The Trade in Human Beings: Human Trafficking in the UK - Home Affairs Committee Contents


Memorandum submitted by the Home Office

  The Committee have indicated that the primary focus of the inquiry will be on the response by public authorities in the UK and the effectiveness of international co-operation in addressing the problem. In particular, the Committee will consider:

    —  Estimating the scale and type of activity.

    —  The difficulty of finding those who have been trafficked when they are normally too frightened to complain to the authorities; and the role of NGOs in helping to identify and assist victims.

    —  The treatment of those who have been trafficked but have no legal right to remain in the UK, including the requirements imposed by the Council of Europe Convention on Combating Human trafficking.

    —  Co-operation within the EU (including Europol); and control of the EU's external frontiers.

    —  Relations with transit and source countries, and the role of Interpol and the UN Office on Drugs and Crime.

    —  Effectiveness of the co-ordination between public authorities in the UK (Home Office, FCO, police forces, Serious Organised Crime Agency, Border and Immigration Agency, social services).

INTRODUCTION

  1.  The Government affords a high priority to combating human trafficking. The UK Action Plan (http://www.homeoffice.gov.uk/documents/human-traffick-action-plan) published on the 23rd March 2007 sets out the Government's end to end strategy on tackling human trafficking. It includes a range of measures in the four key areas of prevention/investigation, law enforcement and prosecution/protection and assistance to victims/and child trafficking. The information set out in the Action Plan is not repeated here but read alongside this memorandum provides a comprehensive overview of current structures in place and action targeted at tackling human trafficking.

  2.  The UK Action Plan is a "living" document which will be updated regularly to ensure that our response remains targeted as our knowledge and understanding of this area grows. The implementation of the Council of Europe Convention on Action against Trafficking in Human Beings ("the Council of Europe Convention") signed by the UK on 23 March 2007 impacts on a number of different areas in the UK Action Plan. Implementing the Council of Europe Convention is action point 1 of the Plan and a dedicated project team was set up within the Border and Immigration Agency (BIA) at the beginning of May 2007 to lead on implementation. The team report to a Project Board (made up of senior officials from across government including representatives from the devolved administrations) and through that to the Inter-Departmental Ministerial Group on Human Trafficking.

  3.  The Convention implementation project has a number of work streams. In spring 2008 a pilot will be undertaken to test victim identification and support processes for trafficking for forced labour in a number of areas. Alongside intelligence gathered under Pentameter 2 this will help to broaden our understanding and develop our response to a lesser known form of human trafficking. An evaluation of the National Referral Mechanism being tested under Pentameter 2 will be conducted in early summer. A provisional victim support model has been agreed. It is expected that we will reach compliance with the Convention through a limited number of changes to primary legislation and wider changes to existing secondary legislation and procedures. It is intended that as far as possible proposals for these changes will be introduced before the summer recess with a view to ratification by the end of the year.

  4.  We are conscious that we need to see the implementation of the Convention as part of our wider anti-trafficking activity. Ratification is not an end in itself and we are already compliant with much of the Convention. There has already been a significant amount of good work under the UK Action plan and developments in the four key areas are set out briefly below.

PREVENTION

  5.  Work under the prevention strand of the Action Plan has been taken forward through a number of different initiatives. In order to develop a firm evidence basis the UK Human Trafficking Centre (UKHTC) has been established as the central repository of all data and intelligence on human trafficking. Awareness raising initiatives have been undertaken overseas as well as at home. A Foreign and Commonwealth Office ( FCO) funded awareness raising campaign amongst potential victims in Bulgaria and Romania, ahead of EU Accession, about the risks of migration as they relate to human trafficking was implemented through the UKHTC and International Organisation for Migration. The UKHTC's blue blindfold campaign is in the process of being rolled out across the UK. It is aimed at raising awareness amongst a number of different groups including the general public about all forms of human trafficking with the slogan "Don't close your eyes to human trafficking". The Home Secretary announced at the end of November 2007 a short term review on what more can be done to tackle the demand for prostitution and the impact this has on human trafficking. The review will consider approaches adopted in other jurisdictions, the development of additional measures and will involve further consultation with stakeholders.

  6.  Work to build capacity in source and transit countries continues and the UK have recently part-funded the secondment to the UK of two Romanian police officers into a Metropolitan Police joint unit to exchange experience, skills and knowledge in the fight against the criminal exploitation and trafficking of Romanian children to the UK. This was of particular assistance in relation to the recent operation which took place in Slough. The Department for International Development continues to support projects which address the factors that make individuals vulnerable to trafficking via their support for nationally developed poverty reduction programmes.

INVESTIGATION/LAW ENFORCEMENT/PROSECUTION

  7.  A number of measures have been undertaken over the last year to reinforce the strong enforcement response to human trafficking. The current police led, multi-agency operation, Pentameter 2, provides another opportunity to increase expertise amongst law enforcement and to encourage the proactive policing of human trafficking beyond the lifetime of the operation. The operation is ongoing but has made good progress thus far; over 300 arrests have taken place and more than 600 premises have been visited. A number of money laundering investigations are underway and a number of restraint orders have been put in place; with in excess of £400,000 seized to date. The continued funding and expansion of the UKHTC will also assist in the development of the policing response to this crime by upskilling front line officers through targeted training, awareness raising and the provision of 24/7 specialist tactical, immigration, victim and legal advice. We recognised in the UK Action Plan that performance indicators could have a role in ensuring that human trafficking is core police business alongside other measures and a performance measure on organised crime (which includes human trafficking) will be introduced in the new APACS (Assessments of Policing and Community Safety) system from 1 April 2008.

  8.  We have also kept the legislation on trafficking under review, to ensure it continues to provide an effective framework for the prosecution of trafficking offences. The number of successful cases prosecuted is increasing year on year and there have been 70 convictions for trafficking offences under the Sexual Offences Act 2003.[180] In January 2008 amendments made to the trafficking and facilitation legislation in the UK Borders Act 2007 came into force which will enable the more effective prosecution of those cases where the trafficking has been arranged by someone who is outside the UK and who is not a British citizen. It is important to note that traffickers may not necessarily be charged with offences under the trafficking legislation, depending on the facts of the case and alternative offences such as kidnap, rape and facilitation under the immigration legislation may also be charged. In preparation for Pentameter 2 the Crown Prosecution Service (CPS) issued further guidance to prosecutors to raise awareness about trafficking cases and a briefing/ training day was held for specialist prosecutors in each CPS area and Organised Crime Division.

PROVIDING PROTECTION AND ASSISTANCE TO ADULT VICTIMS OF TRAFFICKING

  9.  The Government has a comprehensive strategy to protect and support all victims of crime. This includes: a statutory Code of Practice for Victims of Crime; special measures to assist with giving evidence; a Criminal Injuries Compensation Scheme for victims of violent crime; and statutory protection for witnesses subject to intimidation. Significant progress has been made on the additional targeted measures in the UK Action Plan on the protection and support of adult victims of trafficking. The UK's decision to accelerate the implementation of the Council of Europe Convention to enable ratification by the end of 2008 will help us to enhance our existing provisions. It will provide the formal basis for many of our already established or piloted initiatives including: the development of a formal identification and referral process; a reflection period; minimum levels of support; and access to temporary residence permits in certain circumstances.

  10.  To help with capacity building and extending expertise on a national level we invested additional resources into the Poppy project during Operation Pentameter 2. As a result, service level agreements are now in place with seventeen third-sector organisations, a number of which are Women's Aid service providers. The UK Action Plan highlights the importance of developing a consistent approach in the quality of services for victims of trafficking. The Government is working with the interpersonal violence specialist Third Sector to develop national guidance and service standards for providers working with victims of domestic violence, trafficking for sexual exploitation, sexual violence and childhood sexual abuse. It is expected that the standards will be ready by the middle of the year.

  11.  As part of the Victims Strategy for Operation Pentameter 2 the Government wrote to all Local Authorities to inform them of the campaign and to highlight the complex needs of trafficking victims. Pentameter 2 provides an opportunity to help develop local expertise and responses to victims. The Senior Investigative Officers toolkit for Pentameter 2 includes advice on: engaging with local stakeholders including specialist services for victims; appropriate victim sensitive behaviour during operations; special measures for victims of crime; procedures for referring victims to support arrangements and contact details for 24 hour advice.

CHILD VICTIMS OF TRAFFICKING

  12.  Some good progress has also been made on action directed at child trafficking. Together with Comic Relief and part funded by the Home Office, the NSPCC launched the Child Trafficking Advice and Information Line (CTAIL) on 7 October 2007. This is proving an invaluable resource to practitioners who suspect a child to have been trafficked. The service is also testing an e-learning package developed by ECPAT( End Child Prostitution and Trafficking) with Home Office funding which is tailored to train practitioners to improve their skills in identifying and taking appropriate action to safeguard trafficked children.

  13.  In December 2007 the Home Office and Department of Children, Schools and Families (DCSF) published multi agency guidance on child trafficking. The guidance is supplementary to the Statutory Guidance "Working Together to Safeguard Children" published in April 2006. The Guidance is called "Working Together to Safeguard Children Who May Have Been Trafficked" and alerts practitioners to the risk indicators of trafficking and actively guides them to taking appropriate safeguarding action.

  14.  The Border and Immigration Agency announced on 31 January 2008 a consultation on the Code of Practice for Keeping Children Safe from Harm. The Code of Practice is a clear statement of the requirement for BIA staff members, the immigration service, and contractors who support immigration functions to be responsive to the needs of all children and ensure they are kept safe from harm. This includes staff members being vigilant for signs that children are at risk of harm and acting on those indicators. This includes awareness of indicators that children may have been trafficked to safeguard children entering the immigration system. On the same day BIA also announced its strategy for delivering improved support to unaccompanied asylum seeking children. The programme—Better Outcomes : The Way Forward includes plans for better identifying and supporting unaccompanied asylum seeking children (UASCs) and includes measures for those who are potential and identified victims of trafficking. We are working to establish contractual arrangements with specialist local authorities to ensure their needs are met.

  15.  Frontline staff at ports are receiving up-dated training to ensure they are fully equipped to identify potential victims of child trafficking. Immigration Officers are receiving one of 3 tiers of training. Tiers 1 and 2 are being implemented across the country and tier 3, designed for staff who will have regular contact with children, will role out in the spring.

  16.  Although progress has been made we are aware of the continuing challenge presented by children who go missing from care who may have been trafficked. If a looked after child, who may have been trafficked, goes missing from their care placement, then the local authority responsible for the child's care and the provider of the care placement must follow the arrangements agreed with the police for managing missing from care incidents.

  17.  The Government takes this issue very seriously. The practice guidance published in December and outlined above is intended to help agencies and their staff safeguard and promote the welfare of children who may have been trafficked. The BIA UASC Reform plans include safe arrangements for trafficked children who claim asylum and later go missing from care. In addition, the draft Code of Practice emphasises the need to identify trafficked children at risk of going missing and the appropriate action to safeguard them.

  18.  We are also looking at additional measures to address children trafficked into domestic servitude from Africa and how to continue to develop our strategy for safeguarding children who are trafficked for criminal exploitation.

Estimating the scale and type of activity

Scale

  19.  The UK is primarily a destination country for human trafficking. The majority of our knowledge regarding the situation in the UK centres on trafficking for the purposes of sexual exploitation and although the extent of the problem is unclear evidence suggests that it is not reducing in scale or reach. Home Office analysis estimates the size of the UK market for sexual exploitation was up to £275 million in 2003. The analysis also estimates that in 2003 there were up to 4,000 women in the UK that had been trafficked for sexual exploitation.

  20.  The problem of making an accurate assessment of the scale of human trafficking within national borders is not one which is unique to the UK. The covert nature of the criminal activity means that it is difficult to accurately size the problem. At the recent UN Global Forum on Trafficking which took place in Vienna from 13-15 February 2008 there was a great deal of discussion on the need to improve knowledge throughout the world in this area through the targeted collection of intelligence, data and research.

  21.  The UK is using the national Pentameter operations to develop the strategic intelligence picture on trafficking across the UK. During the four months of operational activity under Pentameter 1 in 2006 88 potential victims from 23 different countries were recovered, predominantly from Eastern Europe (including EU Member States), the Balkans, China/South-East Asia or Africa. This largely reflects what are considered to be the most common nationalities of victims trafficked for sexual exploitation and also reflects the nationalities of traffickers involved. Operation Pentameter 2 is still ongoing but one of the promising aspects to emerge from the current operation has been the increase in intelligence provided by forces on human trafficking from across the UK. A bespoke database and business process has been developed to support the submission of intelligence which has assisted with the flow of information. This intelligence will assist the UK Human Trafficking Centre in co-ordinating an assessment of the number of victims recovered by police and in producing an up to date strategic picture of the nature and scale of trafficking for sexual exploitation. Strategic and tactical intelligence has also been sought on other forms of trafficking such as trafficking for forced labour.

  22.  Knowledge of the scale and nature of trafficking of minors (aged under 18) for the UK vice trade is limited, and the extent of serious organised criminal involvement is also unclear. Traffickers of children appear to vary between those highly organised and linked to other organised crime, particularly organised immigration crime and vice, and those that are individually opportunistic. More informal trafficking lends itself to domestic servitude, although instances of sexual exploitation have also been uncovered.

  23.  The extent to which the UK is a destination country for adult victims of trafficking for forced labour is not known. It is assessed that the majority of the illegal migrant workers in the UK, including those that have been "debt-bonded" as part of their facilitation costs, accept they will not receive the same treatment as their legal counterparts. Some legal migrant workers also suffer exploitation by unscrupulous employers due to a lack of understanding regarding their rights. However, the extent to which cases occur where the deception, exploitation and curtailment of freedom is sufficient to constitute trafficking is unclear. The following applies mainly to trafficking for sexual exploitation.

Victims

  24.  Whilst intelligence may help us develop common profiles of victims, it is important to recognise that there is no "typical victim" of trafficking and their circumstances will differ. Some women come to the UK with the intention of working in prostitution and may be subsequently trafficked within the UK. Others are duped or coerced by traffickers from the outset. There is no evidence to suggest that there is a specific demand for trafficked victims amongst those who use the off street sex market in the UK ; the demand appears to come from "pimps" who can generate a far higher profit from trafficking victims than from others.

  25.  The factors that make the UK attractive to migrants generally make it easier for traffickers to recruit victims for sexual exploitation; however, it is not clear why some countries are more significant source countries than others. There are certain factors that may make individuals more easily susceptible to becoming a victim of trafficking. For example previous experience of violence (include sexual violence), poverty and unemployment can all influence vulnerability. Victims recovered through operational activity throughout 2006 were between the ages of 14 and 45, with most aged between 18 and 30. This is thought to be representative of women trafficked for sexual exploitation across the board.

Recruitment and Transportation

  26.  Traffickers use a variety of techniques to recruit and control victims, most commonly deception or misrepresentation. To recruit Eastern European victims, traffickers often use advertisements on the Internet or in newspapers for au pairs, bar-staff, nannies and models; or direct recruitment by traffickers posing as friends who present them with job opportunities. Women often act as facilitators, increasing plausibility, including previously trafficked women recruiting new victims, either by returning to source countries or by telephone contact. Additionally, there have been isolated cases of women being abducted and then forced into prostitution.

  27.  The methods used to recruit Chinese and South-East Asian victims are more complex. Commonly, a Chinese trafficking victim will have borrowed money and sought to be smuggled into the UK; this trade is organised by Snakehead groups. Once in the UK, they find work and begin repaying their debt. Some turn to prostitution to do this, whilst others end up in prostitution after responding to offers of other work.

Profits and Costs

  28.  Traffickers make money from their victims either by selling them or by taking a large share of the money they earn as prostitutes. It is not known how the price paid by traffickers for their victims is determined, but it is likely to be largely based on the victim's earning potential. The buyer of a trafficked female can expect to recover his costs quickly. Typically, a trafficker controlling two victims of trafficking is likely to make in the region of £1,000 to £2,000 per week.

The difficulty of finding those who have been trafficked when they are normally too frightened to complain to the authorities; and the role of NGOs in helping to identify and assist victims

Identification

  29.  We recognise that victims of trafficking are often reluctant to come forward to the authorities and that the self-reporting of these crimes is low. There are possibly many reasons for this; some do not self-identify as a "victim of a crime" (this may be particularly pertinent in incidents of trafficking for forced labour where victims, although exploited, might consider their situation as still superior than that offered in their country of origin) whilst others may develop a psychological and emotional dependency on their exploiter (sometimes referred to as the Stockholm syndrome). Significantly traffickers will often use fear, intimidation and deceit as a method of controlling the behaviour of others and some victims are too afraid of the possible repercussions from the exploiters or authorities. For foreign nationals there are additional obstacles like isolation, communication barriers, cultural differences, lack of knowledge of the destination countries including the criminal justice and immigration processes, and possible irregular immigration status.

  30.  The issues relating to the identification of child victims of trafficking are complex and different. As with adults, many victims may come willingly to the UK often with their parents blessing who have been deceived into believing the trafficker is a benevolent agent who will smuggle their child into the UK so that they will enjoy a better life and be able to send money home. The children are groomed by the trafficker on what to say at our ports of entry. Many claim asylum on arrival at the behest of the trafficker and become Unaccompanied Asylum Seeking Children (UASC). It is particularly difficult to identify these children at ports of entry as many, if not most, have experienced no abuse or exploitation at this stage. It is for this reason, on referral to Local Authorities who are tasked to assess and provide for their care needs that some go missing willingly back to the traffickers before a thorough assessment has taken place. Other children and young people are coerced or intimidated by traffickers.

  31.  Emerging intelligence from police operations suggests that despite the provision of support, information and protection some victims remain reluctant to come forward. The Poppy project has recently produced discreet pocket-sized cards with the organisation's number on a tear-off strip, in a range of languages. These can be usefully disseminated to victims in a number of ways, including by the police during operations. This will hopefully encourage initially reluctant victims to contact the project at a later date.

  32.  A comprehensive victim's strategy was developed in advance of Pentameter 2 which produced detailed guidance to police on victim identification, treatment and referral. Special arrangements and instruction for the police were developed for children including a model protocol for Local Safeguarding Children's Boards and their equivalents in Scotland and Northern Ireland. The newly established Child Trafficking Advice and Information Line (CTAIL) was engaged together with ECPAT UK to provide an "advocacy service" to support local authorities children's social care in ensuring appropriate assessment and safeguarding procedures were employed. As the operation progresses one of the areas subject to further analysis is the reason why victims drop out of the criminal justice process or lose contact with the police or authorities. The results of this analysis will be considered by the UKHTC Victim Care Sub-Group who will explore what further measures may be required to help address this issue.

  33.  There are different stages in the identification process for victims of trafficking. The first stage requires front-line responders to be sensitised to the indicators that suggest that an individual may have been trafficked. This will enable them to sensitively make further enquires and facilitate an environment where the individual can feel more confident about disclosure. A multi-agency human trafficking toolkit has been produced to help in the identification of victims. It can be viewed at www.crimereduction.co.uk/toolkits. This will be updated following Operation Pentameter 2 to reflect the latest intelligence picture and cover a wider range of agencies.

  34.  The recently published Working together to safeguard children who may have been trafficked guidance has been widely welcomed by NGOs and statutory agencies. It provides comprehensive advice and methodology as to how to identify trafficked children and what action each agency should take. The guidance includes the contact details of the NSPCC Child Trafficking Advice and Information Line (CTAIL) which provides to those professionals with little experience of working with trafficking cases, expert advice from qualified and experienced child protection social workers.

  35.  The UKHTC, in consultation with stakeholders has developed an aide memoir for police on indicators for trafficking for sexual exploitation and forced labour. This forms part of the comprehensive Senior Investigative Officers (SIO) toolkit developed for Pentameter 2 and has been circulated to all forces. The UKHTC has also developed a comprehensive four-day SIO training programme which covers the issues around trafficking indicators, victim identification and victim care. This has been rolled out in all but three police forces.

  36.  There are a number of opportunities within the Border and Immigration Agency's business where staff could encounter victims prior to leaving their country of origin, on entry to the UK, within the UK, and on leaving the UK. Beyond the UK's borders all new Risk Assessment Officers and Managers based within UKvisas have received training on trafficking from the UKHTC. BIA Airline Liaison Officers in over 30 countries have been working with airlines to raise their awareness of vulnerable children travelling to the UK. On entry to the UK there are 600 border control officers, located at 22 ports of entry into the UK who are trained in identifying children who may be at risk. Teams of social workers have been set up at three of the UK's busiest ports and at two asylum screening units to help strengthen arrangements for keeping children safe and forging closer partnerships with the police.

  37.  Additionally, within the UK all asylum Case Owners receive training in conducting interviews which cover gender sensitive issues and interviewing victims of trauma. We have commissioned Poppy to provide some innovative awareness raising and training on trafficking to some London asylum case owners. Claims from asylum seeking children are only considered by Case Owners who have received special training. Furthermore to help combat child trafficking, an E-Learning training package "Keeping Children Safe" has been developed and is available online for all immigration staff to complete. Within our enforcement offices the UKHTC has provided awareness-raising sessions for 850 enforcement staff.

  38.  NGOs can play an important role in helping to identify and engage with potential victims. In 2006 the Government agreed to fund the extension of the Poppy project to include an outreach service, which went live in January 2007. Some of the outreach clients were initially reluctant to come forward but with the help of an independent outreach worker felt able to disclose. The outreach service is continuing to raise awareness amongst other agencies, including NGOs working with vulnerable women to help with early identification. In relation to child victims and in addition to the role fulfilled by NSPCC in managing CTAIL, ECPAT is supporting the service by providing training and development opportunities for organisations and teams at a local level.

  39.  We recognise that the general public have a role to play in identifying victims; encouraging them to seek support and protection or to report suspicious incidents to the police. Between March 2003 and December 2007 the Poppy project received 50 referrals from third-party individuals and 16 from "punters". The various awareness campaigns, including the Government funded Poppy project poster campaign with Transport for London and the UKHTC Blue Blindfold campaign are aimed at sensitising the wider public to trafficking.

  40.  The second stage in the victim identification procedure involves a more formal process. This is necessary to ensure the protection of real victims by having appropriate safeguards in place to try and prevent against abuse and possible infiltration by organised criminal networks. The Council of Europe Convention describes this process as the "competent authority" assessing whether there are "reasonable grounds" to believe that an individual has been trafficked. Pentameter 2 is being used to pilot this formal process.

The treatment of those who have been trafficked but have no legal right to remain in the UK, including the requirements imposed by the Council of Europe Convention on Combating Human trafficking

  41.  Some victims of trafficking are subject to immigration control and may enter the UK on genuine documents in the belief that legitimate work or study opportunities await them. Others enter the country illegally. The Council of Europe Convention obligates signatories to provide a minimum 30 day reflection period to those who are illegally present and who the competent authority identify as having reasonable grounds to believe are victims. This period is to ensure the individual can recover and escape the influence of traffickers and can take an informed decision on cooperating with the law-enforcement authorities in an investigation. During this period the individual will not be removed from the UK.

  42.  It is accepted that immediate return of a victim to their country of origin is sometimes unsatisfactory both for the victim and for efforts in investigating and securing convictions against the traffickers. The Convention requires signatories to consider two options for granting residence permits: on the basis either that the victim's stay is necessary owing to their personal situation and/or that it is necessary for the purpose of their cooperation with the competent authorities in an investigation or with criminal proceedings. The Convention recommends a minimum period of 6 months.

  43.  Work on setting up provisions for both reflection periods and residence permits is on-going under plans to implement the Convention. A minimum 30 day reflection period has been provided for all illegally present identified victims under Pentameter 2 and has been in place for those accepted on the Poppy scheme for some time. A reflection period will also be provided under the trafficking for forced labour pilot undertaken this spring. A decision on the length of the reflection period will be taken after Pentameter 2. It is expected that necessary changes to immigration rules and procedures on both reflection periods and residence permits will be introduced before the summer recess.

  44.  It is accepted that these measures are necessary to provide some foundation of security and support to victims. We are clear that the response to trafficking should be primarily about protecting victims of crime and bringing those who exploit them to justice. But many victims of trafficking are foreign nationals. For those that are, giving some security to their immigration status is central to our aim but our policy on protecting trafficking victims must be consistent with wider immigration policies too.

  45.  We acknowledge that there may be situations when it is more appropriate for victims to remain in the United Kingdom. In the longer term, under implementation plans for the Convention we will introduce temporary residence permits for victims eligible on certain grounds. In the interim the Poppy project includes a resettlement service to help individuals in their long-term recovery. It is also open to victims to apply for protection through normal immigration routes and asylum case owners in the New Asylum model have received specific awareness raising training which will be rolled out across the country. There is also now greater engagement between asylum caseworkers and Non-Governmental Organisations (NGOs) like the Poppy project to ensure that the applicant is supported throughout the claim.

  46.  There is no reason in principle why a victim of trafficking should not qualify for asylum. However it should be noted that the fact that a person has been trafficked is not in itself a ground for refugee status. Some individuals who are at risk of being trafficked may be able to establish a reason (such as membership of a particular social group) under the 1951 UN Refugee Convention and have valid claims to refugee status. Alternatively, trafficking may well constitute inhuman or degrading treatment, in which case a person at risk will be granted Humanitarian Protection (HP) (for 5 years with the possibility of settlement at the end of the period).

  47.  For children or young people whose asylum and/or humanitarian protection claim is unsuccessful, Discretionary Leave (DL) is granted until they are 17 and a half years of age or for three years whichever is the shorter period.

  48.  The Convention does not place an obligation on signature states to allow all those who are identified as victims of trafficking to remain permanently in the particular member state and this is consistent with UK immigration policy. We are aware that most victims of trafficking want to return to their home countries. We recognise the importance of supporting victims of trafficking who wish to return home. The Government currently works in partnership with the International Organisation for Migration (IOM) to support irregular migrants in their voluntary return. The IOM Assisted Voluntary Returns Programme for Irregular Migrants (AVRIM) is in many ways targeted at vulnerable groups such as victims of trafficking. We are utilising opportunities like Operation Pentameter and awareness raising sessions for front-line staff to promote the use of the programme, so that victims can utilise the opportunities that are available to them.

Co-operation within the EU (including Europol); and control of the EU's external frontiers

  49.  The policy framework for action at an EU level to combat human trafficking is set out in the EU Plan on best practices, standards and mechanisms to prevent and combat trafficking in persons which was adopted in December 2005 during the UK presidency of the EU. Responsibility is placed on EU institutions, the Commission, member states and rotating presidencies of the EU to take forward action. Successive EU presidencies have prioritised different aspects of the Plan. The EU Anti-Trafficking Day held in Brussels on the 18 October 2007 focused on two recent initiatives by the Commission—the production of "recommendations" for member states on national mechanisms for victim identification and assistance and on indicators to monitor and evaluate national anti-trafficking policies.

  50.  The G6 has also been a driver for the development of more dynamic and concrete operational co-ordination on human trafficking. The UK is currently leading (with Poland) an initiative on human trafficking which came out of an agreement amongst G6 interior ministers to undertake more practical co-operation. The project is running from July 2007—July 2008 and participants include the UK, Poland, Italy, the Netherlands and Ireland along with the support of Europol, Interpol and Eurojust.

  51.  The project has a number of strategic aims (including enhancing international co-operation in human trafficking as well as the knowledge and specialist capability of participating states). One of the work-strands included in the project is consideration of how tax and revenue powers can be used more effectively to disrupt and target organised criminal gangs engaged in trafficking. The Irish are also leading a work-strand looking at the merits of joint awareness raising initiatives whilst the Netherlands are leading on how tools for front line responders can assist in identifying trafficking for forced labour situations more effectively. Collaboration across borders with partners in this project is also yielding operational results. SOCA responded to a request for mutual legal assistance from the Netherlands in the joint investigation of an individual engaged in trafficking Nigerian females to the EU and the UK for exploitation in the sex industry. This was enforced in late October 2007 under the auspices of this project and led by the Dutch. The main subject was arrested and extradited to the Netherlands, where he is now in custody awaiting trial. The Irish were also involved in assisting with the case.

  52.  The early indications from the G6 initative suggest that multilateral projects on a sub-regional level such as this are an effective mechanism for achieving practical operational co-ordination.

Council of Europe and the Organisation for Security and Co-operation in Europe (OSCE)

  53.  Organisations like the Council of Europe and the Organisation for Security and Co-operation in Europe (OSCE) also work at a political level with their member states to develop the EU response to human trafficking. The UK has worked closely with the Council of Europe following UK signature of the Convention. On the 10-11 December 2007 we jointly hosted with them a successful regional seminar on trafficking in human beings in London. The UK invited eight member states to share expertise and best practice on issues such as victim identification, reflection and residence permits and support for victims of forced labour. A great deal of useful comparative material was obtained which we can draw upon as we move forward with ratification this year.

  54.  The OSCE also assists member states, including the UK in implementing the Ministerial commitments and recommendations contained in the OSCE Action Plan to Combat Trafficking in Human Beings, including the establishment of an effective National Referral Mechanism. In practical terms, the OSCE concentrates on enhancing awareness and understanding of human trafficking across the OSCE region; policy, planning and advocacy especially in the area of emerging trends and effective approaches to combating human trafficking; and direct assistance to member states in practical and technical areas, at their request.

  55.  The OSCE are currently conducting an assessment of the UK's National Referral Mechanism. This forms part of a wider study into how a number of destination countries in Western Europe approach identification and referral of trafficked persons, protect their rights and ensure their access to justice. The original timetable for publication of the assessment has been delayed to take account of the recent pace of developments in the UK and the OSCE are due to visit the UK this summer to continue their analysis.

  56.  At an operational level, co-operation on human trafficking within the EU is facilitated by a number of EU institutions such as Europol, Eurojust and Frontex.

Europol

  57.  Europol provides an intelligence structure for EU-wide analysis, as well as analytical support and coordination for joint operations between EU Member States. The UK Liaison Bureau at Europol is the largest of any member state and consists of seven liaison officers and two support staff drawn from SOCA as well as other agencies. These liaison officers link both to Europol to its analytical and support activities but mainly with their bi-lateral colleagues from the other countries represented at Europol.

  58.  Europol has a number of tools which are of assistance in developing cross border investigations into human trafficking. The Europol Information System is the main area of growth at present. It is a relatively new system which allows member states to insert current intelligence "objects" eg names, addresses, vehicles, firearms etc into the system to allow cross checking/cross matching against other law enforcement activities /interest.

  59.  In addition, Europol's Analytical Work Files (AWFs) provide another assistance mechanism. Member states contribute intelligence to Europol who analyse the whole and provide added value in terms of intelligence products or operational opportunities. Europol currently has two AWFs that deal specifically with people smuggling and human trafficking. AWF Checkpoint deals with organised people smuggling and AWF Phoenix on human trafficking for both labour and sexual exploitation. The UK is a member of both work files and is working with member states on specific operations and projects.

  60.  One example of support given to the UK was around Operation Greensea, an investigation into Chinese and Turkish smuggling networks that culminated in the arrest of 23 people in France and the UK in January 2008. Intelligence from this operation was fed into AWF Checkpoint with Europol providing analytical support and co-ordination with three other Member States.

Eurojust

  61.  Eurojust is the EU's judicial co-operation unit, created in 2002, tasked with promoting and facilitating co-operation in the investigation of serious cross-border crime, particularly organised crime. It is made up of senior prosecutors and judges from all 27 member states. Each of these representatives (known as National Members) is appointed by his/her own country. Eurojust exists to stimulate and improve judicial cooperation between the member states (and third countries) in cases of serious, transnational crime, particularly when it is organised. In the UK context "judicial cooperation" means cooperation by the investigating and prosecuting authorities. In continental Europe, it often means cooperation by the investigating authorities and the investigating magistrates or judges who direct them.

  62.  Eurojust's function is to plan and oversee coordinated actions across the member states and to ensure cooperation in supporting transnational enforcement and prosecution actions. In the context of trafficking in human beings this provides the means by which entire pan-European trafficking networks can be taken out rather than the partial disruption of these networks as a domestic response in those countries for whom human trafficking is a priority. In general, though not exclusively, Eurojust aims to be involved in cases requiring multilateral cooperation rather than those requiring purely bilateral cooperation.

  63.  Following on from these multilateral investigations Eurojust assists in ensuring that the best possible evidence is available to support ensuing prosecutions. Also based in The Hague, Europol is a key partner for Eurojust. Europol's receipt, analysis and dissemination of intelligence allows the prosecuting and investigating authorities to build a clear picture of criminal activity in operational cases and in real time. This can be invaluable when planning the coordinated actions at a judicial level. Eurojust were also involved in the successful Operation Greensea, mentioned above, working alongside Europol.

  64.  The Government is a firm believer in the important role that Eurojust plays in the increasingly complex, cross-border nature of serious and organised crime, which can be fought more effectively through improved judicial co-operation and coordination of cases across the EU. Eurojust is helping to break down the barriers to effective judicial co-operation by promoting greater understanding and trust between the different legal systems across Member States and facilitating co-operation between jurisdictions on specific cases. One example is "Operation Pachtou", where Eurojust co-ordination between UK, Greek, French, Italian and Turkish authorities helped dismantle a criminal network involved in human trafficking, resulting in 82 arrests across Europe on 14 December 2006.

Frontex

  65.  Frontex's remit focuses on improving operational cooperation between EU member states and facilitating integrated border management at the EU's external borders, aimed at identifying and preventing threats including illegal migration flows to the EU.

  66.  The UK participated in a number of Frontex joint operations/ activities in the course of 2007, which included operations in the Mediterranean as well as on the Eastern land borders. The practical co-operation co-ordinated by Frontex brings additional security in terms of stronger borders, combating illegal immigration, and immigration crime such as human trafficking.

  67.  In addition, e-Borders is a key component of the Government's border transformation programme which aims to deliver a modernised border control that is fundamentally more effective, efficient and secure to meet the future operating needs of the border agencies. The main purpose of the e-Borders programme is to collect and analyse passenger, service and crew data provided by carriers (air, sea and rail), in respect of all journeys to and from the United Kingdom in advance of their travel, supporting an intelligence-led approach to operating border controls. These data will be checked against watch-lists, analysed, risk assessed and shared between UK border agencies.

  68.  Whilst improving border security more generally, the provision of a modern border control will assist in the fight against organised crime. Such a flow of information which informs on an individual's movement to the UK and any claim to immigration status whilst within the UK will assist in identifying deception which is a key tool used by traffickers. This information will allow us to pick up on suspicious movement of both victim and trafficker and contribute to combating and preventing this crime.

  69.  To help meet the increased challenge from organised crime and terrorism the Prime Minister announced in November 2007 the creation of the United Kingdom Border Agency which will bring together into a single organisation the work of UKvisas, the Border and Immigration Agency and the border work of HM Revenue & Customs. The UK Border Agency will give officers the power to detain people not just on suspicion of immigration offences or for customs crime but also for other criminal activity. Powers are also being given to airline liaison officers to cancel visas where justified.

Relations with transit and source countries, and the role of Interpol and the UN Office on Drugs and Crime

  70.  The UK works with transit and source countries in a number of different ways. At a diplomatic level work is undertaken through the overseas network of the Foreign and Commonwealth Office (FCO). Investment in trafficking related projects is made via the development programme of the Department for International Development. Law enforcement co-operation is facilitated by the network of SOCA overseas liaison officers and co-ordinated through the programmes of activity that form the UK Serious Organised Crime Control Strategy. Border and related issues are also addressed through BIA's airline liaison officers and projects. The UK also works through membership of international organisations such as the UN Office of Drugs and Crime and Interpol as well as through partner organisations such as the International Labour Organisation. Chapter 2 of the UK Action Plan on tackling human trafficking sets out in detail the range of work that is currently undertaken.

  71.  The FCO's main role in tackling organised immigration crime networks is focussed on co-ordination and liaison with law enforcement and implementation agencies, as well as with overseas missions on awareness raising and lobbying issues. The FCO also allocates money from the Global Opportunities Fund (GOF) through the Drugs and Crime Programme (DCP) to build capacity of law enforcement agencies within countries globally. This contribution has been welcomed by those governments involved, and has helped with broader crosscutting cooperation at operational level. The FCO also uses its overseas network to raise awareness of the dangers of trafficking and to lobby host governments in order to help partners across government at all levels. Recently, the FCO has encouraged its overseas Missions to publicise UK prosecutions and convictions of traffickers' via media outlets in source and transit countries.

Serious Organised Crime Agency (SOCA)

  72.  Internationally, SOCA manages a global network of approximately 140 liaison officers based in some 40 different countries, who work against all SOCA priorities including organised immigration crime. SOCA is also engaged in projects managed by other government departments or with EU partners.

  73.  SOCA co-ordinates multi agency programmes of activity directed at organised immigration crime, as part of the UK Serious Organised Crime Control Strategy. One of which is Organized Immigration Crime: Source and Transit Countries (Nexus Points). The objectives of the programme include the development of knowledge and understanding of organised immigration crime in the key source and transit countries which impact on the UK as well as the development of bilateral and multilateral operational strategies and plans with agencies in source and transit countries and with EU partners. The ultimate goal is to reduce the harm caused by organised immigration crime into the UK and deter and prevent organised immigration crime in major source and transit countries.

  74.  One example of work in this area is the SOCA coordinated response to maritime organised immigration crime and the movement of illegal immigrants from source countries into Western Europe. Since the project inception in October 2006, SOCA—together with its UK based and international partners, have made 9 maritime interdictions resulting in the detention of 765 illegal immigrants and 17 arrests.

Border and Immigration Agency

  75.  The UK has a network of 34 Airline Liaison Officers (ALOs) in 32 locations overseas which have been identified as major source or transit locations for inadequately documented passengers arriving in the UK. Their role is to offer advice and expertise to airlines with a view to preventing or disrupting the carriage of such passengers. In the normal course of their liaison activities with airlines ALOs seek to raise awareness of trafficking. They deliver a comprehensive programme of formal training for carriers in UK passport and visa requirements and forgery awareness, and incorporate within this a session which includes the drivers behind the trafficking of children and adults, and means of identifying vulnerable passengers and their traffickers by their demeanour and the travel documents they may present. In Southern Africa ALOs are working with the IOM on a regional project aimed at developing the capacity of both border authorities and the carrier community to recognise trafficking and to take action to address it.

  76.  In 2007-2008, the Risk Assessment Unit (RAU) network of UKvisas expanded from 27 to 35 units. All new Risk Assessment Officers and Risk Assessment Managers have received training in trafficking from the UKHTC. Training material on trafficking issues has been developed by the Risk Assessment Operations Centre (RAOC) in London. The RAOC will ensure this material is shared across the network and used to educate staff in visa sections globally. The first presentations took place in Moscow and St Petersburg in October 2007, Nairobi in November and Hong Kong in January 2008. RAUs overseas are developing post specific awareness material to complement the overarching presentation. The RAOC and the network continue to work closely with stakeholders such as UKHTC, SOC A and the Child Exploitation and Online Protection Centre (CEOP) in an effort to tackle human trafficking and feed in to their intelligence requirements as appropriate.

International Organisations—Interpol

  77.  Interpol's I-24/7 global police communications system connects law enforcement officials in all of its 186 member countries, providing them with the means to share crucial information on criminals and criminal activities 24 hours a day, seven days a week. Using I-24/7, National Central Bureaus (NCBs) can search and cross-check data in a matter of seconds, with direct access to databases of information on suspects, wanted persons, fingerprints, DNA profiles, lost or stolen travel documents and other data which can be useful for trafficking in human beings investigations. One of Interpol's most important functions is to help police in member countries share critical crime-related information using the organization's system of international notices.

  78.  A specialist working group addressing the issue of trafficking in women for sexual exploitation was established by Interpol in 2001. This has now been extended to include all forms of trafficking. Member countries include the UK and the UKHTC sit on the Steering Committee which meets annually and focuses on a variety of issues including: the practicalities of investigation, sharing of new techniques and best practices and the promotion of the Human Trafficking Message for information reporting and sharing. Interpol has also developed a best practice guide for investigators which is currently being revised.

  79.  Interpol also does analytical work on the information received from member countries on trends in human trafficking. Red Routes is an analytical project that has been running since 2004 focusing on Eastern European women being trafficked for sexual exploitation. A team specialising in crimes against children also operates within Interpol's human trafficking unit. The team focuses on the sexual exploitation of children, often linked with trafficking, and serves as a hub for cooperation with and among member states. The team works in cooperation with the UK's CEOP on matters of victim identification.

United Nations Office of Drugs and Crime

  80.  The UK is active in co-operation with the UN Office of Drugs and Crime (UNODC), with nearly US$ 5 million dispersed in 2006-07. Our contribution, in addition to our standard UN share of the regular budget (5.3%), was about 9% of the UNODC's support and programme budget. The UK has lead responsibility internationally for counter-narcotics efforts in Afghanistan; therefore, much of the work we currently do with the UNODC is focussed on co-operation in this area. The UNODC's work on human trafficking is mostly focused on ensuring implementation and ratification of the UN Palermo Protocol to prevent, suppress and punish trafficking in persons which the UK has fully implemented.

  81.  The UK has supported the UN's recent Global Initiative to Fight Human Trafficking from the outset with the official launch taking place in London on 26 March 2007. A high level UK delegation also attended the Forum in Vienna from the 13-15 February 2008 designed to bring together representatives from member states, the United Nations, international organisations, the business community, academia and non-governmental organisations with the objective of raising awareness and facilitating the co-operation between stakeholders.

Effectiveness of the co-ordination between public authorities in the UK (Home Office, FCO, police forces, Serious Organised Crime Agency, Border and Immigration Agency, social services)

  82.  The Inter-Departmental Ministerial Group on Human Trafficking was established in 2005 to co-ordinate and direct government policy on human trafficking. It has recently been expanded to include representation from the devolved administrations. This Group, which is currently chaired by Vernon Coaker, includes the Solicitor General, the Deputy Minister for Women, alongside ministers from the Foreign and Commonwealth Office, the Department for International Development, Department of Health, Department for Children, Schools and Families, the Ministry of Justice, the Department for Work and Pensions, Department for Business, Enterprise and Regulatory Reform, Department of Communities and Local Government, Scottish Executive and the Northern Ireland Office.

  83.  This Group has responsibility for monitoring both the implementation of the UK Action Plan on tackling human trafficking and the Council of Europe Convention on Action against Trafficking in Human Beings. It is supported by the Non-Governmental Organisations (NGO) Ministerial Advisory Group which meets regularly and brings together a range of UK stakeholders with expertise in human trafficking.

  84.  Combating human trafficking requires a complex multi-faceted response. The UK has a number of multi-agency forums which attempt to bring together different organisations to work effectively towards common goals whilst minimising unnecessary duplication of effort.

  85.  Activity on human trafficking by UK law enforcement has been characterised in recent years by partnership working and multi-agency collaboration and co-operation. The establishment of the UK Human Trafficking Centre in October 2006 has been central to this strategy as it embodies a multi-agency approach. It brings together a number of organisations under police leadership and demonstrates through the auspices of its sub-groups that civil society and voluntary organisations have a role to play.

  86.  The UKHTC provides a central point for the development of expertise and the strategic and operational coordination in respect of all forms of trafficking of human beings. The centre has embedded staff and officers from BIA, CPS, Police Service, SOCA and Social Services. The UKHTC offers law enforcement a 24/7 support line for tactical, immigration, victim and legal advice and has sought to raise awareness amongst police forces about human trafficking in a number of ways, including through the production of an awareness raising DVD to be distributed to front line officers. It has also developed good working relationships with forces and designed and delivered specialist training courses.

  87.  The operational activity of the UKHTC is focused around five core work groups in the areas of victim care, prevention, research, learning and development and operations and intelligence. It has already played a key role in delivering many of the commitments in the UK Action Plan. The model of working presented by the UKHTC is already being presented in international forums as an example of best practice. Although only in existence a short time it has established a good reputation both nationally and internationally.

  88.  The work of the UKHTC has been complemented by that undertaken by SOCA which co-ordinates the overall assessment of the threats posed to the UK by serious organised criminals, producing the UK Threat Assessment (UKTA). In response to the UKTA, the UK Serious Organised Crime Control Strategy is developed which sets out how UK agencies, working with overseas partners, plan to tackle serious organised crime affecting the UK.

  89.  The Control Strategy consists of a series of linked inter-agency programmes of activity, which are aligned to the threats set out in the UKTA. The Organised Immigration Crime programmes are "Organised Immigration Crime Source and Transit Countries (Nexus Points)" and "Organised Immigration Crime into and in the UK, including exploitation of migrants in the UK". Together, the UKTA and Control Strategy deliver a shared understanding of the problem—in this case human trafficking—and a framework for co-ordinated and concerted action by the relevant UK and overseas agencies. SOCA works closely with the UKHTC and domestic partners such as ACPO, ACPOS, HMRC, BIA, CEOP, Identify and Passport Service, UK Visas, Gangmasters Licensing Authority, as well as international partners within the EU and beyond.

  90.  Like the other agencies involved in the UK Control Strategy, SOCA takes a lead or supporting role in particular pieces of activity within the programmes that underpin the Control Strategy. Since its inception on 1 April 2006, SOCA has undertaken 121 pieces of activity against Organised Immigration Crime, of which 42 have focused primarily on human trafficking.[181] An example includes a response by the Metropolitan Police Service, supported by SOCA, against the activities of a Turkish immigration network based throughout Europe. The operation resulted in the arrest of thirteen people on suspicion of facilitating illegal immigration into the UK in January 2008. This operation dismantled two organised criminal networks, believed to be two of the largest human trafficking rings in London, and demonstrated interesting linkage between both EU and Chinese nationality traffickers and the convergence of upstream and near continent networks. SOCA also seeks to use non-traditional interventions against serious and organised criminals to disrupt their criminal activity. For example, SOCA worked closely with BIA to impose Exclusion orders on a key trafficker and two associates, who are all now formally excluded from the UK. Exclusion orders against four further associates are being pursued.

  91.  In addition to ongoing co-ordination under the SOCA work programmes and UKHTC sub-groups the model of partnership working has also been further developed by nationwide operations on human trafficking such as Operation Pentameter 1 and 2. The inclusion in the ACPO led steering and planning group for the operations of non governmental organisations alongside law enforcement, the CPS, BIA as well as other partners underlines the innovative and comprehensive approach which is being adopted for operations such as these. One example of partnership working under Pentameter 2 has been the tasking of CEOP by the UKHTC Victim Care Group to develop the victim care strategy for children for the operation. The strategy is particularly innovative, providing Local Safeguarding Children's Boards with a model protocol for and guidance on interviewing child victims. It also has an advocacy service to assist the police and children's services unfamiliar with safeguarding child trafficking victims linked to the 24/7 new NSPCC advice and information line. The advocacy service also ensures that the cases are tracked and the children's individual situations are recorded.

  92.  The Border and Immigration Agency's approach to combating trafficking provides a clear example of collaborative working and the establishment of strategic partnerships. In addition to the staff seconded to the UKHTC, BIA has also seconded staff to CEOP. Social workers have been set up at three of the busiest ports and at two asylum screening units (ASU) to help strengthen arrangements for keeping children safe. The Paladin Team is part of the Metropolitan Police Child Abuse Command. It is a joint BIA and police team working together to identify victims/and or potential victims of trafficking. The Paladin Team has a permanent presence at the Asylum Screening Unit in Croydon and also at Heathrow Airport. At these locations Paladin works closely with Croydon and Hillingdon Social Services. It also participates in the Local Safeguarding Children's Board Trafficking Sub Group chaired by Hillingdon Social Services. In cases where children/young people present themselves either as unaccompanied or accompanied but with unsuitable guardians, the Paladin team work with the dedicated social worker teams at Heathrow and Croydon to ensure suitable care and accommodation arrangements are put in place.

  93.  The preparation of the Government's practice guidance—Working Together to safeguard children who may have been Trafficked—involved close collaboration between DCSF and the Home Office. We consulted widely with practitioners from across public bodies and children's charities to improve the practical usefulness of the guidance. The guidance stresses the key role of Local Safeguarding Children Boards (Child Protection Committees in Scotland) to address and record the needs of child victims of trafficking. This will ensure greater collaboration between local authority Children's Services, Police, BIA, Health Services, schools and children's charities in ensuring that known trafficked children are safeguarded.

  94.  We know that young UK-born girls are being groomed and trafficked within the UK for sexual exploitation by men who are British Citizens. We are working to tackle this criminal activity in a number of ways. The UKHTC's Operation Glover has secured the conviction of a trafficking gang, rescuing 33 female victims aged between 12-15 years who are believed to have been trafficked internally. This operation demonstrated the effectiveness of multi agency work and the effective use of intelligence to secure convictions. The UKHTC multi agency internal trafficking working group aims to raise awareness amongst police, professional, statutory agencies and NGOs of this problem. Police forces are working collaboratively with voluntary and community groups and adding to their intelligence on internal trafficking, to improve case building and evidence gathering in such cases.

  95.  Inter-agency working is integral to the UK's strategy to combat trafficking and providing victims with a coherent high quality service. A Memorandum of Understanding (MOU) that sets out clearly the various agencies roles and responsibilities in respect of victims has been agreed between ACPO, the UKHTC, CPS and Eaves Housing for Women. Similar MoU's have now been developed with other NGOs. This partnership approach is also evident on the ground, for example Poppy project outreach workers have been seconded to the UKHTC to help with identification and support issues during Pentameter 2.

  96.  The UK has developed a strong institutional and strategic framework on human trafficking in recent years. Implementation of that strategy on the ground will be a key objective going forward. The challenge will be how to harness all the goodwill, passion and endeavour to work with partners in the public, private and voluntary sector to maximum effectiveness.

26 February 2008








180   as at 8 February 2008. Back

181   Activity focused primarily on other sectoral threats may also have had elements relevant to human trafficking. Back


 
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