Exploring the place of adult learning for refugees and asylum seekers in migration policy for integration in England and Scotland

Abstract Learning, particularly learning English is presented as a key part of integration for adult migrants in the UK. England and Scotland differ in how their policy approaches to integration include adult learning. This article aims to explore and uncover the ways in which adult education, particularly for refugees and asylum seekers is embedded and included in policy for integration of new migrants in England and Scotland. This is based on a discourse analysis of policy documents, through which themes were developed and explored. In these documents, adult education can be included in explicit ways, particularly when it comes to language learning, while informal learning is not always explicitly considered. In England, British values are highlighted as an important area for learning, while Scottish policy uses a different tone, referring to newcomers as ‘New Scots’. The ways in which certain groups, particularly people seeking asylum are politically constructed, appear to impact greatly on how they are included in policy. This paper argues for the need for an explicit policy for adult learning for refugees and asylum seekers, the need to consider informal learning in policy, and identifies areas for future research in the field of adult learning relating to migration.


Introduction
In May 2021, the then Home Secretary Priti Patel stated that 'Refugees who make their home here will be given supportmore support to integrate into the community, learn English, and become self-sufficient' (Home Office 2021a). Politicians often highlight learning, particularly learning English, as important for new migrants, and English for Speakers of Other Languages (ESOL) is often conveyed as a key area that newcomers need when they arrive in the UK. But there is little policy that discusses adult education specifically for new migrants, particularly refugees and asylum seekers in the UK. Integration is also regularly cited in political discourse as something which control of this for the whole of the UK. As will be discussed in more detail later in this paper, in contrast to England, Scotland chooses to specifically include people who are seeking asylum in its strategy for integration. Scotland also has had a history of integrating a community-based, learner-centred approach (Slade & Dickson 2021), while England has moved to a more skills-based approach since the 2000s, with adult education provision more focussed on the labour market (Tuckett 2017).

Integration
Both of the policy papers discussed in this article are concerned with 'integration'. Integration has an implication of wider, informal adult learning, as it expects that newcomers should learn about their new host country. However, this is a concept that has been debated at length. Integration is often presented in policy as being a 'two-way street' between migrants and their new communities. (HM Government 2018, p. 10). This is how policy makers differentiate 'integration' from 'assimilation', which expects that a migrant would adapt to a new culture, by abandoning their own and adopting its cultural practices. Integration, asks migrants to learn about the new culture, but the 'two-way' nature suggests that there would be some effort from the host society to learn about migrants' cultures and make changes and adaptations for them. There have been numerous criticisms of the concept of integration, including that it is simply used in policy as a synonym for assimilation in practice, as many states do not attempt to facilitate a two-way element, rather expecting migrants to adapt to the host culture but not learning about them (Xanthaki 2016). Furthermore, it has been suggested that in the UK there is 'no single national policy framework for integration, and no consensus on what the goals of such a policy might be. There is a lack of clarity on where responsibility lies in Whitehall, or between national and local government; differing definitions of integration used and some lack of consistency' (Broadhead and Spencer 2020, p. 5). In addition to these different perspectives on adult education policy and integration, there are also unsettled issues around how to define refugees, asylum seekers or migrants.

Theoretical framing
Who is a refugee, asylum seeker or a migrant?
There is a wealth of terminology surrounding those who have moved from one country to a new one. For example, a few years ago I lived and worked in Vietnam, teaching English, and British people living there called themselves 'expats'. But people who move to the UK to work in similar jobs are labelled as 'skilled migrants' by the British government. The language used to talk about mobility is not neutral, and Kunz (2020) argues that categories such as 'expat' and 'migrant' work to reproduce racialised power relations.
The UN defines a refugee as 'someone who is unable or unwilling to return to their country of origin owing to a well-founded fear of being persecuted for reasons of race, religion, nationality, membership of a particular social group, or political opinion' (UNHCR 2019). In the UK, the Home Office is responsible for deciding whether this definition is met. Someone who has applied for refugee status, a process called claiming asylum, but has not yet been approved by the Home Office is labelled as an 'asylum seeker'. There are also refugees in the UK who have moved here through resettlement schemes, for example, the UK Government announced the Afghan Citizens Resettlement Scheme for people who need to come to the UK from Afghanistan, and the Ukrainian resettlement scheme, although at the time of writing, the former does not seem to have successfully relocated many Afghan people in the UK (Migration Observatory 2022). Crawley and Skleparis (2018, p. 51) point out that when talking about refugees, 'policy and legal categories may appear fixed, neutral or objective even, but are, in fact constantly subject to challenge across different national and regional contexts'. 'Migrant' is often used as a more general term, and also has contested definitions. For example, the UN International Organisation for Migration (IOM n.d.) defines a migrant as 'the common lay understanding of a person who moves away from his or her place of usual residence, whether within a country or across an international border, temporarily or permanently, and for a variety of reasons', but also asserts that no definition of 'migrant' is agreed upon in international law. The boundaries of who is categorised as a refugee, asylum seeker and migrant are blurred and overlapping. Policy categories are frequently binary and fixed in nature, but this is challenged by the complexities of movement (Crawley and Skleparis 2018). Within all of this terminology it is important to remember that these words are referring to real people with rich and varied lives, who move from numerous countries around the world. In this article, I will use the terms 'refugee', 'asylum seeker' and 'migrant', in line with the policy documents, but I acknowledge the complex and problematic nature of these terms.
In 2022, the UK government passed the Nationality and Borders Bill, which aims to 'deter illegal entry into the UK' (Home Office 2021b). This bill attempts to make it more difficult to claim asylum in the UK, depending on the method of arrival, and would limit the legal rights of people seeking asylum. In April 2022, the Home Office announced the Migration and Economic Development Partnership, through which it plans to deport some asylum seekers to Rwanda. The Nationality and Borders Bill has been criticised by hundreds of organisations supporting refugees in the UK, including the UNHCR (2021). The UK Home Office has been accused of aiming for the explicit separation of refugees into two tiers, those who have arrived in the UK and claimed asylum, and those who have been resettled in the UK through government schemes, who are framed as more legitimate (Refugee Council 2022).
People seeking asylum are not allowed to work in most circumstances (UKVI 2014). Adult asylum seekers are also limited in their options for accessing education, with funding for free college English classes restricted until they have been waiting for an asylum claim for at least six months (Refugee Education UK n.d.). To meet this need, charities around the UK are offering free English classes for refugees and asylum seekers, and these are usually taught by volunteer teachers. This means that new arrivals in the UK who want to learn English, and may have time to do so, are usually not able to access much formal adult education, and non-formal education may not be sufficient.

Adult learning
My analysis of the policies and this context is informed by theory on informal learning (Rogers 2014). This literature posits that learners already possess 'funds of knowledge' (Moll et al. 1992), examples of tacit knowledge and skills which may have been acquired through informal learning. For people who are migrants living in the UK, this could be related to their lives in countries of origin, acquired through professional roles, their homes, or on journeys to the UK. In the UK, accreditation of prior learning schemes have attempted to recognise learners' funds of knowledge in a more formal way (Rogers 2014). Unfortunately for international migrants living in the UK, even formally accredited prior learning from their home countries often goes unrecognised, leading to de-skilling and underemployment (Morrice 2007). Additionally, it has been found that policy that bans those seeking asylum from working also reduces their chances of future employment (Fasani et al. 2021). Blommaert (2004) has applied theories of literacy as a social practice to refugees who have moved from one country to another, suggesting that literacies that might be valued in one culture may become abnormal and stigmatised in another. Refugees make journeys across the world to the UK, so their prior-knowledge and ways of approaching learning may be challenged. This means that much prior learning and the ways that they may approach learning, or what they value as important knowledge may be unfamiliar and is often unrecognised in the UK context. On the other hand, community learning provision of ESOL in the UK often provides flexible, friendly spaces and often the provision of community meals. For example, Slade and Dickson (2021) have commented that these environments in Scotland have fostered informal learning for migrants.

Methodology
This article is based on a discourse analysis of two policy documents, one from England and the other from Scotland. It is a part of a wider PhD project which is exploring how adult learning for refugees in England and Scotland relates to social transformation. As the PhD project involves fieldwork in both Scotland and England, I wanted to delve into the policy background, to explore how this may impact learning. The devolved nature of education, alongside the fact that immigration policy is not devolved, reveal how England and Scotland have differing approaches to 'integration'.
In January 2018, the Scottish Government published the 'New Scots Refugee Integration Strategy 2018-2022' paper (Scottish Government 2018). I will refer to this paper throughout this article as the New Scots strategy. This is publicly available on the Scottish Government website and listed as a 'strategy/plan'. The first 'New Scots Strategy' was published in 2014, establishing 'networks and partnerships … [enabling] the New Scots approach to be implemented through the direct work of organisations, as well as through collective effort' (Scottish Government 2018, p. 14). The updated strategy has built on this and been developed by engaging with partner organisations and states that it 'aims to be dynamic, so that it can adapt to changing political, policy or international contexts' (Scottish Government 2018, p. 14). The paper starts by introducing the 'New Scots' approach, the context of refugees and asylum seekers in Scotland and then outlines the key themes that have been developed through the consultation. These are: Needs of Asylum Seekers Employability and Welfare Rights Housing Education Language Health and Wellbeing Communities, Culture and Social Connections (Scottish Government 2018) In England, the Ministry of Housing, Communities and Local Government published the 'Integrated Communities Strategy Green Paper' (HM Government 2018) in March 2018, which applies only to England. I will refer to this paper throughout the article as the Integrated Communities strategy. The government has also updated this with an 'Integrated Communities Action Plan' (HM Government 2019) in February 2019. The green paper calls for responses and the action plan identifies specific action points that came from the green paper, with some case studies of organisations mentioned. The green paper starts with a foreword from the then Prime Minister Theresa May and the then Secretary of State for Housing Communities and Local Government Sajid Javid, although neither were in these roles when the action plan was published. The action points are divided to different areas of UK government (e.g. The Home Office, Department for Education, etc.). The papers are divided into the following themes: Strengthening Leadership Supporting migrants and resident communities Education and young people Boosting English language Places and community Increasing economic opportunity Rights and freedoms (HM Government 2018) I explored how the two papers on integration approached adult learning, the ways in which they discuss learning and how they presented the subject of refugees/migrants themselves in relation to education. Through exploring the theory and wider literature, I devised the following research questions: How does policy aimed at 'integration' of refugees and asylum seekers include adult education in England and Scotland, and in what ways do the two nations differ in their approaches to adult learning for refugees? I used a comparative, critical approach to discourse analysis, drawing on Gee (2014) and Fairclough (2015) to explore the language that was used in the policy documents, and informed by theories around informal learning and migration, to consider how learning was discussed in the texts. I hoped to explore how policy constructed adult learning for new migrants through discourse, and this approach additionally 'seeks better understanding of how language contributes to the domination of some people by others' (Fairclough 2015, p. 46). As will be discussed, there are significant differences in the construction of migration and learning between the two papers. Key themes were identified through the reading of these documents and the wider policy, context and theoretical framing of informal adult learning, these themes will be explored below. The next sections will discuss the themes identified from the comparative analysis of the policy documents in line with the research questions.

Comparative analysis of the two policy documents
Finding a place for adult education Although both papers devote sections to education, adult education is discussed in varying ways. Integrated Communities (HM Government 2018) has a section on education that is solely about children and young people, although it does have an additional section on universities and Higher Education. It is a separate chapter on English language that is concerned with adult education, and it does mention the 'Adult Education Budget' several times, which funds some ESOL (English for Speakers of Other Languages) provision. This omission from the education chapter is reflective of a neglect of adult learning from discussions of education in policy. The fact that it is consigned to the chapter on language education suggests that this may be the only area of adult education that the government feels is important for migrants in England.
The New Scots strategy (Scottish Government 2018) also has a chapter on education, which does have a section on post-school education. It mentions Community Learning and Development as 'an important part of the education sector in Scotland' which 'supports primarily disadvantaged or vulnerable groups and individuals of all ages to engage in learning, with a focus on bringing about change in their lives and communities' (Scottish Government 2018, p. 47). There is a specific acknowledgement of wider learning needs of adults, although this is admittedly fairly small compared to the space given to ESOL learning. The New Scots strategy identifies recognition of prior qualifications as a key action point and commits to developing an accreditation process (Scottish Government 2018, p. 49). Integrated Communities does not mention prior learning, other than that at the jobcentre, Work Coaches will discuss migrants' skills, previous qualifications, training and employment with them. 'Work coaches are assigned to claimants and discuss with them their skills, qualifications, previous training and work history. Where a claimant has skills needs which are a barrier to work, those needs are assessed and referrals made to training or other action that will support them in finding work' (HM Government 2018, p. 52). The language used assumes a deficit approach, that migrants are lacking in skills, and need to receive further training which will help them to find work. However, research has explored the idea that refugees experience high levels of de-skilling and underemployment when settling in the UK (Morrice 2007). This means that people are often overqualified for roles that they take on, but this is not acknowledged in the policy, which suggests that it is individuals who need to gain skills. There is no exploration of how to support people to recognise prior qualifications and learning in Integrated Communities. This lack of acknowledgement of the prior learning and skills of refugees could give some insight into why deskilling may continue. There is no mention of whether job centre staff are supported to help those with overseas qualifications and experience to find work in the UK.
There are less explicit mentions of areas which suggest informal lifelong learning. As discussed above, Rogers (2014, p. 20) states that 'Informal learning is ubiquitous, universal and continuous; it is part of the process of living in a social context'. Integrated Communities places a very strong emphasis on social connections as contributing positively to integration (HM Government 2018). It emphasises that a 'lack of social mixing' can 'increase levels of mistrust and anxiety … limiting their ability to make the most of the opportunities that Britain offers' (HM Government 2018, p. 12). This suggests an underlying acknowledgement of informal learning, with an implication that socialising with people from other cultures will lead to learning about them and changing assumptions. However, there is no overt mention, and informal learning has not been explicitly considered in the education or English language section, and there is no discussion of how it might be facilitated. This shows that although certain types of informal learning are recognised as important, they are not necessarily considered to be part of adult education in England.
The education section of the New Scots strategy states that it wishes to identify and promote 'informal activity that helps to raise awareness of best practice when working with refugees and asylum seekers' (Scottish Government 2018, p. 48). There is also mention of 'informal language sharing' (Scottish Government 2018, p. 51), and this shows that the Scottish Government has considered the role of informal learning more consciously. On the other hand, this is not expressly incorporated into its action points for English language learning, so it does seem to be an area which could be explored more concretely in both nations. However, there does seem to be more explicit acknowledgement of informal learning in Scotland than in England.

Learning English
English language is a key theme in both England and Scotland. The Integrated Communities Strategy starts with the assertion that 'everyone living in England should be able to speak and understand English so that they can integrate into life in this country' (HM Government 2018, p. 35). The New Scots strategy suggests that English Language was a key factor for integration identified by the stakeholders developing the strategy and 'there were consistent appeals from refugees and asylum seekers for help to improve their English language skills' (Scottish Government 2018, p. 51). This demonstrates a difference in approach between the two nations. England presents learning English as something that migrants 'should' do in the eyes of the government. Scotland, through its research presents it as something that migrants are themselves concerned about. For example, they found in their research that 'some participants highlighted a lack of opportunities or awareness of informal language learning beyond the classroom' (Scottish Government 2018, p. 53). This could be seen as respective top-down and bottom-up approaches to the policy. It could also tell us about how migrants and the facilitation of their learning are viewed in the eyes of the governments. The Integrated Communities strategy devotes several pages and graphs to the 'challenge' that 'too many' (HM Government 2018, p. 35) people do not speak English, and statistics of people who do not speak English according to ethnicity. This is presented as a failing of individuals, and presents barriers to learning English in these terms, seemingly a neoliberal individualisation of responsibility. However, this rhetoric that individuals must learn English is contradicted by the continual funding cuts to ESOL classes in recent years (Bennett 2018). Additionally, even when funding is given, it may be from a racialised deficit approach, for example, David Cameron's attempt to 'support' South Asian women to learn English (Mason and Sherwood 2016). In contrast, Scotland presents migrants as wanting to learn English and sees the challenge as providing learning opportunities to meet this demand. Therefore, the Scottish government does accept some responsibility, rather than seeking to blame those who have not learned to speak English yet.
The Integrated Communities strategy states that English language education is funded by the Adult Education budget, with 'eligible learners' able to access free classes through the job centre (HM Government 2018, p. 38). There is not an acknowledgement in Integrated Communities that there is a lack of funding for English classes. However, this has been acknowledged in other government documents, for example in a more recent 'plan for an adult skills and lifelong learning revolution' (House of Commons 2020). Other research in England has suggested that ESOL is underfunded and many refugees and asylum seekers in areas around the UK are unable to access these funded classes (e.g. Refugee Action 2019). Integrated Communities mentions volunteer-led 'conversation clubs', which it states are useful when standing alongside formal English classes in colleges (HM Government 2018, p.41). This is presumably referring to community language classes led by volunteers, as these are not mentioned elsewhere. Integrated Communities states that it will need to develop a strategy specifically for ESOL (which Scotland has already done), although a strategy for England has not yet been published at the time of writing. This shows a picture of ESOL in the UK which seems to be lacking in depth, and neglects to acknowledge that many classes for refugees and asylum seekers are provided by volunteers to fill the gap in provision.
The New Scots Strategy also has a section devoted to language learning, and in addition, has published a separate, specific strategy for ESOL (Scottish Government 2015). Interestingly, the New Scots strategy has the objective that 'refugees have the opportunity to share their language and culture with local communities' (Scottish Government 2015, p. 53). This is evidence of an eagerness to incorporate a 'two-way' element to integration. Although it could be suggested that the proposed action of promoting 'good practice, in which the home language of refugees is used in positive ways' (Scottish Government 2015, p. 53), could be developed further and be more concrete, as it does not give explicit ways or examples in which this could be done.

Learning for asylum seekers
The New Scots strategy has a theme covering the needs of asylum seekers. This section identifies that people who are seeking asylum, as opposed to those who have been resettled, or have gained refugee status, have unique needs. Since 1999, asylum seekers have been 'dispersed' to different areas of the UK, in Scotland this has predominantly been to Glasgow which houses around 10% of those dispersed in the UK (Scottish Government 2018, p. 28). The New Scots strategy highlights the fact that asylum policy is not a devolved area, so is guided by the government in Westminster, but that the Scottish government has been keen that 'integration should begin from the day an asylum seeker arrives in Scotland' (Scottish Government 2018, p. 28), through utilisation of devolved services. This section acknowledges that those going through the asylum process have particular challenges that can 'impact … on their integration' (Scottish Government 2018, p. 29). It also highlights the challenges surrounding asylum housing which has been contracted by the UK government to the private company Serco since 2012 (Scottish Government 2018, p. 28). The document suggests that this outsourcing may mean that many asylum seekers are housed in areas that mean they are not able to access the adult education and support services that they require.
One action point in the New Scots strategy is to 'examine the implications of the Immigration Act 2016' (Scottish Government 2018, p. 31), this is the UK legislation often referred to as the 'Hostile Environment' aimed at discouraging irregular migration (Webber 2019). The Scottish government also wishes to involve asylum seekers in 'policy formulation and in the strategic planning and development of services for them' (Scottish Government 2018, p. 31). The New Scots strategy does not explicitly condemn the UK government's approach to migration, but it does seek to distance itself from it, consistently highlighting policies that are out of the Scottish Government's jurisdiction. By seeking to support asylum seekers in these ways, the document seems to make a political point that the Scottish Government does not agree with the Home Office's 'hostile environment' approach. By recognising the alternative needs of asylum seekers, the Scottish government is able to identify different approaches to helping them access services that they may require.
The Integrated Communities strategy does not have a corresponding section about the specific needs of people seeking asylum. The only mention of asylum seekers occurs when the paper talks about 'unaccompanied asylum seeking children' (HM Government 2018, p. 24), acknowledging that additional funds have been directed to local authorities for unaccompanied children. Integrated Communities notes that refugees who arrive in the UK 'through a resettlement scheme' should 'receive a comprehensive package of support to help them … resettle successfully in Britain' (HM Government 2018, p. 22), but does not elaborate on those who arrive in the UK and seek asylum. This quote indicates the separate funding streams for education and integration of those arriving in the UK on particular resettlement schemes. The lack of acknowledgement of asylum seekers could signal the belief that those seeking asylum are not seen as legitimate migrants, or deserving of integration, or adult education. The 2016 immigration act was aimed at creating a 'hostile environment' for those whom Theresa May referred to as 'illegal' migrants (Kirkup and Winnett 2011). The fact that there is a lack of acknowledgement of those seeking asylum in the English policy seems to imply that in the eyes of the government in 2018, access to education for 'integration' is not for people seeking asylum by ignoring them in policy. This seems to contradict the UK government's assertion that all migrants should learn English and integrate, by excluding some of the most recent arrivals from its policy on integration. This seems to be exacerbated by recent Home Office policy papers which try to restrict asylum seekers' rights more explicitly by attempting to label them as 'illegal' (HM Government 2021). This could be reinforced by the government's plan to send those arriving in the UK to seek asylum to Rwanda (Refugee Council, 2022). In this plan the government spends money to settle asylum seekers in Rwanda, rather than investing it in education for all those who arrive in the UK.
The naming of the 'New Scots Refugee Strategy' starkly differentiates Scotland's approach. The Scottish government chooses to name new refugees as 'New Scots', immediately making a statement that it would like to consider them as Scots, rather than outsiders. This positions the Scottish government as welcoming, and the replacement of the terms refugee and asylum seeker with 'New Scots' demonstrates a far less suspicious and hostile approach, as well as disrupting the UK Government's polarised policy construction of illegal/legal migration.

Learning British values
The Integrated Communities strategy consistently references British values as an important area of learning for new migrants. It asserts that the government will 'support teachers to promote British values across the curriculum' (HM Government 2018, p. 14), and 'The Green Paper proposes measures to support recent migrants so that they have the information they need to integrate into society and understand British values and their rights and responsibilities' (HM Government 2018, p. 25). This is one area which is expected of all newcomers to the UK, not just those who are learning English. British values have been developed as a part of the government's 'Prevent' strategy, devised to prevent what the government deemed to be extremism (Shah 2020). The Integrated Communities strategy predominantly outlines supporting teachers to promote British values in schools, but this has also filtered into ESOL education (Cooke and Peutrell 2019). British values (sometimes referred to as Fundamental British values, FBV), have been described as democracy, respect for the rule of law, individual liberty and respect and tolerance for other religions and beliefs (Pattison 2020). British values emerged in political rhetoric after the 7/7 London bombings in 2005, in a speech by Tony Blair, and were later re-emphasised by David Cameron in 2014, and were then incorporated by the Department for Education to be promoted by teachers in schools (Pattison 2020). It has been noted that ESOL teachers have been expected to 'broker' these 'values' in the ESOL curriculum (Cooke and Peutrell 2019).
Interestingly, in this area in the Integrated Communities strategy, the lines become blurred between migrants and British citizens who were born in the UK. The paper sometimes moves into questions of 'ethnicity', rather than migration, even though many people who may be 'ethnic minorities' are British citizens. For example, Integrated Communities states 'Extremists promote actions that undermine our shared values. We see far right and Islamist extremists seeking to divide communities with a false narrative that being Muslim is incompatible with British values and our way of life, despite all the evidence to the contrary' (HM Government 2018, p. 57). People who speak English who may have lived their whole lives in England have become potential subjects of policy aimed at integration of migrants. As Pattison (2020, p. 91) has suggested, the boundaries between national identity and belonging are becoming more and more complex: 'Fundamental British Values make explicit the identifying features of citizenry-no longer a passport or birth certificate but a way of life and values marked by allegiance to the law and democracy, to personal autonomy, and to maintaining the collective peace through prescribed mechanisms of toleration. On a less explicit agenda, these values play into the control of knowledge and reason through constructions of what is rational and right and it is these same structures of rationality that give FBVs a logic and credence such that they may be seen as a duty of education, rather than an overt political choice'. These values are considered to be top-down, and unnegotiable and by embedding them within formal policy and curriculum in England, educators seem to be expected to reproduce these. Similarly, Heinemann (2017) has noted that in Austria and Germany, integration education for migrants has a 'civilising mission', reproducing Eurocentric norms.
It is also interesting to note that although the Integrated Communities strategy is an English policy paper, it refers to 'British' values. The New Scots strategy does not reference the promotion of British values (or indeed Scottish, or any other kind of values). The absence of this from the New Scots strategy suggests that this is not a priority area for the Scottish government and perhaps that it does not wish to associate itself with promoting this set of values. It seems unlikely that this is because the Scottish government has its own set of 'Scottish values', as this is not mentioned either.

Discussion
There is a key difference between how England and Scotland conceptualise what integration is, and who integration is for. England's policy dances around the concept of refugees and asylum seekers. By not explicitly talking about asylum seekers, there is an implication that they are to be excluded from integration. The New Scots strategy is specifically for refugees and asylum seekers, and there is no equivalent policy which matches this in England, especially for asylum seekers. This creates a hierarchy of who is or is not able to access adult education provision. In England, if those seeking asylum are excluded from policy for integration, and subsequently for provisions for language education, they may not be able to access classes.
Adult learning is present in certain areas of both policy papers, but not elaborated fully at times, particularly in the English policy. Scotland has a history of supporting community adult learning, and this is reflected in its policy. England only acknowledges the importance of English language education for adults, which is admittedly a crucial area, but neglects the life-wide and life-long elements of adult education. This could be reflective of a wider neglect of adult education in England.
In England, the challenge was put forward that too many people do not speak English, and in Scotland it was posited that refugees wanted to learn English.
Although both policy approaches aim for the same goal, for migrants to learn English, England comes across as top-down, and Scotland as more learner-centred. It is possible that Westminster's approach stems from an intentional political decision to put the blame on individuals for not learning English, rather than acknowledge explicitly that funding for ESOL has been continually cut in England (Refugee Action 2019).
Scotland does not mention British values, which significantly marks it from England whose strategy is peppered with references to the importance of the promotion of these values particularly through education. Firstly, this could be indicative of the different framing of new migrants, and the individualising of responsibility to learn what it is to be British. For Scotland, refugees are already considered to be 'New Scots', rather than prescribing a set of criteria that encompass 'Scottishness' or 'Britishness', as is the implication with 'British values'. In England, migrants, and even citizens (particularly British Muslims) are positioned as outsiders or 'other', until they learn these British values. This deficit approach means that the opportunity is lost to develop other areas of learning, or more democratic ways of learning about shared values as a community, for example through critical dialogue. Even though the Integrated Communities strategy initially asserts that integration is 'two-way', there is no discussion of how learning could be reciprocated by host communities.
The ways in which learning is incorporated in both policies are sometimes explicit, mostly with regards to schooling and learning English. Sometimes mentions of learning are not as explicit, for example suggestions that socialising with people from other countries will foster inter-cultural learning. With the promotion of Fundamental British Values, there is not a developed curriculum, and there is less suggestion of where adults may learn these, and the focus is generally on schools.
The Integrated Communities Strategy contains little explicit acknowledgement of the prior learning and experience of migrants, assigning this to be handled by the job centre. However, this limitation misses an area that is a huge part of the lives of adult newcomers. In Italy, Bencivenga's (2017) research of informal initial assessment, as seems to be provided by the job centre in the UK, has suggested that much of adult migrants' informal and non-formal prior learning and skills are disregarded. Scotland does discuss prior learning to some degree, but could elaborate on this further in its policy. Both countries could consider more closely the very wide range of skills, experience and prior learning which many migrants, refugees and asylum seekers bring with them. More acknowledgement of prior learning could help migrants, but also benefit the communities they live in. Considering informal learning more directly would additionally help to bring focus to and acknowledge the wide range of prior learning and skills that migrants have.
Each paper approaches integration and the learning that is required for it in relatively individualised ways. In England, there is more of a neoliberal individual responsibility approach, and Scotland has a person-centred approach to learning. The spaces and resources where learning is to take place are not deeply considered. There could be much more consideration of how charities are supporting learning, particularly in the Integrated Communities strategy. Furthermore, neither paper discusses adult educators much, or the people who will facilitate the learning. There is a need for research to explore whether and how this policy matches to what is going on in practice.

Conclusion
Both Scotland and England have some areas in common in policy for adult education for refugees and asylum seekers. Both have a strong focus on English language education, which is an important area for newcomers to the UK who do not yet speak English. Both emphasise the importance of integration itself, and frequently stress community cohesion. However, there are many differences between the nations' ideological approach to migration itself and both England and Scotland's inclusion of wider adult education. Scotland has a community adult education focus and has attempted to specifically involve refugees and asylum seekers in policy. Wider immigration policy, controlled by the Home Office, impacts how people who move to the UK can access adult education, and fosters unequal access to learning opportunities, and this can be seen reflected in the Integrated Communities strategy. It seems likely that recent policy such as the Rwanda plan to deport people seeking asylum will exacerbate challenges, by creating more stress and uncertainty for those seeking asylum in the UK and making it more difficult to live and learn in the UK. A specific policy focus on adult education for all who move to the UK would likely help, as well as more welcoming immigration policy.
Further study is needed to determine the impacts of policy on practice. For example, in Scotland it has been commented that although the New Scots strategy is promising, in reality there is still a need for additional and more stable funding for community ESOL classes in practice (Slade and Dickson 2021). Additionally, this research is limited to England and Scotland, but it is important to note that Wales and Northern Ireland have their own policy approaches in this area, which would also be important to explore in the future. This paper has critically compared policy in England and Scotland aimed at the integration of migrants, and explored the ways in which they include adult learning. Areas for future research in this field are highlighted in addition to areas in which policy towards newcomers need to be refined with detail of how to support learning and potentially integration in local communities.