Email address:


Telephone Number:




These are the views of:  

Simon Borja


Safer Wales


029 2046 1564


1st Floor, 1-7 Castle House, Castle Street, Cardiff, CF10 1BS

An organisation (Third Sector)   


Committee Clerk

Communities, Equality and Local Government Committee

National Assembly for Wales

Cardiff Bay, CF99 1NA


1 Introduction

1.1. Safer Wales would like to thank the Committee for the opportunity to provide evidence towards scrutiny of the ‘Gender –based Violence, Domestic Abuse and Sexual Violence (Wales) Bill’, which we applaud as a step forward for victims in Wales.

1.2.Safer Wales has over 17 years experience in developing and delivering evidence-based services for victims of Domestic Abuse, Sexual Violence, Women and Girls exploited through street based prostitution and Women offenders.




2 About Safer Wales

2.1 Safer Wales manages Women’s Safety Unit which provides a fully qualified team of CAADA qualified Independent Domestic and Sexual Violence advocates to support women who are high risk victims of domestic abuse and sexual violence; developing the MARAC, Specialist Domestic Violence Court (SDVC) and the IDVA service.

2.2Safer Wales developed the Safer Wales Dyn project, launched 2006.  Safer Wales Dyn project is the lead project working with men experiencing domestic abuse and sexual violence. Dyn Wales Helpline and training to support services across Wales and the UK.

2.3Safer Wales develops and delivers services to reduce violence, exploitation and slavery. Safer Wales StreetLife project works with women at risk of violence and exploitation, particularly women exploited through street-based prostitution.  Safer Wales StreetLife provides outreach and intensive support and case management to improve personal and community safety  reducing violence and abuse. Safer Wales StreetLife developed the Sex Workers Operational Team (SWOT): Safer Wales targeted prevention service for young girls reduces risks of child sexual exploitation through positive engagement, increased disclosure and access to learning.

Safer Wales is a member of the Violence Against Women Action Group and Welsh Women’s Aid and we fully support their written evidence submissions in particular:

3 General Principles and purpose of the Bill: removal of Violence Against Women’

3.1. Safer Wales is disappointed with the loss of the term ‘Violence Against Women’ from the title of the Bill. Safer Wales feels its replacement with ‘Gender Based Violence’ has presented a gender neutral response to Domestic Abuse, Sexual violence, FGM, Forced Marriage, crimes committed in the name of honour, slavery, stalking and harassment. All of which are crimes that disproportionately effect women and girls.  In Wales in 2013/14, there were 6,325 prosecutions for offences of violence against women and girls , with a conviction rate of 76.7%. Of these, 5,637 were cases of domestic abuse; 257 cases of rape, and 431 cases of sexual offences.

3.2. Both domestic abuse and sexual violence  are included within the internationally accepted understanding of what constitutes  ‘violence against women’ along with other forms of violence and abuse which disproportionately affect women, such as female genital mutilation (FGM), women and girls exploited through street based prostitution, forced marriage, crimes committed in the name of ‘honour’, human slavery, stalking and harassment.

The current internationally accepted definition of ‘violence against women’ used by the  United Nations, World Health Organisation, Crown Prosecution Service, UK Government and international governments is:

’Any act of gender-based violence that results in, or is likely to result in, physical, sexual or mental harm or suffering to women, including threats of such acts, coercion or arbitrary deprivation of liberty, whether occurring in public or in private life."[1]

This definition is particularly significant as it firmly places violence against women as a violation of women’s human rights and reflects interntional understanding of this. Safer Wales is proud of Wales taking a lead in this area, as recognised by the UN Rapporteur, however, we are concerned that the dilution of the title of the Bill may weaken the potential positive and pro-active international and local impact of eradicating violence against women and girls.


Safer Wales developed the Dyn project to support men who experience domestic abuse.  Men and Boys will continue to experience domestic abuse and sexual violence and Safer Wales is strongly supportive of the principle that all victims should have access to effective, appropriate support services. Safer Wales recognition of all victims including children as victims is important to combat the harmful impact of such violence.  Safer Wales feels that the inclusion of the term ending violence against women and girls does not detract from appropriate and effective victim services.   


3.3. Safer Wales is concerned that the gender neutral term will mislead the public commissioners, and victims who access services across Wales.  The success of the Womens Safety Unit and the Dyn project are that they are gender-informed; designed for women and men.  Safer Wales believes that a gender neutral response will not engage with victims, or recognise the differences in women’s and men’s services.


3.4. The Safer Wales Dyn project developed an assessment tool,  based on research, This assessment ensures that we are able to offer appropriate support to all victims based upon risk of harm, identification of primary victim, increasing safety and provide appropriate support for cases where counter allegations exist.    Safer Wales’ fromtline delivery experience supports a direct difference of approach is required for  men and women to maximise service effectiveness.


4 General principles and purpose of the Bill: role of the Advisor 


4.1 Safer Wales welcomes the Advisor role and would strongly suggest that the proposed Advisor role has the authority to hold parties to account, with scope to issue sanctions should public authorities not comply.  Safer Wales would suggest the setting up of an independent advisory group from specialist third sector organisations to inform and support the Advisor.


5 General principles and purpose of the Bill: omission of education and prevention


5.1 Safer Wales request that the Welsh Government ensure that prevention is at the forefront to prevent future victims of violence against women.  Safer Wales recognises that the current curriculum review will consider domestic violence. However, Safer Wales supports embedding the prevention agenda at every level across the education system, incorporating a whole school approach. Safer Wales believes prevention needs to be set in statute, which will serve to support the curriculum review.


5.2 Safer Wales request that more work be done with boys to break the cycle of violence against women and girls including boys who have witnessed violence against women.  Safer Wales recommend that the Welsh Government take the lead to do more work to ensure that boys are engaged with and specific programmes developed and evaluated. Safer Wales recommends that more work be done, to challenge the root causes of violence against women which include; sexism and lad culture.


6 The financial implications of the Bill –Increased pressure on services


6.1Increase in people accessing services due to increased public sector awareness through ’Ask and Act’ and Welsh Government campaigns e.g. live fear free will put pressure on frontline services, particularly IDVA services. Safer Wales recognises that domestic abuse is costly to the Welsh economy. (Recent Wales figures on the cost of just domestic abuse on the Welsh economy was a total of £826.4 million, which included £303.5m [health care, criminal justice costs, social service, housing, legal and economic] and £522.9m [human and emotional costs]).[2]However, Safer Wales believes these costs will mitigated in the long-term, by appropriate identification and response, beneficial for future generations. Safer Wales recommends compulsory audit of demand for services, relevant costs and where evidenced savings across public sector service areas. 


6.2 Safer Wales would recommend that the Welsh Government reference the CAADA review of Domestic Abuse services in South Wales to support the influencing of commissioning of services in other areas across Wales.


6.3 Safer Wales would recommend that evidence based services be protected e.g. IDVA services and that the standards are maintained across the sector e.g. formal CAADA qualifications maintained and funded.   Safer Wales would recommend that commissioners recognise an IDSVA particular role and qualifications to ensure that consistency for victims across Wales is maintained.  Safer Wales recognises that there will be an unlikely increase in funding, however it is vital that evidence based interventions are protected.   


6.4 Safer Wales recommends that funding is sustained for evidenced based services for longer periods e.g. three to five years      





[1] United Nations: ‘Declaration on the Elimination of Violence against Women’, General Assembly