We were pleased to make a submission to Submission to the Anti Slavery Commissioners Invitation for Input: Strategic Plan.
In our submission we highlighted the interconnections between human trafficking and the sex and pornography industries which trade on the commodified bodies of women and girls. We welcomed the announcement of Australia's new Anti-Slavery Commissioner and made several recommendations to assist the Commissioner's efforts to combat Modern Slavery.
(Click image below to read full submission)
Our Recommendations
Our key recommendation to the Commissioner was to prioritise strategies which address the trafficking of women and girls for sexual exploitation, noting that the Modern Slavery Act 2018 was not designed to target trafficking for sexual exploitation, nor framed in a way that provides assistance or support for survivors.
We commended the position of Reem Alsalem, United Nations Special Rapporteur on Violence Against Women who stated in her 2024 report, Prostitution and Violence Against Women and Girls:
The extreme levels of violence inflicted on women in prostitution – which would never be accepted in other contexts – are blanketed by a financial transaction, designed to materialize so-called ‘consent’ that cannot be expressed freely in the prostitution system. In this context, the very concept of ‘consent’ is weaponized against women in prostitution, as it is extorted through physical or economic coercion, manipulation and violence. Coercion is built into the prostitution system, facilitating entry factors as well as control and exploitation by pimps, traffickers and States.
Special Rapporteur Alsalem further explains that under the Trafficking in Persons Protocol, trafficking is defined as “an act (e.g. recruitment); the means (e.g. abuse of power or of a position of vulnerability); and the purpose (e.g. exploitation)...when these three elements are met, the consent of the trafficked person becomes irrelevant.”
With regard to Section 20C of the Modern Slavery Act, we urged key priorities to address trafficking in women and girls for sexual exploitation:
- To support Australian entities and entities carrying on business in Australia to address risks of modern slavery practices in their operations and supply chains, and in the operations and supply chains of entities they own or control;
- To support victims of modern slavery by providing information in relation to government and non-government resources, programs and services, including by developing and maintaining guidance material and making such material publicly available;
- To advocate to the Commonwealth Government on matters relating to modern slavery, including for continuous improvement in policy and practice.
Further, we recommended the following actions to support Australian entities and entities carrying on business in Australia to address risks of modern slavery practices in their operations and supply chains, and in the operations and supply chains of entities they own or control:
- Advocate for requirements for all businesses in the sex industry to report on risks of modern slavery in their operations and supply chains, regardless of revenue threshold;
- Advocate for appropriate screening of vulnerable groups for indicators of trafficking;
- Encourage educational institutions to identify and prevent visa fraud connected with human trafficking. For example, “none of the 14 Australian colleges identified as corrupt [by Trafficked] have faced criminal sanctions, and most remain open.” These colleges helped facilitate the trafficking into Australia of almost 200 South Korean young women for sexual exploitation (McKenzie, 2022).
We recommended a range of strategies to promote and support the Nordic (or Equality) Model, which criminalises the acts of selling and buying sex by pimps and johns, rather than punishing women in the sex industry.
We said we would like to be contacted for consultation on the initial draft of the Strategic Plan as set out in phase II.
Read our full submission here.
See also
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