The Nordic Model seeks to establish norms under which no woman, man, girl or boy can be sold, and no one has the right to sexually exploit another human being

The afternoon panel. Gemma Kelly is on the far right.

This is an edited transcript of Gemma Kelly’s speech in the afternoon session at the ‘Students for sale: Tools for resistance’ conference, held in London on 15 October 2022. You can watch the recording on YouTube. Gemma’s speech starts at 41:00.

My name is Gemma Kelly. I am the Head of Policy and Public Affairs at Cease UK, which is the Centre to End all Sexual Exploitation. We wanted to give ourselves a really big aim so we went all out! We work to end prostitution and pornography, and I’m also part of Nordic Model Now! which is how I weaselled my way onto this panel, so thanks for letting me speak today.

I missed all of this morning, so I’m going to apologise in advance in case I’m repeating anything you’ve already heard. I’m going to discuss the Nordic Model, and I think we all probably know what the Nordic Model is, which is why we’re all here but I’m just going to run through a little bit of the background and some of the positive things that have come out of it.

I have worked in policy longer than I care to remember and no legislation is perfect. It really isn’t. We try our best and we get what we can. What’s really important with legislation is its implementation, and often that’s not perfect either, so I just want you to bear that in mind as we talk through the Nordic Model – it’s not a perfect model. No legislation is perfect but it is the best we have at the moment.

I should say as well, that I wrote my dissertation on the Nordic Model, and I think I saw my supervisor wander in earlier, whose eyes are glazing over as I speak because she’s heard me say this so many times, but let’s go through it.

The Nordic Model:

A legislative approach to prostitution that addresses the male demand for paid sex

First introduced in Sweden in 1999 now in several countries

Built upon a Gender Equality Framework

Three-pronged legal framework:
criminalises paying for sex.
decriminalises selling sex. 
provides support and exiting services for people exploited through prostitution.

The Nordic Model, as we know it, started in Sweden and it’s a legislative approach to prostitution. It addresses the male demand for paid sex.

It’s in various different countries. It started in Sweden and we now have it in Ireland, where I’m from, and Israel, France and Norway, and so it’s growing, which is great.

The founding principle of this legislation is that systems of prostitution are rooted in gender inequality and the uneven power balance between men and women. That’s fundamental to this piece of legislation.

Proponents of the Nordic Model, when the Swedish government first came up with it, and other governments that have implemented it since, firmly believe that it needs to be rooted in a gender equality framework, so that’s really important.

It’s a three-pronged approach as legislation: it criminalises paying for sex, it decriminalises the people who sell sex and it provides support and exiting services for people exploited through prostitution. So, these three things are really key because these are the three things that have to be implemented really well.

What’s really important is that it decriminalises people who are selling sex. In the Republic of Ireland, where we have the Nordic Model, and it’s not perfect, but it’s getting there, our Minister for Justice just recently expunged the criminal records of about 600 women who were involved in prostitution.

This was on the back of a huge pushback on the legislation because it was during its midterm review. It was implemented in 2017. and there was a report released by Amnesty International, talking about the usual stuff, and our Minister for Justice came out and said she was going to expunge the criminal records and that the legislation is staying.

The other really important thing about the Nordic model is that you need to have those wrap-around services. It’s not enough to criminalise buyers and it’s brilliant to decriminalise people who are selling sex, but we also need to have all of those services that are going to wrap around as well.

Introduced after research revealed:

- Extent of women’s suffering in prostitution

- Sex buyers’ ignorance of the consequences of their actions

- Idea is to criminalise buying sex to deter men

- Aim was to change social norms
 Intention of the Law – located in a framework of ending violence against women

The wonderful Swedish government, who are also not perfect, as my friend here will tell us later I’m sure, researched prostitution and they found that the extent of women suffering in prostitution was horrific, as we’ve all heard this morning.

Also they found sex buyers’ ignorance of the consequences of their actions was really key. Some of them just had no clue. Some of them did of course, but some of them genuinely, for all of these reasons that Michael Conroy has just outlined, didn’t realise the harm that they were causing.

So, the aim then is to criminalise buying sex in order to deter men. But what’s really key to the Nordic Model, and what really interests me, and which is why I wrote my dissertation on it, is the normative effect that it has – because that’s really important.

It seeks to establish norms under which no woman, man, girl or boy can be sold and no one has the right to sexually exploit another human being. That’s the norm that it sets up. That’s what it’s saying when your government says it is illegal to buy a human being for sex and that’s critical to this piece of legislation.

It places men as perpetrators of violence who, when they purchase another human being, are committing a crime and by doing this, as well as setting that normative effect, it’s disrupting the sex industry and it’s creating a hostile environment for prostitution and human trafficking.


- Training for police and officials

- Public education campaign

- Investment in policing sex buyers

- Investment in services for prostituted people 

- Addressing poverty and economic inequality

Image on the right of Simon Häggström's book, 'Shadow Land: The true story of a Swedish detective fighting prostitution'

One of the key things in any piece of legislation is implementation and that’s across the board. It’s only as good as its implementation. It’s one thing to have well-written legislation sitting in an archive somewhere, it’s another to have legislation and policies that are funded and implemented appropriately.

What we’ve seen with the Nordic Model is that in the countries where it is enacted, implementation varies from country to country. In France, I think they do it really well – they take the revenue from criminalisation and they funnel it into social services for prostituted people. That’s the ideal.

In Ireland there’s still a long way to go on implementation and there’s a really long way to go on those wrap-around services that are needed, that are the number one need for women who want to exit prostitution and also for preventing women from going into prostitution in the first place.

What they did really well in Sweden was training for police and officials and a massive public education campaign. Going back to something Michael Conroy was saying, education is really important because we know that boys and girls are growing up in a hypersexualised world. So, they had a massive public information campaign, which we didn’t do in Ireland.

You also need investment in police forces. You need training for police; you need to inform them about what’s happening; they need money and training resources. Policing costs money so it’s really important that all of those things are properly funded as well as investment in services, and then a whole government approach to addressing poverty and economic inequality.

Results in Sweden:

- No evidence prostitution has gone “underground”

- Percentage of men who bought sex fell from 13.6% to 8% between 1996 and 2008

- Only 0.8% of men in Sweden, had purchased sex in the previous 12 months (UK APPG 2018)

- New Zealand which has a population of 4.5 million, has between 6000 and 8000 women in prostitution, which is 12 to 16 times that of the sex trade in Sweden 

- Hostile destination for international sex traffickers 

- Most effective approach at shrinking the prostitution market and reducing demand. And that includes demand for human trafficking

There have been some good results in Sweden. I am sure our friends outside would say that the Nordic Model pushes prostitution underground. It doesn’t.

[Editor’s note: While Gemma was speaking, there were people outside the venue, protesting that the conference was taking place, because, they said, the Nordic Model makes prostitution more dangerous for women.]

In Sweden the percentage of men who bought sex fell from 13.6 to 8% between 1996 and 2008 – 1999 being when the legislation was brought in.

In the UK, the All-Party Parliamentary Group on Commercial Sexual Exploitation undertook a study in 2018. They found that in the previous 12 months only 0.8% percent of men in Sweden had purchased sex. That’s pretty small.

In New Zealand on the other hand, which is fully decriminalised and has a population of only 4.5 million, which is tiny, has between 6-8,000 women in prostitution, which is 12 to 16 times that of the sex trade in Sweden.

So under decriminalisation, you get a huge amount of prostitution; under the Nordic Model, you get less prostitution. You would think that governments would understand this better.

In Germany prostitution is legal but regulated and has a prostitution rate between 30 and 40 times that of Sweden.

These numbers show that the Nordic Model makes countries a hostile environment. Traffickers don’t want to go there because that’s not where the demand is, so they’ll go to countries where the demand is. This means that if we tackle the demand, we’ll ultimately stop prostitution.

The Nordic Model is the most effective approach to shrinking the prostitution market and reducing demand and again this isn’t just in Europe. They’ve done this in some cities in America – Jersey City, San Francisco, California, and the harms and rates of sex buying went down by 40 – 75 %.

They did an education programme for sex buyers in San Francisco. It was a while ago now, but I think it still stands. It showed a reduction in re-arrests by over 40% and it didn’t cost the taxpayers anything because the police fees were paid by the offenders, and that fully covered the cost of the whole programme, and also generated an extra $3 million in additional revenue that they then put into services.


- Significant normative effect… what is deemed by a government as legal is usually going to be seen as acceptable by society and vice versa 

- It’s normative, so gradually … the norm is going to be that it’s not acceptable (to buy women) and young men will change

- Massive public awareness campaigns directed at men and the public, saying it is not acceptable to buy sex

- ‘Changing the conversation around cultural norms and stereotyping, particularly stereotypes that see women and girls as dispensable, as commodities’

What these results show is that the Nordic Model produces a significant normative effect on society, particularly on men and boys.

My niece, who is 18, was born in Ireland in April 2004, one month after the smoking ban was introduced in Ireland. She’s never known an Ireland where you can smoke indoors, ever. She doesn’t get it when we tell her you used to be able to go into a pub or a restaurant and light up and there’d be smoke everywhere. It’s alien to her – she just doesn’t understand it and the reason that it’s so alien to her is because she grew up in a country where the law says you cannot smoke indoors in a public place. What is deemed by a government as legal is usually going to be seen as acceptable by society, and vice versa.

In New Zealand prostitution is decriminalised and, as we know from Chelsea’s talk this morning, women and girls are advertised there. Little boys and teenagers walk by those signs and see them every day when they go to town, as they go to school. That’s seeping into their psyche, just like Michael Conroy said – their brains are sponges and this is what they are seeing and so it’s completely normal. It’s completely normal when you are 18 to go to a strip club to celebrate your 18th birthday; to buy a woman for sex to celebrate being 18. It’s normal but it shouldn’t be.

The Nordic Model can stop that because it says to a society that no person should be bought. That’s what it says. The law says that it is our best teacher and when the law says something is illegal, we as a public have a tendency to believe it.

We don’t always agree with the laws our governments enact, but legislation speaks volumes and it changes attitudes and it changes behaviours and we’ve seen that with the smoking ban. If we were to see the Nordic Model brought into the UK, we would see it here as well.

Thank you.

Watch the recording

Here is the recording of the afternoon session of the ‘Students for sale: Tools for resistance’ conference. Gemma’s brilliant contribution starts at 41:00.

Further reading

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