1          Introduction: About Welsh Women’s Aid

1.1       Welsh Women’s Aid is the lead national organisation in Wales, providing the voice of local services and survivors to government as well as campaigning, influencing policy and practice, and innovating to end domestic abuse and violence against women across Wales and the UK. Welsh Women’s Aid is a membership organisation for 27 independent, specialist services in Wales which provide a range of support, advocacy and prevention services for women, children and families affected by domestic abuse.

1.2       We also deliver essential national and local services and projects across Wales, including  the All Wales Domestic Abuse and Sexual Violence Helpline – a 24 hour helpline for victims, concerned others and professionals; the Children Matter Project – to improve support for  children and young people  across Wales who are affected by domestic abuse; an Accredited Training Centre – Welsh Women’s Aid is an Agored Cymru centre, developing and delivering training in domestic abuse accredited qualifications for member organisations and external agencies; and delivering services for women and children in North Wales (Wrexham and Colwyn Bay) by providing refuges, outreach and community advocacy and support for women and children affected by domestic abuse.

1.3       Despite progress that has been made in Wales, research studies continue to find alarming and persistently high levels of violence against women and girls:

·      In Wales in 2013/14, there were 6,325 prosecutions of violence against women and girls offences, 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.

·      Welsh Women’s Aid’s members supported 9,337 women in 2013/14, with 2,263 women entering refuge;

·      The All Wales Domestic Abuse & Sexual Violence Helpline (managed by Welsh Women’s Aid) supported 27,972 callers in 2013/14.

1.4       Our response to this consultation is informed by our 37 years’ experience of responding to and preventing domestic abuse as a national membership organisation, ensuring the experiences of our direct and member services and survivors inform improvements in legislation, policy and practice



2.0 Welsh Women’s Aid is concerned by the suggestion within the draft Bill, that a supported standard contract will be issued to women who are residing in refuge accommodation once they have been resident for six months - unless there is designated, safe and appropriate move-on accommodation allocated specifically for women and their children leaving refuge in each local authority.


2.1 From Welsh Women’s Aid’s biannual data report (first half of 2014-15) almost three quarters of women stayed in refuge for two months or less (73%) and the most common length of stay was two months with 22% followed by 17% for 1 month. 14% of women stayed in refuge for 6 days or less. Only 27% of women stayed in refuge for more than 3 months, with only 4% staying for more than 6 months.


2.2 So although the majority of women reside in refuge for tfour months or less, there is still a small group of around 4% who will exceed the Bill’s six month threshold. The reasons why women may reside in refuge for longer than six months can be due to continuing and complicated support needs. This can be a result of the severe effects of domestic abuse, but the more common is a lack of suitable move-on accommodation for women in the local area.


2.3 It is therefore crucial for appropriate move-on accommodation to be allocated in order for women to leave emergency refuge and begin to rebuild their lives within the community.


2.4 The lack of safe move-on accommodation also has implications for victims who are yet to reach out to services, who may not be able access emergency refuge during their time of crisis due to bed spaces being occupied by women who are remaining in refuge awaiting appropriate move-on housing. Between April and December 2014, 104 women were turned away from Welsh Women’s Aid member services due to there being no free bed spaces.


2.5 Welsh Women’s Aid are concerned that under this new legislation women who are ready to leave supported accommodation, but are unable to do so, will not be granted the three month extension due to their reasons not being related to the explicit support needs the draft Bill refers to. It is felt that any transfer onto a supported standard contract can only exacerbate the issue of bed-blocking within emergency refuge accommodation.


2.6 Welsh Women’s Aid believes that the only way in which this contract system would work for supported housing schemes such as refuge, is if there was guaranteed access to safe and appropriate move-on accommodation. Therefore, this Bill’s amendments to tenancy reform cannot be supported by Welsh Women’s Aid or its members without this assurance.


2.7 Welsh Women’s Aid supports the proposals relating to addressing anti-social behaviour in households. We believe that the prohibited conduct term is a positive step forward in keeping women in the own home when it is safe to do so.


2.8 Welsh Women’s Aid would appreciate clarity around ‘prohibited conduct’ and the support for domestic abuse and other forms of violence against women within the Bill. In certain situations the perpetrator will not reside within the home, in which case the victim as the tenant may come under scrutiny for abusive or antisocial behaviour, which could conceivably put them at risk of losing their home. There may be opportunities here to cross-reference the Violence Against Women, Domestic Abuse and Sexual Violence Bill/Act.


2.9 A situation that may also arise is where a perpetrator of abuse may also be a victim and be in need of support from advice services through housing. It would be beneficial for this circumstance to be considered when writing guidance on applying the prohibitive conduct term. Welsh Women’s Aid would advise that training would need to be provided to all staff on the context of domestic abuse and other forms of violence against women to ensure that staff are able to appropriately identify victims and perpetrators, and support both effectively, including specific guidance and pathways for the various forms of violence against women (forced marriage, sexual violence, so-called ‘honour’ based violence, domestic abuse, female genital mutilation etc.). This may need to be in addition to any training requirements imposed by the Violence Against Women, Domestic Abuse and Sexual Violence (Wales) Bill/Act.


2.10 Within the draft Bill, the Prohibitive Conduct tool is named as anti-social behaviour and ‘other prohibitive conduct’, but Welsh Women’s Aid would recommend that domestic abuse needs to be stated explicitly and separately for those who will be using the guidance, in order for both these issues to be recognised as very separate issues and given equal importance for those utilising the legislation.


2.11 Welsh Women’s Aid believes it would also be beneficial to discuss a potential duty on Homelessness to support the perpetrator of abuse that has been removed from a household. Recognition for the effectiveness of accredited community perpetrator programmes is an opportunity to enhance the prevention of domestic abuse. The recently published Mirabal research undertaken by the Durham and London Metropolitan Universities suggests domestic violence perpetrator programmes (DVPPs) could play an important role in the quest to end domestic violence.


2.12 The study found that before attending the programme a third of men made women do something sexual they did not want to do, but none did so after taking part in the programme (30 per cent to zero). In the same way, cases of the men using a weapon against their partner reduced from 29 per cent to zero.[1]


2.13 Far fewer women reported being physically injured after the programme, with 61 per cent before compared to 2 per cent after. Over half of the women reported feeling ‘very safe’ after the programme, compared to less than one in ten before the programme (51 per cent compared to 8 per cent). This approach can therefore be seen as crucial when attempting to reduce the amount and severity of domestic abuse.


2.14 Welsh Women’s Aid would also advise that the Bill incorporates a duty to pay regard to the UN Convention on the Elimination of All Forms of Discrimination Against Women (known as CEDAW) and the Council of Europe Convention on Preventing and Combating Violence Against Women and Domestic Violence (known as The Istanbul Convention)[2] which was adopted by the UK Government in 2012 but is yet to be ratified. As Wales are members of the EU through the UK, Wales will also be responsible for complying with the Istanbul Convention when ratified, and as safe housing is key to supporting victims of domestic abuse, it is important that registered social landlords are aware of the duties that come under these conventions.


2.15 Welsh Women’s Aid supports the proposals for a more flexible approach to tenancies, which supports women to remain in their homes when safe to do so, once the perpetrator has been evicted. We hope that for some women it will allow them to sustain their tenancy individually, maintaining independence and the security of a home and local support network.


2.16 We would strongly advise, that in the circumstance where an eviction takes place on the grounds of domestic abuse being perpetrated, that there is guidance for registered social landlords to signpost to local specialist services and ensure community support is arranged. We would recommend that this is explicit within the Bill.  


2.17 Welsh Women’s Aid feel it is also important to highlight the detrimental effect that the UK Government’s welfare reform may have on the success of flexible tenancies. This may be the case when the benefit cap and the spare room subsidy have an effect on whether a victim is able to afford to live alone, and the potential pressure this may impart for them to remain in a violent or unsafe home.


2.18 This concern also relates to tenancy arrangements for 16 and 17 year olds. Welsh Women’s Aid supports the proposal to treat 16 and 17 year olds in exactly the same way as those aged 18+, however, girls between the age of 16 and 19 are also the most ‘at risk’ group in terms of experiencing domestic abuse with the CPS ‘Violence against Women and Girls Report stating that 25% of victims of violence against women were under the age of 24[3]. It is therefore vital that those aged 16-17 are also afforded the same protection in housing as those aged 18+, as well as a sensitivity to these increased levels of victimisation.


2.19 There are also relevant concerns in relation to the impact of welfare reform on these proposals, and how effectively they can be implemented. The single room rate for individuals under 25 may affect their ability to maintain their tenancy individually even with legal support through housing.


3.0 Thank you again for the opportunity to contribute to this consultation. If you require any further clarification of the information contained in this response, or any other matter relating to volence against women, please do not hesitate to get in touch.



Becky Jones (Policy Officer)

Welsh Women’s Aid





[2] http://www.coe.int/t/dghl/standardsetting/convention-violence/about_en.asp

[3] http://www.cps.gov.uk/publications/docs/cps_vawg_report_2014.pdf