Case Study: Dawn Raid and Modern Slavery Investigation- Forbes Secures No Further Action for Business Owners

Forbes Solicitors acted for the owners of a large North West business following a high-profile joint operation involving police and regulatory authorities investigating allegations under the Modern Slavery Act 2015.

The operation involved a coordinated dawn raid at business premises and residential addresses. Officers seized substantial quantities of business records, computers, mobile phones and electronic material. National media organisations, including Sky News and the BBC, attended the operation, creating immediate and serious concerns regarding reputational damage, business continuity and future regulatory exposure.

Craig MacKenzie, Partner and Head of Forbes Solicitors’ High Profile & Private Crime Division, was instructed.

Following extensive engagement with investigators, detailed legal representations and sustained challenges regarding the scope of the investigation and seizure of material, the police ultimately concluded the investigation with no further action against both the business and its owners. All seized property was ordered to be returned.

The Investigation

The investigation arose under the Modern Slavery Act 2015 and related to the operation of a substantial commercial business. It began with a coordinated dawn raid involving police and regulatory authorities, during which extensive business records and electronic devices were seized. Senior individuals connected to the business were subject to interviews and investigative enquiries, all taking place under intense national media attention, with organisations such as Sky News and the BBC present at the scene.

This level of exposure significantly heightened the reputational risk for both the business and its owners. Alongside the criminal investigation, immediate concerns emerged regarding business continuity, employee confidence, ongoing commercial relationships, and potential regulatory scrutiny. There were also critical legal issues relating to the preservation and protection of legally privileged material obtained during the raid.

Forbes’ Involvement

Forbes Solicitors was instructed at an early stage to advise both the business and the individual owners. The matter required urgent and coordinated strategic management across multiple fronts. This included direct engagement with police and regulatory authorities, challenging the scope and ongoing retention of seized material, and ensuring that legally privileged communications were properly protected.

The team also advised on reputational management and the wider commercial implications of the investigation. A significant issue arose regarding the seizure of privileged material contained within electronic devices and documentation, which required careful handling and ongoing legal challenge.

Throughout the investigation, Forbes maintained active engagement with the Officer in Charge and investigating authorities, making detailed and sustained representations on both the evidential position and the proportionality of the investigation.

Outcome

Following full review of the evidence, the Police formally concluded the investigation and confirmed that no further action would be taken against either the business or its owners.

The police confirmed that the evidential test required to support any prosecution had not been met and the investigation was formally closed.

Key Issues

The case involved a number of critical issues, including responding to a dawn raid, navigating a joint regulatory and police investigation, and dealing with allegations under the Modern Slavery Act. It also required careful management of media exposure and reputational risk, alongside safeguarding legally privileged material. The seizure of electronic devices and business records created further complexity, necessitating strategic engagement with investigators and coordinated representation of both the corporate entity and individual owners. Ultimately, these issues were resolved with a no further action outcome.