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Rights Lab
Safe Car Wash
App Report
Rights Lab
University of Nottingham
Foreword Foreword
Foreword
-
Long before The Clewer Initiative and the That so many people downloaded and
Santa Marta Group joined together to launch used the Safe Car Wash app is indeed an
the Safe Car Wash app, hand car washes had encouraging sign, but we obviously have
been named as a key battleground in the fight more work to do in understanding why
against modern slavery in the UK. However, some people may be reluctant to report
data was patchy. Law enforcement did not what they have seen.
have the resources to count each hand car
wash, let alone investigate them all. As well as noting the limits of our advocacy,
We designed the Safe Car Wash app as the report is also limited by the data available
a way to bring the issue into the mainstream, to the researchers. To encourage more people
in the hope that the general public would to use the Safe Car Wash app, we worked
see a role for themselves in mapping and with our developers to make it as simple
reporting modern slavery in hand car washes. as possible. That meant no complicated
questions, and very little room for nuance.
We were seeking to combat a phenomenon As a result we don’t know why one person
that Pope Francis calls the globalisation of called the helpline, when another, who may
indifference, where the laudable value of have seen almost exactly the same
tolerance is twisted. Instead of looking out concerning signs, chose not to.
for our neighbour, finding common ground,
and exploring our differences, we ignore Alongside this report into the data generated
them. This indifference fuels modern slavery, by the app, we have been pleased by the
because as a society we have chosen to anecdotal feedback that we have received
ignore the most vulnerable. from law enforcement, that the app’s data
has been exactly what we envisaged it to
In that light we were encouraged to see how be: a piece of the puzzle, which they can
many people did download and use the Safe put together with their own intelligence and
Car Wash app but until now we have only experience. As a result of their feedback
been able to look at the headline figures. and this report we have made a few updates
This report is the first time we have been to the Safe Car Wash app which will make
able to dig into the data. The value of it simpler and more effective for both users
robust research and evaluation cannot be of the app and users of the data.
overestimated. With such a hidden crime,
more and better information is needed Modern slavery can only be ended through
across the board. partnership. We hope the Safe Car Wash app,
and this report, will inform policy makers and
Broadly, this report confirms what we had those on the front line as they engage with
already surmised. Many hand car washes the problem of exploitation in hand car
are suspect and do not protect their workers. washes. We hope too that this report provides
A lack of protective equipment and fearful a useful example of what can be achieved
and withdrawn body language are far more by bringing together technology, insight,
common than one would hope. and people of goodwill, while highlighting
the gaps that are still to be filled.
We were disappointed to learn that only
18% of those who were prompted to call The Rt Revd Dr Alastair Redfern,
the Modern Slavery Helpline did so, whilst The Clewer Initiative
acknowledging that they may have called at The Rt Revd Patrick Lynch,
another time, or reported in a different way. Santa Marta Group
2 3
Introduction Introduction
Introduction
-
The Home Office estimates that there are activities has unearthed exploitative labour
10,000 – 13,000 victims of modern slavery and employment practices. Reports,
in the United Kingdom (UK)i, many of whom press coverage, and investigations
are forced or coerced into performing work describe excessive working hours,
for little or no pay and exploited in a variety withholding of wages or below national
of industries. One area where exploitation minimum wage (NMW) payments and
is said to be prevalent is the hand car wash working without adequate protective safety
(HCW) sector, a popular form of car wash gear and equipmentii. Reportedly, there exists
service, which is performed manually. a spectrum of abuse in HCWs. While some
Prior to 2004 the presence of HCWs as a workers are subject to some form of labour
business activity was virtually non-existent, and employment violation, others are forced
but research suggests that they now into modern slavery, compelled to work
dominate the car wash market. gruelling hours under the threat of violenceiii.
The lack of data makes it difficult to estimate
Although HCW operations have grown at the prevalence of labour exploitation and
an exponential rate, their activities, business modern slavery, which is critical to address
models and workforce are only just beginning abuses in this high-risk trade.
to gain attention. Recent scrutiny of HCW
4 5
The Safe Car Wash app The Safe Car Wash app
The Safe Car Wash app
“
Thank you for providing us access to this tool against
modern slavery and human trafficking (MSHT). From
the data we reviewed we did find three identifiable car
- wash locations which showed potential signs of MSHT
that had not been brought to our attention previously.”
In June 2018, The Clewer Initiative and the and the National Police Chiefs’ Council. Kent and East Sussex
Santa Marta Group, in partnership with a These agencies are given real-time access Serious Crime Directorate
number of stakeholders, launched the Safe to the data to help develop the intelligence
Car Wash app, which seeks to provide a required to lead effective investigations.
“ “
community intelligence-led approach to
mapping car washes across the UK and In order to further understand the data
gathering data in relation to modern slaveryiv. collected, The Clewer Initiative and Santa
Since then it has been downloaded Marta Group generated a dataset including
8225 timesv. The app enables users to app users’ responses from June 26th to The Gangmasters and Labour Abuse Modern day slavery is a rising threat
anonymously provide information on December 3rd 2018, and shared it with the
Authority (GLAA) have worked closely to our communities, and because of its
the location and setting of the car wash, Rights Lab at the University of Nottingham
with The Clewer Initiative (TCI) on the hidden nature, is a major concern - we
workers’ access to suitable clothing, living for analysis. Entries that have been partially
completed by the users are excluded from development of the ‘Car Wash App’, and all need to be alert to it, wherever we live.
arrangements, the presence of minors we are one of the organisations ‘badged’ Councils are committed to protecting the
working on site, and the cost and method this dataset, which comprises 2271 entries.
This report outlines the findings from the within it. We are the link between the most vulnerable in society, but everybody
of payment. Users are prompted to call the
data, and reflects on how the app might TCI [The Clewer Initiative] and UK law has a role to play in tackling this terrible
Modern Slavery Helpline if their answers
promote a better understanding of the enforcement and we have ensured that crime. This is why the LGA has been
indicate that there is a likelihood of modern
slavery or exploitation at the car wash. industry and promoting higher standards every police force has a ‘log on’ to the pleased to be involved in the development
Anonymous data collected from the app is in the future. database and particularly the map of car of the Safe Car Wash app, and encourages
shared with the National Crime Agency, the washes that the app creates. We see great people to use it to help identify these
Gangmasters and Labour Abuse Authority, value in the use of technology in the fight ruthless profiteers and rescue their
against Modern Day Slavery and Labour victims from lives of servitude. Reporting
Exploitation and commend TCI for the any concerns through this app could
leading role they have taken in this area make a world of difference to people
and the lead they have given to willing being exploited at the hands of heartless
partners – ourselves included.” gangmasters.”
Gangmasters and Labour Councillor Simon Blackburn
Abuse Authority Chair of the Local Government
Association’s (LGA) Safer and
Stronger Communities Board
6 7
Acknowledgements Acknowledgements
Acknowledgements
-
We would like to thank the Clewer Sisters modern slavery in hand car washes and
and Trustees, as well as the CCLA for for the work you do to help end modern
making the Safe Car Wash app possible. slavery. Finally to all those who have used,
Thank you also to the Gangmasters and and continue to use, the Safe Car Wash
Labour Abuse (GLAA), the National Crime app - in the complex landscape of modern
Agency (NCA), the Local Government slavery you are bringing clarity and insight,
Association (LGA) and the National Police thank you.
Chiefs’ Council (NPCC) for your support
of the Safe Car Wash app. We owe a debt This report was produced and funded by the
of gratitude to all those who advised us on Rights Lab at the University of Nottingham.
what the app should look like and the key It was authored by Dr Akilah Jardine and
indicators we needed to include, thank you Dr Alison Gardner (Rights Lab Governance
for giving us your time and expertise. Programme), with assistance from Dr Selim
Thank you to the Modern Slavery Helpline Cakir (Rights Lab Business Programme),
for providing insight into the reporting of and Dr Mike Gardner.
8 9
Application usage Application usage
Figure 1
Safe Car Wash app monthly usage
1000
Application
Number of entries
800
usage
600
400
- 200
When the app was launched in June 2018, Taxi Drivers Association and the Car Wash
0
there was a high-level of application usage. Advisory Service also publicised the app
Modifications were subsequently made to their members. Heightened public and June July August September October November December
to the app in July 2018 that sought to media attention to abuses occurring in this
respond to early user feedback. The app sector also contributed to the promotion of (Source: Safe Car Wash app online car wash report, 2018)
was promoted through the grass roots the app, in particular, media coverage of the
networks of The Clewer Initiative and Environmental Audit Committee’s inquiry into The app has been welcomed by many I had with the helpline it looked as if this was
the Santa Marta Group and through the the social and environmental impact of hand national and local anti-slavery activists. a case of labour exploitation but not slavery.
Gangmasters and Labour Abuse Authority car washes (HCWs). Regular users of the app commented: I was assured the information I'd given would
(GLAA), the National Police Chiefs’ Council be passed on to GLAA.”
(NPCC), National Crime Agency (NCA), Although usage dropped after the initial “The Safe Car Wash app is something I
and the Local Government Association marketing push in June 2018, there was have started using since becoming aware Judith, Sheffield
(LGA). Trade bodies such as the London evidence of stabilisation and a steady rate of modern slavery within the car washing Safe Car Wash app user
of reporting from September 2018 onwards. business. It's really easy to use and being
available on your phone, it doesn't cause “I found the Safe Car Wash app very clear and
See Figure 1 (right) easy to use, and it was great that it was able
suspicion while you're having your car
washed. It has helped me to really take to prompt me to ring the Modern Slavery
notice of the subtle differences between Helpline as a result of my answers. When
how different car washes are run. It helps I spoke to them, I was able to answer most
in many ways from spotting the signs of their questions easily because the app
when something’s not right, to giving the had already prompted me to consider the
confidence to report it.” questions they asked me. Using the app has
also helped me to be more aware of the signs
Helen, Lichfield to look out for not only at carwashes,
Safe Car Wash app user but in other industries too…”
“The safe carwash app is extremely quick and Anna, Norfolk
easy to use, with straightforward questions. Safe Car Wash app user
I found it satisfying to know that following it
through with a conversation to the Modern “I really like the App - it's simple and easy to
Slavery Helpline has contributed to providing use and gets some important information
local information that may enable further straight to the people who need it. Perhaps
investigation by the Police.” more importantly it makes people stop
and think about their behaviour and if it is
Elizabeth, Portsmouth contributing to the exploitation of others.
Safe Car Wash app user I'd recommend everyone download
it and use it.”
“I found the app very easy to use and I got
through to someone at the Modern Slavery Mike, Lincoln
Helpline very quickly. From the conversation Safe Car Wash app user
10 11
Patterns of reporting Patterns of reporting
Patterns of
Figure 2
Car wash reports using the Safe Car
Wash app, June - December 2018
reporting
-
Figure 2 (left) demonstrates the initial exceptions). Finally, Wales and Scotland
spread and intensity of reports submitted were not specifically targeted in the initial
from the Safe Car Wash app between June marketing for the app, and this is probably
2018 and December 2018. In this study we reflected in the low number of reports from
have focussed on the reports rather than those areas.
exact car wash locations for a number of
reasons. Within the dataset there were There are a number of possible explanations
duplicate location reports (as one might for reporting being higher in some parts
expect for a car wash causing concern). of the country than others. The first is that
We also found that some users chose to some (urban) areas simply have a higher
submit their report from an alternative density of car washes, and rural areas such
location, away from the car wash, so the as Exmoor, Yorkshire and Cumbria certainly
geo-location did not always reflect the show fewer reports. However, we know that
position of the car wash itself, an issue car washes still exist in rural locations,
we pick up further in the analysis section. so it is probable that some under-reporting
For this reason, it was sometimes difficult is occurring, particularly as the 2000 plus
to clarify which points represented an entries in the data at this point will be an
accurate car wash location, without ground- incomplete reflection of the total (estimated
truth verification of every data point, which 10,000-20,000) car washes in the UK.
was outside the scope of this research. Another potential reason is that awareness
However, it is important to recognise that and thus usage of the app was higher in
statutory agencies are still able to draw some parts of the country than others.
effectively on the data to identify high-risk For instance, Nottinghamshire is the national
car washes, using local knowledge. headquarters for one of the agencies
involved in advising on the app, and The
The map shows that there are a higher Clewer Initiative, and may therefore have
intensity of reports within some centres had a higher number of regular users.
of urban population, as one might expect,
but that intensity is not directly correlated For the app to give a more accurate picture
with population size and density. of distribution, it will be important to
For example, there appears to be a encourage users to pinpoint the car wash
high intensity of reporting in and around locations using the app, even if they do not
Nottingham, compared to comparably- have specific concerns or subsequently enter
sized cities such as Bristol or larger cities additional information at another site. The
like Manchester. In some more rural regions map also perhaps highlights the opportunity
of the country, fewer reports were emerging to promote the app further in rural regions,
than we might expect. Many significant as well as Wales and Scotland, particularly
market towns include at least one report, given the church’s unique capacity to reach
but not all (Hereford, Wetherby, into rural communities.
and Bridgwater, for instance being
(Source: Safe Car Wash app, 2018)
12 13
Reporting to the Modern Slavery Helpline Reporting to the Modern Slavery Helpline
Reporting to the CAR WASH SETTING
17% of users identified fearful workers
exploitation is their accommodation style.
For instance, in some cases workers were
reportedly found living on the car wash
Modern Slavery Helpline
at the car wash. site in converted shipping and storage
The Safe Car Wash app asked users containersx. The Safe Car Wash app asked
-
if anyone appeared over-controlling users to look out for nearby caravans,
or intimidating and if the body language containers, mattresses and bedding on site
of workers appeared fearful or withdrawn. as evidence of workers living on site. 14%
17% of reports identified fearful workers of reports suggested that workers were
Although 41% of users were asked to at the car wash. This aligns with research living on the car wash site.
call the Modern Slavery Helpline by the in which law enforcement officials described
application, only 18% called the helpline ACCESS TO SUITABLE CLOTHING
varying methods used to control workersvi,
and 82% did not. There were a total of including physical abuse, threats, coercion, 48% of Safe Car Wash app reports
126 cases where the helpline was called, debt bondage, withholding of wages commented that workers did not have
so the intensity of this type of report and intimidation. access to suitable clothing.
is much lower. See Figure 3 (below).
Factors which seemed to encourage MINORS WORKING ON SITE Safe Car Wash app users were asked to
people to call the helpline are explored look out for gloves and boots to determine
in the next section of this report. 8% of reports logged children working if workers had access to suitable clothing.
on site. Reports on HCW activities have described
Users were asked if there appeared workers operating with potential harmful
to be minors working at the car wash. chemicals used to wash cars, such as
8% of users logged children working on site. hydrochloric acid, and working in poor
Generally, in the UK the minimum age a child and unsafe conditions. Health and safety
can work is 13 years for part-time work and regulations require employers to take
16 years for full-time workvii. School-aged practical steps to manage health and safety
children under the age of 16 are not entitled risks and to protect workers from harmxi.
to the national minimum wage (NMW), This includes providing workers with
while young persons over the age of 16 are appropriate personal protective clothing
entitled to a wage significantly lower than and equipment. 48% of Safe Car Wash
the NMWviii. While employing children and reports commented that workers did not
young persons in car washes may not be have access to suitable clothing.
unlawful, their age and cost of their labour Because of the nature of the work,
increases their vulnerability to exploitation. employees should be provided with
WORKERS LIVING ON SITE adequate clothing and gear to protect
them from harm such as safety shoes and
14% of reports said that workers were gloves. Workers operating without personal
living on the car wash site. protective equipment could indicate that
employers are in breach of health and
Research on the nature and prevalence safety regulations.
of labour exploitation in the HCW sector
reported that workers are housed in
different accommodation types,
some provided by their employersix.
A key factor that may suggest worker
Figure 3
Users employing the app to call the Modern
Slavery Helpline, June - December 2018
(Source: Safe Car Wash app, 2018)
14 15
Reporting to the Modern Slavery Helpline Reporting to the Modern Slavery Helpline FAIR PAY The average price paid for a HCW service was £7.10. Users of the Safe Car Wash app were requested to input the cost paid for the HCW service used. A low cost could indicate an exploitative business model where workers are paid below the national minimum wage (NMW). An assessment of the car wash industry by Waves, Tesco’s HCW supplier, suggests that a breakeven cost for an outside wash is £6.88 including value added tax (VAT) and £11.10 including VAT for an inside and outside washxii. This takes into consideration a number of expenses including the cost of labour, materials and resources. Though these figures are likely to vary across the UK, the cost of a HCW service below this price could suggest that workers are not paid the NMW. The app did not identify the type of service users received at the car wash, however the average price paid for a HCW service was £7.10. Although this is higher than the estimated price for an outside wash by Waves, the price of a car wash service is not sufficient to determine the prevalence of exploitation, and other factors need to be taken into consideration such as the car wash setting, health, safety and working conditions and method of payment. PAYMENT 80% of car wash visits had a cash only policy, 41% of users had to pay the manager directly and 87% were not offered a receipt. The Safe Car Wash app asked users if the car wash only accepted cash, if a receipt was offered, and if they had to pay the manager. These variables could suggest that the car wash is evading tax, national insurance and NMW obligations. 80% of responses entered in the Safe Car Wash app stated that the car wash had a cash only policy, while 41% had to pay the manager directly. Further, 87% reported that they were not offered a receipt. 16 17
Modern slavery reporting Modern slavery reporting
Figure 4
Risk factors identified by users who were prompted
by the app to call the Modern Slavery Helpline
89%
Modern slavery
74%
58%
reporting 31%
-
76%
15%
£6.47 7%
41% of users were requested to call the another means. We need to conduct more
Modern Slavery Helpline. Of these 18% research to understand why this may be, but
Average No access Workers Fearful Minors Cash only Receipt Pay
called the helpline and 82% did not. the data suggests that some features were price to suitable living on workers working policy offered manager
perceived as more worrying than others. clothing site on site directly
Research on exploitative labour and Figure 5 (right) illustrates the comparison
employment practices in HCWs have between data entered by users who called (Source: Safe Car Wash app, 2018)
reported a spectrum of abuse. While the MSH when prompted to do so, and those
workers may be subject to some form who did not call. The price paid for the car
of labour or employment violation, wash service was similar for both users. Figure 5
others may be victims of modern slavery. The average price paid by users who did Risk factors comparison between users who
Users of the Safe Car Wash app were not call the MSH is £6.50 and £6.36 for called the MSH and those who did not call
prompted to report their concerns to the those who did call.
Modern Slavery Helpline (MSH) if there
was a high likelihood that exploitation is Factors such as the average price of a car No access
occurring at the car wash. Users were also wash service, minors working on site and 73%
to suitable
encouraged to contact the police if they receipt offered showed similar data entries by clothing 78%
saw something of immediate concern. users who did not call the helpline and those
that did. However, the cash only policy and Workers 24%
Figure 4 (right), demonstrates the average the presence of fearful workers were living on
price of the car wash service and the site 26%
higher for those who called the helpline in
risk factors entered by users, who were comparison to those that did not. Further, Fearful 29%
subsequently prompted by the app to call data entered on workers’ lack of access to workers
the Modern Slavery Helpline. suitable clothing was higher for users who 35%
A cash-only policy and paying the manager called the helpline compared to those that
Minors
did not. This suggests that the factors most 16%
directly were the most commonly identified working on
features of settings in which user entries likely to influence users’ attitude towards site 16%
suggested a high level of risk. modern slavery reporting in car washes are
cash only policy at a car wash, the presence Cash only 86%
However, many users chose not to call the of fearful workers and workers operating policy
96%
helpline using the app, although we don’t without suitable clothing.
know if they subsequently called using Receipt
5%
offered
6%
Pay
58%
manager
directly 55%
Users who did not call Users who called
(Source: Safe Car Wash app, 2018)
18 19Analysis Conclusion
Analysis Conclusion
- -
This study demonstrates the potential of the log location of car washes even if they do not Gathering data on the scope of the hand car While more work needs to be done to
Safe Car Wash app as a means to record use the services provided, in order to gain wash sector in the UK is pivotal to tackling improve public reporting, the Safe Car Wash
data and raise awareness of signs of modern a fuller picture of the industry as a whole. abuses in this sector. The Safe Car Wash app app demonstrates the importance of citizen
slavery and labour exploitation, but further provides important emerging evidence to science in shedding light on pernicious
development of the app could overcome However, while the app seeks to inform law build our knowledge of HCWs including their practices, particularly in sectors where
some existing limitations. In addition, enforcement, it also aims to raise awareness geographical spread and the prevalence of exploitation is often described as ‘hidden’, yet
this study is a snapshot based on five months of modern slavery in car washes to members modern slavery risk factors. Although in its thrives in plain sight. Leveraging the real life
of usage. We know that the car washes of the community. Consequently, it is early stages, the data arising from the Safe experiences and insights of the public can
featured in these reports are at present just important that any changes that seek to Car Wash app also has potential to provide act as a catalyst for change by broadening
a sample of the car wash industry, which is improve the app as a data collection tool further insight into HCW activities our understanding of the nature of car
estimated to include between 10,000 and do not diminish users' experience and deter by mapping car wash operations. wash activities, the prevalence of labour
20,000 businesses. A longer-term study with individuals from using the app. exploitation and modern slavery, and building
further contextual data, including a ground- There are also likely to be benefits of this essential evidence for the approaches needed
The higher number of persons who did not app which are not yet captured by this
truth reality-check to look at the app’s contact the Modern Slavery Helpline when to tackle abuses.
effectiveness in logging car wash locations, data, including the extent to which the
prompted to do so - in comparison to those app has raised users’ awareness of exploitative
and experiences of law enforcement who did - demonstrates that more needs
agencies in utilising intelligence, would labour practices and promoted a public
to be done to understand the factors that conversation about labour abuse in car
provide valuable additional information. influence public reporting of abuses. washes. This conversation is now starting
In the short term, some further adaptations Research on local media and public to yield important policy changes, such as
could improve the utility of the app for data perceptions of modern slavery highlighted moves towards national and local regulation.
collection and mapping. These include several concerns that hinder public reporting
“
giving users the opportunity to review data of modern slavery cases, such as the lack of
before submission, providing more detailed sufficient information to be able to confidently
categories for the type of service received, report on behalf of potentially exploited
and adding the capacity to log the location persons and the concern that reporting might
make matters worse for workersxii. The Clewer Initiative and the Santa
and name of a car wash without making a
Marta Group recognised the risks in
full data entry. The Clewer Initiative and the
the car wash industry. Mobilising their
Santa Marta Group may also wish to consider
whether to give new recommendations on respective parishes to gather data
the use of the app, encouraging individuals to through the Safe Car Wash app has
resulted in a Parliamentary Committee
Inquiry now looking to regulate
the industry to prevent forced and
exploitative labour in the industry”
Kevin Hyland OBE
First UK Independent Anti-Slavery
Commissioner (2015-2018)
20 21Appendix Appendix
Appendix
-
i “ 2018 UK Annual Report on Modern ix Jardine, A, “Labour exploitation in hand
Slavery,” (2018) HM Government, car washes,” 14
accessed December 14, 2018
x Gangmasters and Labour Abuse Authority,
https://assets.publishing.service.gov.uk/ accessed December 14, 2018
government/uploads/system/uploads/
attachment_data/file/749346/2018_UK_ http://www.gla.gov.uk/media/3537/external-
Annual_Report_on_Modern_Slavery.pdf, 4 natureand-scale-of-labour-exploitation-
reportfinal-version-may-2018.pdf, 16
ii Akilah Jardine, “Labour exploitation in
hand car washes,” (2018) University of xi “Health and safety made simple: the basics
Nottingham, accessed December 14, 2018 for your business,” Health and Safety
Executive, accessed December 14, 2018,
http://www.antislaverycommissioner.co.uk/
media/1238/labour-exploitation-in-hand-car- hse.gov.uk/simple-health-safety/ index.htm
washes.pdf xii “Written evidence submitted to the
iii Ibid Environmental Audit Committee hand
car washes inquiry by the Downstream
iv “Safe Car Wash app,” The Clewer Initiative, Fuel Association,” (2018) Parliament Data,
accessed December 14, 2018 accessed December 18th, 2018,
https://www.theclewerinitiative.org/ http://data.parliament.uk/writtenevidence/
safe-car-wash-app/ committeeevidence.svc/evidencedocument/
environmental-audit-committee/hand-car-
v As of March 25, 2019. washes/written/84625.pdf
vi Jardine, “Labour exploitation in hand xiii Birks, J and Gardner, A (2019) Introducing
car washes,” 15 the Slave Next Door: Local media and
vii “Child employment,” Gov.uk, public perceptions of modern slavery
accessed December 18, 2018, (Forthcoming.)
https://www.gov.uk/child-employment
viii “Child employment,” Gov.uk, accessed
December 18, 2018,
https://www.gov.uk/child-employment/
paying
You can find more information on
the work of The Clewer Initiative and
Santa Marta Group on their websites.
www.theclewerinitiative.org
22 www.santamartagroup.com 23Rights Lab
For further information,
please contact:
Rights Lab
University of Nottingham
University Park
Nottingham NG7 2RD
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