Discussion document

The discussion document covers two areas in relation to people traffickers: prevention and prosecution. With regard to prevention, the document summarises the initiatives New Zealand has already undertaken to prevent people trafficking and lists possible initiatives for strengthening these measures. These initiatives are set out under the broad categories of training and enforcement, research and intelligence-gathering, public awareness, social and economic initiatives and information exchange. Likewise, the document sets out the provisions already in place for the prosecution of people traffickers and suggests possible improvements that could be made.

Submitters were asked what other prevention and prosecution measures could be included in a plan of action, and how the private sector should be involved.

Prevention

Raising awareness of trafficking

Many submitters advocate public awareness campaigns to educate the wider community about people trafficking. They see these as a tool for helping to identify possible cases of people trafficking by providing information about the signs that someone may be a victim, what people can do to help and which agencies they should contact. As discussed below, some submitters consider that education campaigns can also be used to reduce the demand for people trafficking by creating a greater awareness among consumers that certain goods or services may have been produced by trafficked labour. One submitter suggests that awareness campaigns should alert the public to the possibility of domestic trafficking, as well as cross-border people trafficking.

Raising awareness of people trafficking in the community was also a recurring theme of the three consultation meetings. Attendees noted the lack of accurate information about people trafficking in the public arena and suggested that if more people were aware of the issues, people trafficking activity would be more likely to be recognised as such.

One submitter suggests that public education campaigns be supported by a dedicated website that brings together all information about people trafficking, in New Zealand and internationally, in one place. They envisage that the website would be similar to that operated by Child, Youth and Family in relation to child abuse.

As noted above, one submitter comments on the ineffectiveness of awareness-raising initiatives in other countries and emphasises the need to ensure that prevention programmes are based on accurate information, rather than assumptions.

Many resources have been frittered on ineffective awareness raising. Reasons for this include: messages that provide incorrect information (see below); messages which provide no useful information (e.g. Stop Trafficking - together we can do it'); an assumption that people are trafficked because they lack awareness; an assumption, against strong contrary evidence from many fields, that raised awareness will lead to changes in behaviour; and lack of evaluation of awareness raising activities. [Individual Submitter B]

The New Zealand Nurses Organisation cautions that public awareness campaigns need to be careful not to stigmatise migrants and suggests they be planned in conjunction with employers, unions and community and migrant groups.

... public awareness campaigns which highlight extreme forms of abuse can stigmatise migrants per se. There is a particular danger that innocent migrants may be implicated or assumed complicit in illegal activities arousing inappropriate public concern. Such has already been the case with publicity surrounding the United States Report on Human Trafficking earlier this year when, with no corroborating evidence or clarity about which country was being referred to, migrant nurses were reported as at risk of high levels of debt that could lead to their working in the sex industry (Dominion Post). It is unacceptable and counter-productive for migrants to be stigmatised in this way. [New Zealand Nurses Organisation]

In addition to general awareness raising campaigns in New Zealand, submitters suggest:

• targeted campaigns aimed at specific groups that are likely to be in a position to detect trafficking activity, including migrant communities, social service providers, health services, law enforcement agencies (including police liaison officers offshore), local authorities, unions and employer groups
• undertaking education campaigns about the dangers of trafficking in identified source countries
• providing information about working conditions in New Zealand so possible victims of people trafficking overseas are less likely to be "duped"
• incorporating information on trafficking in campaigns targeted at preventing violence against women.

Training

As well as education campaigns, submitters see a need to provide training for groups and agencies that are likely to have some involvement with victims of people trafficking. This includes agencies that have a preventive role in identifying possible people trafficking and agencies that have a protective role in supporting and assisting victims.

Effective and ongoing training for all who may be involved in the identification, rescue and rehabilitation of trafficking survivors is essential. [National Council of Women of New Zealand]

The targeted training and information will work best when it reaches those groups most likely to come in contact with trafficked persons. Thus, the success of the plan depends on identifying all those groups and communicating effectively with them. [Andre Anderson]

Specific suggestions include:

• training community groups, unions and employers to take on a preventative role
• training teachers and incorporating awareness in school programmes
• training healthcare providers and social service organisations to identify victims and to provide services
• training police and customs staff to be aware of trafficking, follow up suspicious behaviour and ask the right questions
• training all frontline law enforcement staff and possibly establishing a specialist unit within the New Zealand Police
• training immigration and legal officials, including judges, to identify and protect the human rights of trafficked persons.

A number of submitters suggest making use of the expertise and experience of specialists in other countries when developing and delivering training material.

The need for training was also raised at the consultation meetings, with victim identification seen as a key aspect of training.

Reaching victims of people trafficking

Some submitters consider ways of targeting messages to victims of people trafficking and encouraging them to seek assistance. Suggestions are as follows:

• establishing an anonymous 'hotline' to enable victims to phone for support and information - possibly expanding on existing services
• providing information packs to everyone entering New Zealand that includes the hotline number, information on the activities that violate human rights and/or the contact details for agencies that can assist - with information provided in different languages
• setting up a website that provides a list of agencies that can help
• placing mandatory notices in brothels to inform workers of their rights and who they can approach for assistance
• placing advertisements in local newspapers, foreign language papers and free literature
• using the media to communicate that the rights of victims will be protected if they come forward.

Some submitters comment that hotlines have been used successfully in other countries, including Italy and the United States. They note that they provide a means for the public and other organisations to seek information or report suspected people trafficking as well as an avenue for victims to come forward.

A number of submitters suggest developing outreach programmes, particularly in the sex industry, to highlight the availability of hotlines, safe shelters and other support. They point to the Human Rights Commission Pink Sticker campaign as an example of the sort of initiatives that "need to be an ongoing dynamic within an overall strategy for action."^[5] One submitter also suggests visiting new migrants four weeks after their arrival to ensure that they are "doing what they say they would be doing and to ensure that they are safe and coping in their new country".^[6]

Addressing demand factors

Some submitters comment that people trafficking is driven by consumer demand for cheap goods, labour and sexual services, and view initiatives designed to reduce demand as a critical part of a plan of action.

Globally there is still a common failure on the part of legislators, law enforcers, agencies and the public to grasp the fact that people traffickers are merely intermediaries who traffic only goods for which there is a market demand. In sex trafficking, for example, it is male demand for prostitutes that is the driving force behind sex trafficking. Without demand there would be no supply. [Stop Demand Foundation]

World Vision New Zealand advocates reducing demand for goods and services produced by trafficked or exploited labour by promoting corporate social responsibility and ethical buying. It suggests the following measures:

• "initiatives to identify fields of business and industry that are likely to create demand for or use products, materials or services produced by trafficked or exploitative labour;
• awareness raising and education about the issue of people trafficking for relevant fields of business and industry and their consumers and clients;
• partnering with the business sector for their cooperation and input on appropriate measures to regulate corporate behaviour and develop industry codes of conduct; and
• appointing a Government Corporate Social Responsibility Watchdog with an emphasis on people trafficking and exploitation to interface between the Government and the business sector, and to implement and monitor corporate social responsibility and ethical buying strategies."

A number of submitters focus on the sex industry and advocate awareness campaigns directed at the patrons of prostitution.

NZ should consider a campaign to raise awareness of the sex industry (ie. massage parlours, social escort agencies, etc.) Unless the patrons of these agencies understand that many women at these agencies are potentially victims of trafficking schemes, and the deeper issues surrounding that of trafficking, the problem cannot be adequately addressed. [Shakti Community Council]

There could also be greater emphasis on reaching out to potential clients of the domestic sex industry, either by appealing to their responsibility to report on suspicious cases or like Germany, which recently introduced severe punishments for persons who engage with prostitutes who are obviously victims of trafficking. [IGC]

The New Zealand Prostitutes Collective, however, expresses concern about possible targeting of sex worker clients and the potential for such measures to reduce demand in the general adult sex industry.

Others suggestions include:

• educating the community about the links between pornography, including child pornography and people trafficking,
• encouraging media providers to promote the responsible use of media (including the internet) to eliminate exploitation of women and children.

Submitters also note the role of sanctions in reducing demand for services related to people trafficking. As indicated above, the IGC mentions the approach Germany has taken by introducing penalties for those who use prostitutes who are obviously victims of people trafficking. Another submitter suggests consideration be given to extraterritorial application of anti-trafficking legislation to New Zealanders aboard, and to sanctions or other measures against New Zealand based businesses, or suppliers to the New Zealand domestic market, which are "found to engage in trafficking-like exploitation overseas (forced labour and the like)".^[7] Sanctions and penalties are further discussed below in relation to prosecution initiatives.

Enforcement of labour standards

A number of submitters consider that better enforcement of labour standards in New Zealand would help to prevent exploitation of migrants and reduce incentives for people trafficking. Submitters consider that activities should be targeted to the industries and workplaces that are most likely to be vulnerable to exploitation.

Research shows that there is less demand for exploitative services where workers are well unionised and where labour standards relating to working hours, health and safety, minimum wages and employment conditions are routinely monitored and enforced. Therefore implementing and enforcing labour protection standards is an important part of combating people trafficking. [World Vision New Zealand]

Deterrence is a key factor in preventing or curbing people trafficking. A targeted campaign involving labour inspectors and immigration officers, where appropriate, to those areas most likely to be non-compliant would have a manifold effect:

• It would "immunise" those areas from the people traffickers
• It would enforce minimum code employment conditions in the businesses themselves
• It would build capacity in terms of the business owners having the means to develop lawful and respectful employment practices
• It would have ripple-effect over time. It would serve to prompt other non-complying businesses to comply. [Robyn Anna Black]

Some submitters comment that government and/or non-government agencies need to be better resourced to enable more effective monitoring and investigation of worker exploitation and people trafficking.

A specific suggestion from the consultation meetings was that the Department of Labour check that the contract provided by an employer at the visa approval stage is in fact the same contract given to the employee on arrival. Attendees also emphasised the need to involve business groups and unions in the development of a plan of action. Submitter comments on the role of the private sector are discussed below.

World Vision New Zealand considers that New Zealand should take a broader interest in improving working conditions for all workers, not just those in New Zealand. It suggests that New Zealand partner with, and influence, other countries to improve working conditions overseas by encouraging them to ratify relevant international agreements, set minimum working conditions and develop strategies for eradicating corruption. It also advocates the inclusion of labour standards in multilateral agreements and the establishment of an international labour inspectorate to monitor and report on labour conditions.

Addressing supply factors

A number of submitters express support for the inclusion of social and economic initiatives in the plan of action in order to address the factors that make people vulnerable to people trafficking. They would like to see specific projects and initiatives in the plan.

We would like to see much stronger emphasis on New Zealand actively prioritising and resourcing work to mitigate the social, economic, political and environmental factors that lead to trafficking. [Family Planning and Family Planning International]

Suggestions include:

• setting a timetable for increasing overseas development assistance to 0.7% of Gross National Income by 2015
• prioritising development assistance to countries in the Pacific and Asia
• funding programmes that offer livelihood options, improve children's access to education and provide security for reducing the effects of poverty, including food security, health care and sanitation
• promoting employment opportunities for women in vulnerable societies, for example through Fair Trade
• investing in gender and sexual and reproductive health and rights as a means of reducing poverty
• working with NGOs to educate local communities about trafficking
• taking practical steps towards the achievement of the Millennium Development Goals.

One submitter comments that economic disparity is a more significant driver of people trafficking than poverty, which should be reflected in prevention initiatives.

Visa and border controls

Some submitters comment that New Zealand needs to have tight visa and border controls in place, particularly for nationals from countries identified as being at high risk of people trafficking. One submitter comments that New Zealand is likely to be most at risk as a transit country for people trafficking to larger markets. As already discussed, submitters identify a need for training of visa officers overseas and staff working at the border.

Countries identified as "high risk trafficking" areas must have stringent visa controls in NZ. [Sue Prowse]

View good border management as a priority. [Pacific Women's Watch (New Zealand)]

One submitter suggests reviewing all policies and programmes to ensure that people trafficking cannot occur within their operation, and gives the example of the seasonal employment scheme. Other submitters, however, caution that policies designed to restrict migration or control irregular migration can exacerbate people trafficking. Likewise, an attendee at a consultation meeting expressed concern that a heightened awareness of trafficking activity at the border, while desirable, could have the unintended result of restricting the movement of women. Some attendees recommended the development of a protocol to deal with any victims of trafficking who are identified at the border, as returning them home may not be the safest option for the victim.

Attendees at the consultation meetings also raised concerns about Borderline, the television programme based on the Department of Labour's compliance operations. Some commented that having cameras on such operations is inappropriate and that compliance procedures are unsatisfactory. It was suggested that due to the gendered nature of trafficking in sex work, a more gender-specific approach to interviewing should be taken by compliance officers when holding operations in brothels.

National human trafficking unit

Some submitters suggest a central agency or unit to act as the first point of contact in responding to possible cases of people trafficking and coordinate assistance. The IGC notes that most states have set up a single unit that liaises with all involved agencies and co-ordinates prevention and prosecution efforts by coordinating operations and disseminating information. It comments that it may be too early for New Zealand to set up such a unit given the lack of cases to date, but that such an approach may help in identifying the first cases. Some submitters consider that a specialist unit should be set up within the New Zealand Police to deal with human trafficking and related offending.

Prostitution law reform

A number of submitters comment on the Prostitution Reform Act 2003. Some submitters express concern that the legalisation of prostitution may have increased trafficking of sex workers and suggest repeal of the Act as a prevention measure.

Repeal of the legalization of prostitution could combat human trafficking and prevent NZ from becoming a significant transit or destination country. Worldwide it is known that legalization has led to an increase in trafficking for sexual exploitation, e.g. the Mayor of Amsterdam recently stated that legalisation was a failed experiment and had led to a significant increase in trafficking for sexual exploitation [Sister Anne Phibbs]

Other submitters comment that no link has been found between the sex industry and people trafficking, and express support for the protections it provides for sex workers.

Where workers have legal protection, workers are able to pursue their rights and have protection against exploitation. Such an environment may be less likely to be appealing to traffickers.... We would not be supportive of policies that set out to re-criminalise sex work as a means of curbing 'demand' for trafficking in a domestic or a regional context. [Family Planning and Family Planning International]

Some submitters call for more research into this issue, and others seek regulation of the sex industry. One submitter expresses concern that the Act removed the responsibility of the New Zealand Police to monitor the sex industry, and notes links between the industry and organised crime.

Some submitters raise concerns about section 19 of the Prostitution Reform Act, which prevents anyone who is not a permanent resident of New Zealand from providing commercial sexual services or from owning or operating a brothel. They consider that failing to provide a legitimate avenue for non-residents to work in the sex industry excludes them from the protections provided to other sex workers under the Act, and increases the risk they could be exploited.

We are concerned that Section 19 of the [Prostitution Reform Act], which prohibits non-residents working in the sex industry, may not be conducive to good policy and practice around preventing trafficking. Section 19 has the potential to create an environment where exploitation can take place, as individuals are silenced by fear of criminal repercussions. [Family Planning and Family Planning International]

While we have not seen evidence of exploitation, we realise that it is necessary to protect international workers from any possible exploitation, or from anything that may encourage exploitation. [New Zealand Prostitutes Collective]

The submission from the New Zealand Prostitutes Collective includes comments from an anonymous international student. This student comments that enabling non-residents to work in the sex industry would prevent people trafficking, benefit New Zealand through increased tax revenue and enable international students to supplement their income to support their studies.

Allowing people to come here and work in the industry on a temporary work permit would deter traffickers further from targeting the industry in this country. Exploitation and coercion flourish in hostile legal environments and creating an open environment for those from all countries would be most conducive to promoting a human rights based non discriminatory approach. This climate would also allow non residents the right to make a valuable contribution to the New Zealand economy through the payment of taxes as a professional working legally in the sex industry. [Anonymous international student, New Zealand Prostitutes Collective]

Other comments

Other submitter suggestions for preventing people trafficking include:

• exploring the possibility of targeting trafficking in side agreements associated with trade deals
• organising signed agreements between countries to ensure government agencies and NGOs have validity when working with others in the international arena
• including the prevention of people trafficking in military and/or peacekeeping training and operations
• establishing a register of non-New Zealand sex workers and/or ensuring there is a reliable record of the ages of women working in brothels
• ensuring government and non-government agencies can freely share information about possible cases of people trafficking.

Prosecution

Sanctions and penalties

A number of submitters comment that the sanctions and penalties for people trafficking must be serious enough to reflect the nature of the crime and to act as an effective deterrent.

Aggressively prosecute cases and ensure that traffickers receive sentences consistent with the heinous nature of the offence. [Salvation Army]

The sentencing laws must be robust enough to act as a deterrent to anyone within New Zealand who considers exploiting people by trafficking. [New Zealand Federation of Business and Professional Women]

One submitter suggests penalties might include deportation and revocation of New Zealand citizenship for people traffickers who are not born in New Zealand. Another submitter, on the other hand, comments that deportation is unlikely to be an effective deterrent and suggests that large fines and/or compensation for victims may be preferable.

Since people trafficking is a crime motivated by greed, large fines/reparations are likely to be effective punishment. [Zonta International District 16]

A number of other submitters comment on the need to make trafficking uneconomic by ensuring financial penalties are sufficient and that the proceeds of crime can be seized. There is also some support for ensuring that compensation for victims is among the list of sanctions.

World Vision New Zealand comments that it may not be appropriate to criminalise the activities of those who recklessly disregard whether trafficking or forced labour is involved in the production of their goods or services. It notes that sanctions could include "fines, confiscation of assets, tax penalties, loss of relevant licences, or disqualification from trading activities", or that incentives such as tax exemptions could be used to encourage compliance.

Investigation and enforcement

A number of submitters consider that increased attention should be given to investigating possible cases of people trafficking and ensuring that the legislation is enforced. Submitters make the following comments:

• There should be an integrated framework across all agencies.
• Relevant UN Protocols and UNHCR guidelines point to international best practice and the actions required.
• Sweden and Norway have pioneered the European approach of nominating special prosecutors for people trafficking who work with the police and bring the main elements of evidence to their attention.
• Memorandums of Understanding should be entered into with the New Zealand Security Intelligence Service and the Government Communications Security Bureau with regard to intelligence gathering and investigation.

As noted earlier in this report, one submitter would like to see the New Zealand Police and other law enforcement agencies increase the priority given to investigating people trafficking, commercial sexual exploitation, organised crime and related offending. The submitter recommends:

• establishing a specialised squad
• creating a database of offenders
• undertaking proactive operations with respect to underage prostitution
• ring-fencing staff assigned to patrol the internet for online child exploitation
• considering the establishment of an alert system similar to the United States, where the community is immediately alerted if a child is abducted
• considering proactive investigation into the links between commercial sexual exploitation and organised criminal groups
• training of all frontline law enforcement staff.

An attendee at a consultation meeting noted that trafficking activity includes both small and large scale operations, and expressed the view that the prosecution of people traffickers needs to include a process for obtaining information about the larger players involved so that trafficking flows can be interrupted at the source. It was suggested that the New Zealand Police's planned Organised and Financial Crime Agency would have a role in such investigations.

Protecting the rights of victims during prosecution

A number of submitters emphasise the need to protect the rights of victims of people trafficking when instigating criminal justice proceedings. Some submitters comment that securing the cooperation of victims is essential to successfully prosecuting people traffickers and that victims are more likely to cooperate if their needs are placed first.

Crucial to a successful prosecution will be witness testimony. Accordingly any measure taken must place the trafficking survivor's safety and wellbeing first. Priority then, will be the care and protection of the survivor/s, for without such reassurance given, the likelihood of people who have been trafficked speaking out against the traffickers, will remain as it is, globally low. [Salvation Army]

The Plan should take into account international experience which suggests that ... victims are much more likely to cooperate with law enforcement if their basic needs are addressed first (i.e. they feel that there is concern for their welfare rather than just their utility as a witness). [Individual Submitter B]

Some submitters note that victims may not feel safe to testify and comment that the provision of support to victims should not be contingent on their participation in criminal proceedings. Some submitters advocate a reflection period of 30-90 days to enable the victim to recover and decide whether they wish to take part in the criminal justice process. They note that this is likely to lead to better outcomes for both the victim and any judicial proceedings.

We believe that provision of a reflection period for victims of trafficking is vital if the New Zealand Government is committed to delivering a human rights-based victim-centred plan on trafficking. Whilst the primary intent would be to recognize the health needs of victims, regularise their immigration status and ensure correct identification, such a provision would also, most likely, lead to a more effective participation in any subsequent criminal investigations and judicial proceedings. [Amnesty International Aotearoa New Zealand]

Submitters make a number of suggestions about the protections required for victims while criminal justice proceedings take place. These include:

• ensuring that legal processes are as quick as possible
• respecting the privacy and confidentiality of victims
• providing a witness protection scheme
• relocating victims to another town if they feel unsafe testifying while their traffickers are nearby
• using video testimony (especially for children), shielding the defendant from the complainant or witness in the courtroom, enabling evidence to be given outside the court, or clearing the courtroom
• providing victims with free legal aid
• enabling victims to return home and then come back to New Zealand to give testimony if proceedings are likely to be drawn out
• ensuring that victims cannot be detained, prosecuted, punished or immediately deported, and that they have the right to work in New Zealand.

World Vision New Zealand submits that the plan of action include a review of current legal and victim support procedures, an analysis of existing legislation to ensure there is adequate provision to compensate victims and a proposal to create a victim support fund from the penalties imposed on traffickers.

Cooperation with other countries

A number of submitters comment that New Zealand should work with other countries to identify and prosecute people traffickers. Suggestions include:

• assisting other countries to develop their capacity to address people trafficking, especially in Asia and the Pacific, by encouraging them to adopt and enforce relevant laws, providing training, and partnering with local law enforcement agencies and NGOs on individual cases
• cooperating with other countries with a view to targeting entire networks
• maintaining contacts with other receiving countries to keep up to date with the latest trends and patterns
• establishing an international inspectorate to take an active role in monitoring the activities of New Zealanders, investigating reports of people trafficking and gathering evidence for prosecution.

Other comments

Several submitters express support for the discussion document's suggestion that specialised training be provided to the New Zealand Police, prosecutors and judges.

Providing specialised training for the New Zealand Police, prosecutors and judges is crucial if sex trafficking is to be taken seriously. [Stop Demand Foundation]

Other comments are that immigration consultants and lawyers should be accountable for the clients they bring to New Zealand, and measures to prevent the obstruction of justice by force and coercion should be extended to all migrant workers.

Private sector involvement

Multi-sector approach to people trafficking

A number of submitters emphasise the need for a comprehensive interagency and multi-sector approach to people trafficking, involving partnerships between government agencies, non-government organisations, the private sector and the community.

It is important that both Government organisations (e.g. labour inspectors, immigration officials, police etc) and the private sector (including social agencies, church organisations, refugee organisations, legal and medical professionals, union officials, fellow employees etc,) work together and share information to combat human trafficking. [Zonta International District 16]

...protection and support measures for survivors require a multi sectoral approach through the intentional linking of government bodies, NGOs, social services and other agencies. [Salvation Army]

World Vision New Zealand submits that a coalition of interested parties be established to provide leadership and policy advice and to share knowledge and coordinate responses.

The role of employers and the business sector

Most submitter comments on the private sector focus on the role of employers and the business sector in combating people trafficking. Submitters identify the following roles:

• being responsible employers and ensuring that they comply with minimum labour standards in New Zealand
• being aware of the possibility that a potential employee may have been trafficked
• ensuring that imported goods are not produced by trafficked labour and encouraging suppliers to enforce minimum labour standards overseas
• developing codes of conduct for their industry, with mechanisms for monitoring and reporting any suspected abuse
• sponsoring broader initiatives aimed at raising awareness and preventing people trafficking.

Engage with large retailers to educate the business sector, bring change to relevant industries, institute codes of conduct and promote the enforcement of minimum labour standards in offshore factories. [World Vision New Zealand]

As the "demand" for cheap labour can be drawn for unscrupulous suppliers/traffickers as a means to strengthen economic competitiveness, employers should be encouraged to self-monitor their industries to uphold NZ business conduct standards. A reporting mechanism of suspected abuse should be established. This self-monitoring mechanism can serve to both prevent unfair competition practices and the exploitation of migrants and other workers. [Lance Bonneau]

Companies operating in New Zealand should be engaged by government agencies that could assist these companies to recognise signs of human trafficking. This would prove invaluable in the event that victims are current staff members, or are employed at a later date. [Shakti Community Council]

In addition, the New Zealand Council of Trade Unions comments that employers should develop industry/sector responses to labour and skills shortages, which are drivers of migrant labour, and that more sustainable approaches to skill and workforce development can help to reduce exploitative practices.

World Vision New Zealand recommends early engagement with key representatives so they can provide input into the plan of action and help to identify and implement actions in required in their own sector. The Human Rights Commission recommends working with employer bodies and unions, as well as relevant NGOs. It comments that Business New Zealand, Chambers of Commerce, Employers and Manufacturers Association and industry sector bodies should be specifically briefed and that the Council of Trade Unions should coordinate information sharing with unions. Another submitter suggests engaging organisations whose memberships comprise business people, such as Lions.

A number of submitters consider that efforts to improve awareness among employers and business groups should be focused on the industries that are at high risk of people trafficking and/or where trafficking has been predominant internationally. Submitters identify the following industries: agriculture, horticulture, construction, factory work, hospitality, domestic help, sex industry and marriage brokering. One submitter suggests providing training through industry training organisations.

Other submitter suggestions are that employers open up employment opportunities and work with ethnic community leaders when employing migrant staff. One submitter comments that airlines unintentionally benefit from people trafficking and could provide free seats to victims that are being repatriated.

Involvement of others