ECPAT UK responds to appointment of Chair of Independent Inquiry into Child Sexual Exploitation

Friday 12th December 2025 

ECPAT UK has welcomed the appointment of the Chair of the Independent Inquiry into Child Sexual Exploitation, describing it as a critical opportunity to bring clarity, rigour and a children’s rights–based approach to an issue where children have too often been failed.

Responding to the Chair’s appointment and the draft Terms of Reference for the Inquiry, ECPAT UK emphasised the need for a clear, evidence-based scope that enables the Inquiry to examine systemic failures while ensuring all child victims are identified and protected.

Definitional Clarity is essential to determine the Inquiry's scope

ECPAT UK has raised serious concerns about the absence of a clear working definition of “grooming gangs” within the draft Terms of Reference. While the Inquiry refers to the Casey National Audit, neither the Terms of Reference nor the Audit itself provide a definition capable of determining scope. Instead, the Audit relies on a wide-ranging descriptive account of certain patterns of offending.

As set out in the Audit, the model commonly associated with “grooming gangs” reflects well-known cases such as those in Rotherham: an adult male targeting a vulnerable adolescent (often a child in care or a child with learning or physical disabilities) grooming them into believing they are a “boyfriend”, showering them with attention and gifts, isolating them, and subsequently facilitating sexual exploitation by multiple perpetrators.

ECPAT UK emphasises that while the so-called “boyfriend model” is widely recognised as a common feature of child trafficking for sexual exploitation, it is not a working definition of the offence or a framework for identifying victims. Rather, it is a description of a particular modus operandi used by perpetrators to exploit children through manufactured relationships of trust and affection. 

The Casey Audit further describes perpetrators as “subsequently pass[ing victims] to other men for sex, using drugs and alcohol to make children compliant, often turning to violence and coercion to control them.” ECPAT UK stresses that this too remains a descriptive account of certain perpetrators’ behaviour, not a legal or operational definition of the offence. Moreover, the emphasis on coercion is inconsistent with international legal standards on child trafficking for any form of exploitation.

Under the Palermo Protocol, the consent of a victim is irrelevant where any of the listed “means” are used, and Article 3(c) makes explicit that, in cases involving children, trafficking is established even where none of those means such as force, coercion, deception or abuse of vulnerability are present. This position is reinforced by the Council of Europe Convention on Action against Trafficking in Human Beings (ECAT), which confirms that a child’s consent to exploitation is always irrelevant. In international law, a child cannot consent to any aspect of their exploitation, and the presence or absence of coercion is not determinative in establishing if a child is a victim of human trafficking.

The Audit also distinguishes “other patterns” of sexual exploitation, including exploitation within street gangs and sexual exploitation linked to modern slavery. ECPAT UK has questioned why these are treated as distinct categories when, in practice, many such cases display the same features described elsewhere in the Audit: the use of the boyfriend model, multiple perpetrators, drugs and alcohol to control children, high levels of violence, and perpetrator groups that are loosely interconnected through existing social networks and often broadly homogenous in gender, age, ethnic background and socioeconomic status.

These shared characteristics point to significant overlap in perpetrator behaviour and victim experience, raising concerns about how conceptual boundaries are being drawn and the implications this has for identifying child victims and shaping effective responses. ECPAT UK is therefore calling on the Inquiry to develop a clear, evidence-based working definition of ‘grooming gangs’ that avoids excluding children from its scope and enables a rigorous examination of systemic and institutional failings.

Children's rights and entitlements must be central

ECPAT UK has urged the Inquiry to place children’s rights and entitlements at its core. Too often, child victims of sexual exploitation are not formally identified as victims of trafficking or modern slavery through the National Referral Mechanism (NRM), restricting their access to vital protections under ECAT. 

Where children are correctly identified, they are entitled to comprehensive support, including safe accommodation, psychological and material assistance, healthcare, education, legal assistance, protection from retaliation, the non-punishment principle, and access to compensation. The Inquiry should examine why these entitlements remain inconsistently applied and how failures in identification contribute to long-term harm. 

Examining systemic and institutional failures

ECPAT UK has welcomed the Inquiry’s focus on historic and current failings and on identifying systemic, institutional and individual factors that have allowed abuse to persist. Children have been repeatedly failed by statutory systems, and meaningful reform and accountability must be a central outcome. 

While the draft Terms of Reference refer to examining how ethnicity, religion or culture have shaped responses, ECPAT UK has urged the Inquiry to also make explicit the role of sex, gender and age in both perpetration and institutional responses. 

Recognising polyvictimisation 

Without seeking to widen the Inquiry’s scope, ECPAT UK has emphasised the importance of recognising that many children are polyvictimised (experiencing multiple forms of abuse and exploitation alongside harmful institutional responses). Criminal exploitation, domestic violence and other forms of child abuse frequently intersect with sexual exploitation and shape both children’s experiences and professional responses.

A UK-wide issue

Finally, ECPAT UK has highlighted that while the Inquiry’s formal remit covers England and Wales, child sexual exploitation and systemic failures in response are UK-wide concerns. Victims’ experiences do not align neatly with administrative boundaries, and learning from Scotland and Northern Ireland will be vital to ensuring the Inquiry’s conclusions have lasting and comprehensive impact. 

ECPAT UK has said it looks forward to supporting the Inquiry and contributing evidence from its direct work with children, practitioner training, and national and international research and policy engagement, to help ensure that this Inquiry leads to meaningful change for children now and in the future. 

-ENDS-

 

NOTES FOR EDITORS 

  1. The Draft Terms of Reference for the inquiry can be found here.
  2. The Casey National Audit on Group Based child Sexual Abuse and Exploitation can be found here.
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