Submission to the Home Affairs Committee’s Inquiry into Human Trafficking

This is the text of the Nordic Model Now! submission to the Home Affairs Select Committee’s Inquiry into Human Trafficking.

About us

Nordic Model Now! (NMN) is a secular feminist grassroots women’s group campaigning for the abolition of prostitution and related practices and for the Nordic Model (also known as the Sex Buyer Law). All our members are unpaid volunteers and about 50% have lived experience of the sex trade.

In this submission, we focus on human trafficking for the purpose of the exploitation of the prostitution of others or other forms of sexual exploitation (sex trafficking).

We are available for questioning and further evidence if required.

Question 1. What is the scale and nature of human trafficking in the UK? Considering in particular:

a) Different types of exploitation (including sexual, labour, or criminal exploitation),

b) The profile of victims and perpetrators,

c) The gendered aspects of human trafficking,

d) The role of technology in facilitating human trafficking.

What the NRM data shows

Latest Figures show that since around the time of the implementation of the Modern Slavery Act 2015 (MSA), there has been a sea change in who is recognised as a victim of human trafficking. Before the MSA, significantly more sex trafficking victims were identified through the National Referral Mechanism (NRM) than labour trafficking victims. This was in line with international trends – which suggest that worldwide, around 80% of human trafficking is for the purpose of sexual exploitation.

Now that’s reversed in the UK – as shown in the following chart of the data for the eight years to 2018 (the last year for which data is available).

Referrals to the NRM by exploitation type
Referrals to the NRM by exploitation type

This shows that in the UK in 2018, more than twice as many labour trafficking victims were recognised than sex trafficking victims (3, 990 labour trafficking victims vs. 1,926 sex trafficking victims).

This is extremely unlikely to be due to changing criminal trends. Rather, it suggests that large number of victims of sex trafficking are not recognised as such and nor are their traffickers. As a result, the victims do not get the support and compensation to which they are entitled under international law, the vast majority of perpetrators have impunity, and the scale and true nature of the problem is significantly underestimated.

The latest data also shows that the vast majority of recognised victims of labour trafficking are male and of sex trafficking are female, as the following chart shows.

Chart showing the sex of recognised human trafficking victims by exploitation type
Chart showing the sex of recognised human trafficking victims by exploitation type

This suggests that the UK authorities are not only failing victims of sex trafficking but that this is profoundly sexist and a violation of Article 3 of the Council of Europe Convention on Action against Trafficking in Human Beings (the CoE Convention), which requires human trafficking provisions to be implemented without discrimination on the grounds of sex, and Article 17, which requires a gender mainstreaming approach.

To understand why there was such a change in the recognition of victims of the different types of human trafficking coinciding with the introduction of the MSA, we need to look in some detail at the MSA and how it frames the different types of trafficking.

The Modern Slavery Act 2015 (MSA)

The definition of human trafficking in the MSA is not conformant with the international definition set out in the Palermo Protocol and CoE Convention, particularly in respect of sex trafficking. This has been recognised as a concern by the independent review and the GRETA Committee and the CEDAW Committee. But the Government appears to have no intention to correct it.

This is of very grave concern. In order to explain our concerns, we will first look at the international definition of human trafficking and then show how very seriously the MSA diverges from it and why this is catastrophic for the understanding of sex trafficking.  

The international definition of human trafficking

The international definition has three key elements:

  1. Act: This can be recruitment, transportation, transfer, harbouring, or receipt of persons. Any one of these acts is sufficient to meet the definition.
  2. Means: This can be the threat or use of force, coercion, deception, fraud, abduction, or the abuse of power or a position of vulnerability. Again, any one of these means is sufficient to meet the definition. If the victim is under 18, there’s no need to prove that any of these means have been used.
  3. Purpose: This is always some form of exploitation, four distinct types of which are defined: (a) The exploitation of the prostitution of others or other forms of sexual exploitation; (b) Forced labour or services; (c) Slavery or practices similar to slavery and servitude; (d) The removal of organs.

Notice that sex trafficking is clearly separated from labour trafficking. This is an implicit recognition that prostitution should not be considered a form of labour and that the harms are of a different nature.

The definition states that consent is irrelevant in respect of the intended exploitation. This implies that exploitation is the core of the human rights abuse of human trafficking and, like all human rights abuses, whether the person consented is not relevant.

Notice the way that sexual exploitation is worded: “the exploitation of the prostitution” of the person, not the exploitation of the person and not “forced prostitution”. This is the same wording that is used in Article 6  of CEDAW and it means benefiting or profiting from the person’s prostitution regardless how that person is treated. This is an implicit recognition that the most common motivation for sex trafficking is to profit from the victim’s prostitution or other forms of sexual exploitation, such as pornography – and that these cannot be considered normal forms of labour.

A man who coerces his girlfriend into prostitution to fund his drug habit satisfies the three elements of this definition: act (recruitment), means (coercion), in order to exploit (i.e. profit from) her prostitution. Under international law he is therefore a sex trafficker regardless whether she agreed or not.

Because the ‘means’ are not relevant if the victim is under 18, any third party involvement in the prostitution of a child is sex trafficking under international law. Therefore, if a 17-year-old girl apparently freely enters prostitution to pay for her boyfriend’s drug habit, she is also a victim of sex trafficking under international law.

It is of extreme concern that under the MSA, neither of these cases would be recognised as sex trafficking – even though they fall under the international definition of human trafficking.

These are, of course, examples of what is commonly called pimping – free loading off someone else’s prostitution. More or less all cases of pimping meet the international definition of sex trafficking. As Catharine MacKinnon memorably put it, “sex trafficking is straight-up pimping.”

Many, perhaps most, women and girls involved in prostitution have some form of pimp, which means that under international law they are victims of human trafficking. And yet most are not officially recognised as such in the UK – and instead are now increasingly considered, erroneously, to be voluntarily participating in “sex work”.

It is hard to know exactly how many women involved in prostitution in the UK are pimped because the definition has morphed in the last 30 years from someone who “lives off the earnings” of a woman in prostitution (which would include husbands, partners and potentially drug dealers) to someone who actively controls or manages a person’s prostitution for gain.

The former, historical definition, more closely represents the reality of sex trafficking, because an intimate partner who is dependent on his partner’s income from prostitution will invariably exert some form of coercive control, if not actual violence, to keep the money coming in – but this might not be obvious to outsiders. Unfortunately, although this might be seen as domestic abuse, it is typically not recognised as pimping and that it is a common way that women get trapped in prostitution. It is even less likely to be recognised to fall under the international definition of sex trafficking, as, in fact, it usually does.

Those who lobby for the expansion of the sex industry, invariably argue that it is wrong that domestic partners of women involved in prostitution should be caught under pimping legislation. We see this as yet another way that lobbyists sanitise and obfuscate the reality of the sex trade – along with their use of the “sex work” terminology which incorrectly positions prostitution as a regular job.

Research from 2012 based on in-depth interviews with more than 100 UK women involved in, or exited from, prostitution found that 50% had suffered some form of coercion. As the definition was restrictive, it is likely that this is an underestimate. A European Parliament Report, found that of the 40-42 million people involved in prostitution worldwide, “90% are dependent on a procurer”, such as a trafficker or a pimp.

This suggests that at least 50% of the estimated 70-100,000 people involved in prostitution in the UK have one or more person profiting from their prostitution and are therefore likely to fall under the international definition of human trafficking. This indicates that the NRM statistics could be an underestimate by a factor of 50 or more.

The definition of human trafficking in the MSA

Human trafficking is defined in Section 2 of the MSA. The definition is substantially different from the international definition in a number of key ways.

The definition is centred on travel

The definition of human trafficking in the MSA is centred on the travel of the victim. Although the ‘action’ components set out in the international definition (“the recruitment, transportation, transfer, harbouring or receipt of persons”) are mentioned, they are only relevant in relation to the travel of the victim. This implies that human trafficking is an immigration issue rather than a gross violation of human rights.

This means that if travel did not take place or cannot be proved, according to English law, human trafficking did not take place – even if all of the elements of the international definition are met.

The forms of human trafficking to which males are more likely to fall victim, such as forced labour on a farm or carrying drugs (‘county lines’), are framed as ‘modern slavery’ which is defined in Section 1 of the MSA without the need for travel to be proved. But sex trafficking is excluded from the definition of ‘modern slavery’ in Section 1, unless the sexual exploitation is positioned as a form of labour that is forced, which would contravene the international definition that defines them as separate.


The definition of human trafficking in the MSA specifies that the consent of the victim is not relevant – but only in respect of their travel – and not in respect of their exploitation as set out in the international definition.

This is a grave concern because it opens the way for defendants – and officials – to claim that the victim consented to the prostitution. It also implicitly suggests that it is only the exploitation of ‘forced prostitution’ that is prohibited – whereas in fact the international definition makes any exploitation of (i.e. profiting from) another person’s prostitution the key factor, not whether the prostitution was ‘forced.’

This misunderstanding has been replicated and expanded upon in the government’s NRM guidance and the Home Office’s typologies of modern slavery. Disturbingly, the latter refers to “forced sex work” even when the victim is a child. Furthermore, the CPS guidance on consent in sexual offences includes a long section on consent in child sexual exploitation cases, even though consent is irrelevant to these offences – and to the international definition of human trafficking.

It should be noted that the restriction on the relevance of consent does not apply to Section 1 of the MSA that defines the criminal offences of slavery, servitude and forced or compulsory labour.

Definition of sexual exploitation

Section 3 of the MSA defines the various forms of exploitation. While the other forms of exploitation (with the exception of organ trafficking) are fully defined in this section, the definition of sexual exploitation refers to a long list of offences in other acts that must also be proved in order to secure a conviction.

While the list includes controlling someone’s prostitution for gain and various offences related to the sexual exploitation of a child, there are many other possible offences in the list. This obfuscates the fact that the trafficking for the purpose of exploiting (i.e. profiting from) a woman or girl’s prostitution (or other forms of sexual exploitation) is the most common form of human trafficking, and that to prevent it, we therefore need to reduce men’s demand for prostitution.

In addition, most of the listed offences hinge on the consent of the victim in contravention of the international definition of human trafficking, and some have other restrictions that are much narrower than the international definition. For example, most of the child sexual offences apply only if the child is under 13 or the defendant “reasonably believed” the child to be under 16 (18 in cases of child sexual exploitation).

This increases the difficulty of securing convictions, because the prosecution has to prove that the defendant didn’t “reasonably believe” that she was older than 15 (or 17 in sexual exploitation cases) and/or the prosecution has to prove that the defendant didn’t reasonably believe that she consented to the sexual exploitation. This is a further discrepancy from the international definition.


To achieve conviction under the MSA, cases of sex trafficking must either be centred on the victim’s travel and a secondary, restrictive offence must also be proved, or the exploitation of her prostitution must be framed as forced labour or services. Both of these options are more complicated than bringing a case of forced labour on a farm, for example. But perhaps even more egregiously this implicitly positions prostitution and other forms of sexual exploitation as a form of regular labour that is sometimes ‘forced’, and therefore implicitly normalises and legitimises what is a heinous human rights abuse.

This obfuscates the true nature of sex trafficking and the fact that the majority of sex trafficking is driven by the easy profits that can be made from women’s and girls’ prostitution – because of men’s demand – and that this is very widespread.

This obfuscation in turn obscures the measures that are required to prevent sex trafficking, and the fact that without reducing men’s demand for prostitution (and other forms of sexual exploitation), efforts to prevent sex trafficking are bound to fail.

The way the MSA frames and defines sex trafficking therefore is not only sexist but also serves to exonerate the Government from addressing this most heinous human rights abuse and from taking holistic measures to address the underlying causes. The catastrophic consequences for women and girls are clearly visible in the disturbing trends in the NRM data.

Question 2. How effective is the UK’s approach to discouraging the demand that leads to trafficking?

We were encouraged that last year the British military introduced a complete ban on military personnel paying prostitutes for sex while stationed abroad. When interviewed about the ban, Defence Secretary Ben Wallace made it clear that a key motivation was the need to improve the working environment for the women in the military. It was disappointing – and arguably irrational – that the ban was not extended to armed forces stationed in the UK.

We were also encouraged that the Secretary of State for Justice successfully appealed the Court of Protection ruling that in certain circumstances it is legal for carers to assist their clients in arranging and paying for sex. The appeal court ruled that there is no human right to buy sex nor for the state to make that possible.

However, these seem to be anomalies in the general trend towards official acceptance of prostitution as a form of normal labour and an overall failure to challenge the male demand that drives sex trafficking.

Policy capture by sex industry lobbyists

“Sex work is real work” tropes dominate mainstream culture and even the police and government departments have embraced them – as evidenced by the adoption of the “sex work” terminology by the Home Office (for example, in its Typologies of Modern Slavery) and police (as evidenced by the NPCC guidelines).

The flip side of “sex work is real work” is that buying sex is of no more consequence than paying for a haircut. This sanitises and trivialises the brutal reality and implicitly encourages men’s prostitution buying.

This is of grave concern and does not reflect a joined up and consistent approach to discouraging the demand. Rather, it is evidence that public bodies and government departments have been captured by academics and lobbyists for the expansion of the sex trade.

For example, Professor Teela Sanders has been the academic lead for the NPCC Sex Work and Policing working group since 2018. Sanders lobbies for the full decriminalisation of prostitution and was the driving force behind the misguided and now withdrawn University of Leicester Student Sex Work Policy and Toolkits.

It should not surprise us therefore that the latest NPCC guidance on policing prostitution is disturbingly biased as we demonstrate in our article: ‘A Sexist Prism: National Police Guidance on Policing Prostitution’. Nor that ACC Dan Vajzovic, the NPCC lead for prostitution, was reported in The Independent to be “working alongside government officials to reassess brothel keeping legislation” and appears to be lobbying for the decriminalisation of brothels.

If implemented, decriminalising brothels would send out a very strong message to men in the UK that they have the government’s blessing to buy women and girls for sexual use and abuse. In other words, it would encourage – not reduce – the demand that drives sex trafficking.

Legislation against sex buyers

Disturbingly, the CPS has accepted the NPCC guidance at face level and recommends against using the kerb crawling legislation (which is one of the few legislative tools for discouraging men’s demand for prostitution):

“National policing guidance advises that forces may give consideration to environmental solutions to encourage those involved in street prostitution to work in areas that are well lit and where CCTV is in operation. Enforcement on either those selling sex or ‘customers’ in cars or on foot is not encouraged as this is likely to result in displacement and put those selling sex at greater risk.”

The final sentence is straight out of the sex industry lobbyists’ playbook. This claim that any challenge to men’s demand for prostitution would make it more dangerous and drive it underground is much repeated by sex industry lobbyists but not borne out in practice.

Prostitution is inherently dangerous and nothing can change that. The best approach to reducing the risks is therefore to reduce the amount of prostitution that takes place and that can only be done by discouraging men’s demand for prostitution and providing genuine routes out and alternatives to the women and others involved.

Research has shown that deterring men from buying sex is not difficult. More than anything they fear exposure – that their wives and girlfriends, employers and communities will find out. It is therefore of grave concern that both the police and the CPS discourage the enforcement of legislation that already exists to deter sex buying – particularly when the harms of kerb crawling to women and children and the wider community are known to be severe.

The other key piece of legislation that targets sex buyers, Section 53A of the Sexual Offences Act 2003, has proved to be ineffective. The way this law is framed means that the prosecution has to prove beyond reasonable doubt that the woman had been forced, coerced, or deceived by a named person. In the murky world of prostitution this is not easy and it invariably requires considerable police work to bring a successful prosecution. But the maximum penalty is only a relatively small fine and the police do not invest many resources into investigating offences that carry such a low penalty – meaning there is a fundamental contradiction within the law that makes its ineffectiveness inevitable.

That it has been ineffective is a very strong argument, however, for a law that creates a criminal offence of purchasing or attempting to purchase sex, regardless whether the person has been forced, coerced, or deceived – i.e. for the introduction of the Nordic Model.


Legislation against advertising prostitution has not kept up with the huge changes that have come about through the success of the internet.

Section 46(1) of the Criminal Justice and Police Act 2001 made placing advertisements relating to prostitution in public phone boxes an offence. That was a significant development at the time, when public telephones were one of the most common ways that sex buyers made contact with women involved in indoor prostitution.

Those days are long gone, however. Now the internet is the key prostitution advertising medium and men who seek anonymity can buy a burner phone for less than £10.

Just as has happened with the rest of the internet, a few huge websites (such as AdultWork and Vivastreet) now dominate the prostitution advertising market. The commercial organisations behind these large websites rake in eye-watering profits.

These websites act as pimps and panderers and facilitate not only the buying of sex but also third parties pimping and sex trafficking women. Rather than “adult websites”, they are pimping websites. The people and organisations behind these websites are themselves pimps and they facilitate pimping and sex trafficking.

Banning these websites would be one of the most effective actions that could easily be taken to reduce sex trafficking and the demand for prostitution that drives sex trafficking. But instead, the police and other public bodies collaborate with the pimps who run these websites in what seems to us to be an utterly pointless attempt to get them to “design out” features that enable “sexual exploitation” – as if the entire function of these websites is not the facilitation of sexual exploitation.

Again, we see the toxic influence of lobbyists for the expansion of the sex industry. It was recently announced that Dr Teela Sanders is now leading a new publicly funded project “to examine how websites which promote and/or facilitate sex work can address sexual exploitation” – which is surely a complete oxymoron.

As prostitution survivor, Esther (not her real name) says: “The only way the police and prosecuting authorities could contribute to reducing sexual exploitation facilitated by these websites is by shutting them down.”

While these websites generally require people being advertised to present photo ID, this is not required of the sex buyers (punters). Esther makes the astute comment that “There would be no punters if the types of identification used elsewhere in society to increase security, such as passports or proof of address, were required before they could make contact.”

This asymmetry in who is required to provide photo ID reveals as a sham the claim beloved by sex industry lobbyists that these websites provide meaningful features for screening clients.

The police and other public authorities collaborating with the people behind the pimping websites is a dangerous strategy. It gives credibility to people who have made a successful business from profiting from the prostitution of others and provides opportunities for them to influence law and policy in this country. It is akin to collaboration with the organised crime groups that traffic illegal drugs.

Public bodies who condone the collaboration with the people and organisations behind the pimping websites are clearly in violation not just with the requirement to discourage the demand that leads to trafficking but also of CEDAW Article 6 that requires the suppression of the exploitation of the prostitution of others.

Porn as promotion of the demand that drives sex trafficking

Pornography and other non-contact forms of the sexual exploitation industry – such as webcamming and lap dancing clubs – feed men’s individual and collective sense of superiority and entitlement to sexual access to women and therefore implicitly promote the demand that drives sex trafficking.

All the myriad forms of the sexual exploitation industry present a picture of a multitude of interchangeable women who are sexually available and willing or even desperate to fulfil a man’s every whim. The women do not fancy him. They are simply desperate to be paid. But how are men to know that or to understand the ruthless business models employed in lap dancing clubs, brothels, the webcamming chatrooms, and on AdultWork and Vivastreet and similar? Business models that ensure there are more women on display than are required so they have to compete relentlessly with each other.

The logic of the sexual exploitation industry teaches men to think that women are inferior beings who owe them sex, and that women are commodities that can be bought and sold. It feeds men’s sense of entitlement and superiority – the exact same attitudes that are known to underlie male violence against women and girls generally, and men’s demand for prostitution.

It is of extreme concern that the government has failed to introduce age verification to prevent children viewing pornography and accessing webcamming and other “adult services” sites. We support the full set of recommendations of the All-Party Parliamentary Group on Commercial Sexual Exploitation’s inquiry into Pornography regulation. We argue that implementing these recommendations is necessary to comply with international obligations under the Palermo Protocol, the CoE Convention, and Article 6 of CEDAW.

Public education

Another way of reducing the demand that drives sex trafficking would be effective public information campaigns and education in schools and colleges about the harms of prostitution. But once again, there is no evidence that the government or public bodies have an appetite for this.

The UK government introduced compulsory sex and relationships education in English schools in September 2020. Many schools now outsource this to external providers and there’s been a rapid expansion in organisations offering resources and sessions. However, there’s no oversight or regulation. There is growing evidence that much school sex education is of low quality and promotes dubious ideas and values, including that “sex work” can be “rewarding”, and dangerous BDSM practices such as “choking” (i.e. strangulation), beating, and slapping. For an exploration of the impact of this, see our article, Sex (mis)education in schools.

We have seen no evidence of an effective public information campaign aimed at ordinary men to discourage them from prostitution buying. In response to a question from Baroness Sugg in the House of Lords on 21 February 2023, Lord Sharpe of Epsom said the Home Department was “tackling demand by targeting users of adult services websites to raise awareness of sexual exploitation on those sites through the use of things such as Google ads”. In the context of the scale of the problem and the incalculable harm that pimping websites cause to women and girls and to the fabric of society, this feels pathetically unambitious. It could also be seen as dangerous, because it suggests that some prostitution is acceptable, when the reality is that all prostitution causes damage.

Question 3. To what extent do support services meet the needs of victims who have been trafficked in or to the UK?

As we have shown, the numbers of victims of sex trafficking is systematically underestimated by orders of magnitude. The services that are available are therefore insufficient by orders of magnitude.

As a large proportion of women who are involved in prostitution meet the international definition of human trafficking, it would make sense for all women involved in prostitution to have access to high-quality services that they can self-refer to regardless whether they are officially recognised as sex trafficking victims. These services need to provide high-quality support that includes help to exit the industry and rebuild their lives.

For most women who are involved in prostitution, the most immediate barriers to exiting are (a) the lack of an adequate alternative income; (b) drug addiction; (c) being under the control of a pimp or trafficker, who is often their ‘boyfriend’ or intimate partner; and/or (d) homelessness. Other longer-term issues can include physical and mental ill-health, including PTSD and crippling anxiety, and the lack of a social network outside of the prostitution milieu.

Research carried out in the UK by the late Roger Matthews and others found that the majority of women can leave prostitution relatively quickly given support and motivation that is positive, proactive, and includes practical help with addressing the immediate barriers mentioned above.

Women-only residential drug rehabilitation should be available for those with intractable drug addictions, and women-only refuges for women who need to escape abusive and controlling partners and pimps.

Services must be women-only, welcoming, non-judgemental, trauma-informed, and free. Separate services should be available to boys, men and trans people where necessary. Funding must be ring-fenced and permanent so that expertise and trust can be developed, collaboration with other services established, and there can be long-term planning.

While the provision of such services would be expensive, we are confident that they would quickly pay for themselves in terms of savings on other services, particularly the criminal justice system and social services.

As well as placing an obligation on states to reduce the demand that “fosters all forms of exploitation of persons, especially women and children, that leads to trafficking”, Article 9 of the Palermo Protocol also requires states to “to alleviate the factors that make persons, especially women and children, vulnerable to trafficking, such as poverty, underdevelopment and lack of equal opportunity.” The UK is currently failing abjectly to meet this obligation. Rather, government policies are leading to a rapid increase in poverty, which is disproportionately impacting women and children.

We therefore call for real practical steps to address women’s poverty and inequality, and to invest in decent well-paid jobs, and apprenticeships and training for women. Similarly, the inadequacies in the benefit system need to be fixed, and the travesty of the no recourse to public funds rule for migrant women must be abolished.

Question 4. What evidence is there, if any, that the National Referral Mechanism process is being exploited by individuals seeking asylum in the UK?

We are not aware of any evidence of this and, as we explain in response to Question 1, there is evidence that suggests that victims of sex trafficking are under recognised by the NRM process by orders of magnitude. This is particularly true of women and girls.

Question 5. How can legislation, including the Modern Slavery Act 2015, policy and criminal justice system practice be improved to prevent and address human trafficking?

Update the MSA to bring it into line with the Palermo Protocol definition

The MSA obfuscates the true nature of sex trafficking and the fact that the majority of sex trafficking is driven by the easy profits that can be made from women’s and girls’ prostitution. This in turn obscures the measures that are required to prevent sex trafficking, and the fact that without reducing men’s demand for prostitution, efforts to prevent sex trafficking are bound to fail.

The way the MSA frames and defines sex trafficking therefore serves to exonerate the Government from addressing this most heinous human rights abuse and of taking holistic measures to address the underlying causes. We are already seeing the catastrophic consequences for women and girls.

The MSA has profound implications not only for how the criminal justice system deals with the crimes of human trafficking but also for how society as a whole understands prostitution and other forms of sexual exploitation and human trafficking for the purpose of their exploitation. As long as the MSA incorrectly frames sex trafficking as either revolving round travel or as a form of normal labour that can be forced, the UK will continue to fail in its binding obligations under the Palermo Protocol and the CoE Convention and confusion about the true nature of sex trafficking will persist.

We therefore believe that amending the MSA to bring it into line with the Palermo Protocol definition must be the first step.

Implementing the terms of a treaty does not necessarily mean adopting the identical text – but it involves ensuring that the essential terms are incorporated. US federal law provides an example of a definition of sex trafficking that elegantly and succinctly summarises the key features of the international definition:

“Sex trafficking is the recruitment, harboring, transportation, provision, obtaining, patronizing, or soliciting of a person for the purposes of a commercial sex act, in which the commercial sex act is induced by force, fraud, or coercion, or in which the person induced to perform such an act has not attained 18 years of age (22 USC § 7102).”

This is paired with a separate definition of labour trafficking, in compliance with the international definition.

The meaning of exploitation needs to explicitly include “exploitation of the prostitution of another person and other forms of sexual exploitation” or equivalent. The commonest other forms of sexual exploitation should be also specified, including making pornography, lap dancing, stripping, live streaming sex acts, and similar.

To be conformant with the international definition, all offences involving the trafficking and/or sexual exploitation of a child under 18 years of age (including paying for “sexual services”) must be strict liability offences.

Other recommendations

1. Redraft the NRM rules and guidance so that the definitions of human trafficking of adults and children align fully with the Palermo Protocol definition.

2. End the policy capture of the police, the Home Office, and other government departments and public bodies by lobbyists for the expansion of the sex trade. At the very least a balance of advisers must be ensured. We recommend the introduction of measures that make it a requirement for advisers on policy in this area to have a commitment to the understanding implicit in the Palermo Protocol, CoE Convention and CEDAW that prostitution and other forms of sexual exploitation are a form of gender-based violence and to measures that aim to reduce the size of the industry and the numbers who are involved in it.

We understand that sex industry expansionist views dominate academia in the UK and those who disagree with these views struggle to find funding and positions. We therefore recommend that the government ensures that funding and academic positions are available to those who understand the sex industry to be a form of gender-based violence and both a cause and a consequence of the enduring inequality between the sexes.

3. Pimping websites: These websites facilitate and profit from not only the prostitution of others but also pimping and sex trafficking by third parties. They therefore play a key role in encouraging the demand for prostitution that leads to sex trafficking.

We recommend the introduction of an offence of enabling and/or profiting from the prostitution of another person and that this is used proactively against those behind pimping websites, along with mechanisms for closing down or restricting access to websites that contravene this law.

4. Redraft the NPCC and CPS guidance to ensure conformance with obligations under the Palermo Protocol and the CoE Convention and Article 6 of CEDAW. At the very least, the advice against using the kerb crawling legislation must be removed.

5. Comprehensive training and guidance for all relevant professionals (including police, CPS, judiciary, social workers, etc.) on the harms of prostitution and other forms of sexual exploitation and the true nature of sex trafficking as defined in the Palermo Protocol.

6. Measures to address men’s demand for prostitution through the introduction of a Nordic Model style approach.

7. Urgent measures to address women’s poverty and inequality to reduce their vulnerability to being trafficked.

8. The introduction of robust age verification mechanisms on all pornography sites regardless whether the pornography is “user generated” or created professionally.

9. Sex education in schools to provide children with a realistic understanding of the sex industry and why it is harmful to those caught up in it and also to the consumers and the wider culture.

10. Police officers and staff should be banned from paying for or attempting to pay for sexual “services” at any time and banned from the personal use of pornography at work or using police equipment or networks, with a breach being considered gross misconduct.

11. Similarly politicians (including MPs, members of the House of Lords, and local councillors) and policy makers should be banned from paying for or attempting to pay for sexual “services” at any time.

NORDIC MODEL NOW! 15 March 2023


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