their legal obligations.
Changes may be coming
In the last month, following NOA’s campaign, there’s an indication that things might be changing.
The first conclusive grounds decision – officially recognising that survivor (who had self-referred through NOA’s campaign, via Unseen UK) as a victim of human trafficking – came in April 2026. The Met also issued a letter to survivors, stating that it had updated its guidance on human trafficking and how it would be explored within the scope of historic legislation and that it was working to “identify indicators of suitability for the referral of some victim/survivors to the National Referral Mechanism”.
This is a first step towards the outcome NOA has been demanding from the beginning. It was not granted willingly. It was extracted, piece by piece, through the sustained effort of women who were owed this from the start.
It should not have taken this long
It should not have required survivors to fight this hard for an institution to discharge its basic legal duties. And the fact that it did is not a footnote – it is the story.
Recognition of trafficking is not optional and it is not contingent on a successful prosecution. Where there are indicators – and in this case they are numerous, documented, and include the accounts of hundreds of women – the duty to refer exists. Ignoring it doesn’t make the trafficking disappear. It makes the state’s refusal to acknowledge it a matter of public record.
Because if the NRM is never engaged, the state never has to formally answer how exploitation on this scale – organised from Knightsbridge, across four decades, in the face of at least 21 prior police reports and clear awareness – was allowed to continue. The paper trail, in that sense, is also a record of what was known, and of the decisions made to look away.
NOA continues to call for full NRM engagement across the case, independent assessment of the adequacy of the Met’s investigative scope and a statutory public inquiry into the full scope of institutional complicity and knowledge.
What has been achieved so far is real. It is also the floor, not the ceiling.
The NRM exists to name what happened. For the survivors of the Al-Fayed network, that naming – full, formal, and state-acknowledged – is still outstanding.
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