HomeReportsOffice to Monitor and Combat Trafficking in Persons2023 Trafficking in Persons Report…Bahrain

# 					2023 Trafficking in Persons Report: Bahrain			

Office to Monitor and Combat Trafficking in Persons

 In this section										/

													BAHRAIN (Tier 1)											

                -  BAHRAIN (Tier 1) 
                -  PRIORITIZED RECOMMENDATIONS:   
                -  PROSECUTION   
                -  PROTECTION   
                -  PREVENTION   
                -  TRAFFICKING PROFILE:    

## BAHRAIN (Tier 1)

The Government of Bahrain fully meets the minimum standards for the elimination of trafficking. The government continued to demonstrate serious and sustained anti-trafficking efforts during the reporting period, considering the impact of the COVID-19 pandemic, if any, on its anti-trafficking capacity; therefore Bahrain remained on Tier 1. These efforts included investigating more labor trafficking cases and continuing to prosecute and convict labor traffickers; it also referred more cases that originated as labor violations as potential trafficking crimes for criminal prosecution. The government provided training on proactive victim identification to officials outside of the anti-trafficking police and identified more labor trafficking victims and potential forced labor victims through increased inspections and provided some potential victims with shelter. The government replaced the Flexi Permit program with the Labor Registration Program (LRP), allowing all foreign workers, including domestic workers, to work without an employer to sponsor their visa under certain conditions, which may have prevented migrant workers’ vulnerability to trafficking. However, as with the previous program, such self-sponsored workers were not entitled to rights and protections enshrined under the labor law. Although the government meets the minimum standards, it investigated, prosecuted, and convicted the fewest sex traffickers in four years. Officials initially identified more potential forced labor victims through increased labor inspections, but the government did not officially identify these individuals as trafficking victims, which may have limited the care they received. The government did not consistently screen vulnerable populations for trafficking indicators, including the 5,200 undocumented workers it deported during the reporting period and individuals in the commercial sex sector, which may have resulted in the penalization of victims for unlawful acts committed as a direct result of being trafficked. Although the government reported domestic workers had the ability to change jobs without employer approval following the conclusion of a contract, which may have prevented domestic workers’ vulnerability to trafficking as they had the freedom to leave exploitive work conditions that could lead to trafficking, it did not issue an official regulation for the change, which limited awareness and hindered its implementation. Bahraini law did not explicitly prohibit passport retention – a key indicator of trafficking – and passport confiscation remained a widespread practice, according to anecdotal reports. In addition, the government did not provide adequate legal protections for domestic workers, a population highly vulnerable to exploitation, including trafficking. Finally, the government did not enforce penalties for noncompliant employers in the Wage Protection System (WPS) which aimed to prevent instances of salary withholding, another key trafficking indicator. It also continued to identify potential forced labor cases only in severe cases of wage theft, in which workers had not received salaries for several months to years.

							PRIORITIZED RECOMMENDATIONS:					

- Significantly increase efforts to investigate, prosecute, and convict sex traffickers and prosecute and convict labor traffickers, including cases of domestic servitude.
- Ensure all frontline officials adequately and consistently use screening protocols, specifically when encountering vulnerable groups, such as individuals in the commercial sex industry, domestic workers who left their employer, migrant workers, undocumented workers, and Cuban medical mission workers, including during law enforcement action and labor inspections.
- Ensure the Expatriate Protection Center (EPC) is equipped to provide specialized services and shelter for labor trafficking victims, including potential victims not confirmed as trafficked by the Public Prosecutors Office (PPO).
- Adopt legal protections for domestic workers and ensure protections are fully implemented.
- Fully implement decision to allow domestic workers to change jobs without employer consent after their contract ends, including by releasing official regulations and raising awareness of the change targeting both employers and workers.
- Adopt legislation prohibiting passport confiscation with deterrent penalties and ensure officials are trained to consider passport confiscation as a trafficking indicator.
- Fully implement the Wage Protection System, including by holding accountable violators with deterrent penalties and ensure officials screen all wage theft cases for other trafficking indicators, and not solely severe cases.
- Ensure non-contract registered workers have access to justice and grievance mechanisms if they experience employer abuse or exploitation.
- During tripartite contract negotiations for domestic worker employment, ensure domestic workers sign a contract in their own language and in the presence of a labor official to improve oversight of contract switching.
- Ensure hotline staff adequately screens for trafficking indicators.
- Continue to conduct national anti-trafficking awareness campaigns, strategically targeting migrants, domestic workers, and employers and use orientation programming to ensure workers have not paid recruitment fees prior to traveling to Bahrain.

							PROSECUTION					

The government made limited efforts to prosecute trafficking offenders through law enforcement channels. Although it investigated more forced labor cases and continued to prosecute and convict labor traffickers, it prosecuted and convicted fewer traffickers overall compared to the previous reporting period, specifically sex traffickers. The anti-trafficking law, No. 1 of 2008, criminalized sex trafficking and labor trafficking and prescribed penalties ranging from three to 15 years’ imprisonment, plus a fine between 2,000 and 10,000 Bahraini dinar (BD) ($5,305-$26,525) and the cost of repatriating the victim(s). These penalties were sufficiently stringent and, with respect to sex trafficking, commensurate with penalties prescribed for other serious crimes, such as rape.

The Ministry of Interior (MOI) investigated 42 cases (59 alleged traffickers) — eight for sex trafficking and 34 for forced labor — compared with investigation of 44 cases, including 26 for sex trafficking and 18 for forced labor in the previous reporting period. Officials prosecuted 16 alleged sex traffickers, a significant decrease compared with the prosecution of 54 alleged sex traffickers in 2021 and 27 alleged sex traffickers in 2020. The government prosecuted three alleged labor traffickers, compared with two labor traffickers in 2021. One forced labor prosecution involved an employer who allegedly withheld four restaurant worker’s wages for more than two years, forced them to work overtime without compensation, confiscated their passports, and denied them a weekly rest day; this case — in addition to one sex trafficking case that involved three alleged traffickers — remained pending at the close of the reporting period. Courts convicted 13 sex traffickers and two labor traffickers in one case referred to the PPO from the labor court; in the forced labor case, the judge also found the company liable for a 10,000 BD ($26,525) fine and all costs associated with the repatriation of the victim. This was a significant decrease compared with the conviction of 50 sex traffickers during the previous reporting period but consistent with the two labor traffickers convicted during the previous reporting period. Officials sentenced all traffickers to between one and 10 years’ imprisonment plus a fine in accordance with the law. The government required convicted traffickers to pay all costs associated with the repatriation of victims and planned to deport all non-Bahraini traffickers upon completion of their sentences. The government did not report any investigations, prosecutions, or convictions of government employees complicit in human trafficking crimes.

MOI’s Directorate of Criminal Investigation and Forensic Science (CID) maintained a police unit dedicated to trafficking investigations. The PPO’s Trafficking in Persons Unit prosecuted all trafficking crimes under the 2008 anti-trafficking law and ensured victims had access to legal recourse and adequate protection services and assistance. Officials reported trafficking cases were regularly fast-tracked to the High Criminal Court, bypassing the lower courts, to accelerate the justice process. The government did not proactively monitor establishments known to be frequented for commercial sex and instead only investigated such cases if an individual filed a report to authorities. The government investigated 103 individuals for “debauchery and prostitution” between April and December 2022. Police reportedly investigated every “prostitution” case as a potential sex trafficking case and of the 103 individuals investigated, identified 20 sex trafficking victims among them. The low percentage of sex trafficking victims identified from those arrested for “prostitution” offenses coupled with the illegality of commercial sex in Bahrain suggests inadequate government screening protocols for individuals arrested for commercial sex.

Although observers continued to report some government officials and frontline authorities handled labor law violations administratively rather than as indicators of trafficking**,** the government made efforts to improve the mechanism in which labor-focused authorities referred suspected forced labor cases to law enforcement for criminal proceedings. The Labor Market Regulation Authority (LMRA’)s Protective Inspection Directorate (PID) and Grievances and Protections Directorate (GPD) continued to identify and refer labor trafficking cases for criminal prosecution, specifically those that originated as labor violations and continued to be incorporated into the government’s broader NRM. If the GPD identified a potential trafficking crime through screening, it referred the case to the PID to conduct a full investigation. PID’s investigators could refer potential trafficking cases directly to the PPO, which often forwarded the cases to CID to conduct a follow-up investigation for additional information to aid in prosecution. This transfer of cases or authority between agencies during the investigation phase sometimes hindered the government’s ability to prosecute labor trafficking crimes that originated as labor violations. In April 2022, the government assigned five trained MOI law enforcement officers to accompany LMRA PID inspectors on worksite inspections to enhance interagency coordination, evidence collection efforts, and prospects for prosecuting trafficking cases. The LMRA reported 40 potential trafficking cases were referred to the PPO through this method, including one which resulted in the prosecution of an alleged trafficker. In comparison, the LMRA referred nine potential forced labor cases to law enforcement and the PPO in 2021.

The government trained – directly and in partnership with Gulf states and international organizations – police and investigators from CID’s anti-trafficking unit, all judges and prosecutors, including newly licensed lawyers, LMRA staff, medical staff and media representatives on several topics, including proactive identification and screening, identifying forced labor cases and victims, and evidence collection in forced labor cases. The government also ensured frontline officials outside of CID’s anti-trafficking unit – including immigration officials, airport staff, and labor inspectors – received training on identifying potential victims or screening for trafficking indicators. Investigators from CID’s anti-trafficking unit, who were trained on screening and identifying trafficking indicators, often accompanied immigration officials during law enforcement action and immigration inspection visits to provide victim identification expertise.

							PROTECTION					

The government increased efforts to protect victims. The government identified more labor trafficking victims compared with previous years and assisted more potential forced labor victims, including by providing some with shelter, but did not consistently screen vulnerable populations for trafficking indicators, including foreign workers subject to deportation or individuals working in the commercial sex industry, which may have resulted in the penalization of victims for unlawful acts committed as a direct result of being trafficked. The government identified 22 adult female sex trafficking victims and five labor trafficking victims, compared with 33 victims (29 adult female sex trafficking victims, two child sex trafficking victims, and two victims of labor trafficking) in the previous reporting period. Separately, the government assisted 182 potential labor trafficking victims, including 177 males and five females, all foreign nationals; these individuals were referred to the PPO but only five were officially designated as trafficking victims. The government continued to utilize its NRM to proactively identify victims, ensure proper documentation of cases, refer cases to the MOI and PPO for an official determination, and provide protection services to victims until case resolution or voluntary repatriation. Officials provided English and Arabic NRM booklets to all relevant ministries, labor-source country embassies, and NGO stakeholders. Police stations, other government entities, NGOs, religious organizations, and foreign embassies directly referred victims to the LMRA.

The LMRA’s EPC served workers regardless of their gender or legal status in the country and sheltered presumed trafficking victims, those who experienced severe labor exploitation, and those who were vulnerable to exploitation. Observers noted that the PPO was inconsistent in how it made official determinations that a trafficking crime had occurred, but also said access to the EPC was not contingent on a determination. However, potential trafficking victims were ineligible for the full scope of government services, such as the Victim Assistance Fund, without an official determination of trafficking by the PPO. Furthermore, activists noted the government limited services to potential victims unless officials identified a perpetrator and collected enough evidence to prosecute the perpetrator, which may have prevented unidentified or potential trafficking victims with complex legal proceedings from receiving adequate and specialized care. Experts also noted because the government established the EPC to care primarily for sex trafficking victims, victims of labor trafficking, who were rarely identified as official victims by the PPO, were potentially left without access to physical shelter, with the exception of egregious cases at the government’s discretion. The EPC provided 16 of the 22 identified adult female sex trafficking victims, all five identified labor trafficking victims, and 54 of the 182 potential labor trafficking victims with shelter, food, clothing, medical care, religious support, psycho-social counseling, transportation, familial reunification, translation services, and legal counsel. The remaining six sex trafficking victims did not accept shelter at the EPC and reportedly stayed with their embassies or community networks. The remaining 128 potential labor trafficking victims did not receive shelter at the EPC but were assisted by the government in their legal cases and were provided basic needs and repatriation support, if needed. The government reported it also offered job placement in Bahrain to victims, but no victims utilized this option during the reporting period. The EPC provided separate spaces for women and men as well as children, with a maximum capacity of 400 individuals. The government provided all official trafficking victims who remained in Bahrain for the duration of their trial with 1,131 BD ($3,000) in assistance in addition to a monthly allowance of 93 BD**($250) via its Victim Assistance Fund. LMRA provided additional funding, as needed, for victim repatriation and financed daily GPD expenditures, such as payroll and operational expenses.

Observers expressed concern that once victims were able to return to work in Bahrain, their employer still controlled their residence and work visa, heightening their vulnerability to exploitation and re-trafficking. The government reported trafficking victims were eligible to sponsor their own work visas through the LRP and the government could use victim assistance funds to pay the registration fees for a victim’s work permit. However, during the year, none of the identified victims became non-contract registered workers under the new system. The government reported it again increased the number of staff at the LMRA’s EPC to adequately handle the number of vulnerable or exploited workers or trafficking victims, enhance services, and support the regional training center. Embassies of labor-source countries also provided housing on a temporary basis for potential victims who decided not to go to the EPC or were unable to reach it.

Although the government had formal identification procedures, authorities did not consistently screen vulnerable populations for trafficking indicators, including undocumented workers and individuals in commercial sex. Therefore, authorities likely penalized unidentified victims of trafficking through detainment and deportation for unlawful acts committed as a direct result of being trafficked. Between October 2022 and December 2022, the government – through LMRA PID inspections and joint-ministry inspections – deported 5,300 workers it deemed were in violation of residency laws; one rights group asserted these individuals were not screened for trafficking indicators prior to deportation. Other observers noted the government did not frequently identify potential trafficking victims during law enforcement actions and individuals in commercial sex were not regularly screened for trafficking indicators. Some migrant workers who fled abusive visa sponsors chose not to report abuse out of fear of deportation. Bahraini officials provided comprehensive protective assistance to all official victims regardless of their willingness to participate in trafficking investigations and/or court proceedings and relieved them from all legal and financial penalties related to acts committed as a direct result of being trafficked. The government shared a full evaluation of their case with the victim and their legal right to restitution in the event of a conviction. Witness protection was enshrined in law and the government reported identities were kept confidential through the stages of the NRM, regardless of whether the individual was declared a trafficking victim. The government reported victims could testify via written correspondence, video recording, a closed-circuit live video, or in private; however, the government reported no victims required or requested to testify through these methods during the reporting period. Victims could speak in their native language in court proceedings with the assistance of an interpreter. Observers reported concerns that because all case-related documents were required to be translated into Arabic before being presented to judges, attempts to seek redress for vulnerable migrants, including potential trafficking victims, remained difficult. Workers infrequently filed complaints against employers due to distrust of the legal system, protracted court processes, inability to afford legal representation, lack of interpretation and translation services, concern over potential loss of residence permits during proceedings, and fear of additional mistreatment due to employer reprisal. During the reporting period, the government repatriated 19 sex trafficking victims pretrial to their countries of origin at the victims’ request; the PPO represented these individuals in absentia during court proceedings. The remaining three victims remained in Bahrain at the close of the reporting period.

							PREVENTION					

The government made uneven efforts to prevent trafficking. Although it allowed some workers, including domestic workers, to self-sponsor their work visas under certain conditions and allowed domestic workers to change jobs at the end of their contract without employer consent, it did not adequately or fully implement these efforts. In the previous reporting period, the government reinstated the National Committee to Combat Trafficking in Persons after a one-year hiatus; however, the full committee did not convene. The government appointed a new chair in March 2023. The government established a working group in July 2022 to implement best practices in the anti-trafficking field, chaired by the Minister of Interior. In July 2022, the government conducted the second iteration of its training of trainers program at its Regional Center of Excellence and Capacity Building for Combating Trafficking, certifying 25 trainers for individuals in healthcare, aviation, labor inspection, victim care, and LMRA staff to enable them to share expertise on victim identification in Bahrain. The LMRA established a new section within the Regional Center to conduct research and development based on data gathered from cases within the NRM, but did not report any outputs of the section at the close of the reporting period.

Article 23 of Bahraini Law No. 19 of 2006 prohibited “for any person to receive any moneys or obtain any benefit or advantage from an employee in lieu of issuing him a work permit or in return for the employment of such an employee or his retention in his job.” However, observers noted migrant workers continued to report the prevalence of schemes in which prospective workers paid a recruiter in their home country, or more rarely paid a recruiter in Bahrain, for employment or a work permit. Furthermore, experts asserted the government did not adequately pursue measures to limit this practice or provide support to workers indebted to unscrupulous recruiters, particularly for small and medium-sized businesses such as construction firms, salons, and those in office support fields like security personnel, cleaners, and other support staff. Nonetheless, during the reporting year, PPO received one case of violation for prosecution. The LMRA continued to oversee issuance of licenses and regulation of recruitment agencies through quarterly inspections, monitoring agencies for employment and immigration violations, and other measures. The government continued to require employers provide workers with adequate accommodation and required recruitment agencies pay a one-time deposit equivalent to 10,000 BD**($26,525) that would be forfeited if the company violated employees’ rights. During the year, PID conducted 241 recruitment agency inspections and shut down two unlicensed agencies and referred them for civil prosecution, one of which resulted in a conviction. PID also shut down one licensed recruitment agency due to noncompliance with LMRA regulations. Between October and December 2022, the LMRA carried out 7,037 worksite and labor camp inspections, including 116 joint inspections with MOI officials and other government ministries; it referred 257 employers for violating labor regulations and 474 workers for violating the residency law to the PPO. Notably, the inspections resulted in the referral of 62 potential forced labor cases to the PPO for criminal proceedings. The LMRA reported in October the conviction of 20 defendants for “obtaining a work permit without an actual need for it” or “keeping the work permit when it is no longer needed,” under Law No. 19 of 2006 with regard to regulation of the labor market.

Since 2011, the government allowed private sector migrant workers freedom to change jobs without their employer’s consent after one year of employment, although the LMRA still had to approve each transfer; during the reporting period, 4.86% of Bahrain’s migrant worker population changed employers. In addition to this policy, the government operated programs granting foreign workers the ability to work without a Bahraini visa sponsor. In November 2022, the government abolished its Flexi Permit program which had previously allowed foreign nationals to reside and work in Bahrain without a visa sponsor. NGOs and labor rights organizations expressed concerns low-income workers could not afford the permit under the old system and, in some cases, accrued debt to pay for it. In December 2022, the LRP replaced the Flexi Permit program at significantly lower cost, allowing migrants to register at labor registration centers to obtain a work permit without a sponsor or contract. Non-contract workers could register for a one- or two-year permit, both renewable at the end of either period. A one-year permit cost 347 BD ($920) and a two-year permit cost 519 BD ($1,376), which included health insurance and departure flight ticket insurance. These programs allowed registered workers to hold multiple jobs concurrently with various employers. Some migrant worker advocates feared that labor registration centers would require a vocational certification or professional qualification and semi-skilled workers, like electricians and carpenters, would face difficulty applying without the proper credentials. The government stated that technical certification was not a requirement for the registration process.

The LRP was available for current Flexi Permit holders and workers with expired, cancelled, or terminated contracts, regardless of their immigration status. Workers transitioning from the Flexi Permit to the LRP were eligible for a refund or credit for fees paid. However, like the Flexi Permit program, migrants could not register with the LRP before arriving in Bahrain or after arriving on a tourist visa; workers were only eligible for the program once their work visa expired, contract ended, or if they were undocumented. This continued to put migrant workers in vulnerable situations with their legal immigration status tied to their sponsor or employer when first arriving and seeking employment in the country. Additionally, workers who were the targets of legal charges filed against them for items such as “absconding” or criminal charges, were not eligible to register. Notably, domestic workers were eligible to register with the LRP following the expiration of their contract or in situations where their contract was cancelled or terminated due to a violation of their rights or abuse. Domestic workers were not previously eligible for the Flexi Permit. Separate from the LRP, the government reported domestic workers could change jobs without employer consent following the conclusion of their initial contracts; domestic workers in Bahrain generally had two-year contracts. However, it did not publicize or announce this policy change, which limited the number of domestic workers aware of and able to utilize this reform, as well as its implementation among officials. One NGO reported low awareness of the change among domestic workers and expressed concerns employers could unilaterally renew a worker’s permit and visa. The LMRA stated that workers had the option to preempt any unilateral or automatic contract renewal or to notify the LMRA at the contract’s end that they do not want to renew. All migrant workers remained able to terminate employment at any time, within the notice period specified in their contract, and leave the country permanently without employer consent; however, some employers continued to demand employees procure an exit permit, suggesting low awareness of the policy.

Previously, advocacy groups expressed the need to ensure rights for self-sponsored workers. Freelance workers or those in short-term employment were not required to have a contract with their employer, and rarely did, heightening their vulnerability to wage disputes or other issues related to temporary employment. Furthermore, because self-sponsored workers were not categorized as “employees,” they were not entitled to rights and protections enshrined under the labor law. The LRP maintained this approach, with registered workers not covered under the labor law, although they could file complaints with the LMRA for addressing disputes between the worker and employer or labor registration center. The government reported it was in the process of launching a hotline for registered workers to report problems as well as signing an MOU with the Ministry of Justice, Islamic Affairs and Endowments to establish offices within the LMRA dedicated to filing civil cases for registered workers and providing pro bono services in legal proceedings; however, it did not report finalizing or implementing either initiative.

The government’s WPS obligated employers to pay wages electronically to workers via financial institutions authorized by the Central Bank of Bahrain. The government designed the system to alert the LMRA to instances of non- or delayed-payment of wages with violators subject to penalties and legal action. The final phase of the WPS launched in January 2022 to encompass any employer with one or more employees and during the reporting year, the government began automatically registering self-sponsored workers in the WPS. As of January 2023, the government had not pursued any penalties against employers for non-compliance and noted it preferred to continue education for employers – especially small enterprises, which comprise the majority of businesses in Bahrain – instead of penalizing them. NGOs continued to express concern that a bar on issuing new work permits was an insufficient penalty for violating the WPS. NGOs reported officials still preferred to mediate WPS wage disputes between the employer and employee, rather than hold the non-compliant employer accountable with penalties. Non- and delayed-payment of wages continued to be common practice; the LMRA reported it received 1,034 claims of unpaid wages from workers during the year. For example, during the reporting period, 62 migrant workers employed by a construction company in Bahrain reported that beginning in January 2021, the company owed six to 12 months of wages to the workers and end of service benefits; as of November 2022, the government had frozen the company’s assets, but the workers remained without their salaries or other benefits. Employers of domestic workers were not required to enroll in the system. A total of 2,760 employers had voluntarily registered to pay domestic workers through the WPS by the close of the reporting period.

Articles 19 and 40 of the labor law established limited protections for domestic workers, which included agricultural workers, home security guards, nannies, drivers, and cooks who work for the employer or family members, requiring employers to provide a labor contract specifying annual leave and bonuses, and that such workers must be paid at least monthly. However, Article 22, which prohibited contract switching or changes to preset work conditions outlined in the contract, was not applicable to domestic workers. Labor inspectors were unable to conduct unannounced inspections of domestic workers’ accommodations and investigate abuse allegations without an official complaint, which may have left some victims at risk of exploitation and without protection. Due to these limited protections, NGOs reported domestic workers frequently fled their employer’s home to remove themselves from abusive situations, thereby further increasing their vulnerability to traffickers seeking to exploit their unemployment and undocumented status. As soon as employers reported a worker as “absconding,” they faced residency law violations and could be detained by officials. Employers reported 1,585 “absconding” cases against workers during the reporting period – including 801 against domestic workers. The LMRA continued to disseminate copies of the standard labor contract to all registered recruitment agencies in Bahrain, which required domestic workers to sign, prior to their arrival, a comprehensive work agreement outlining labor rights and employment obligations. The contract aimed to strengthen protections for domestic workers by requiring employers to disclose duties, hours of work, salary, rest hours, and weekly days off. Domestic workers brought into Bahrain by recruitment agencies were able to accept or reject a contract in their respective countries of origin, and the LMRA maintained copies of signed contracts to assist in future labor disputes. However, NGOs expressed concern the standard contract lacked mandatory working conditions as it remained up to the employer to determine working hours, minimum wage, overtime pay, and rest time. In contrast, title seven of the labor law stipulated a maximum daily limit of eight working hours for other private sector workers. Additionally, NGOs noted many vulnerable domestic workers did not know the contents of their contract due to language barriers; thus, one rights group asserted domestic worker contracts should be signed with a Bahraini government official and interpreter present. Furthermore, domestic workers rarely received a copy of their contract. During the reporting period, the government reported implementing a mandate on the use of the standard contract for all domestic worker recruitment – either through a regulated recruitment agency or directly by a family employer – and ensuring LMRA had the contract on file to mitigate contract switching. Previously, NGOs reported standard contracts were only required when using regulated recruitment agencies.

Bahraini law did not explicitly prohibit passport retention, even when the employee objected to the practice. Instead, the government handled passport retention administratively once migrant workers filed a grievance for passport withholding with the police or the LMRA. Such cases handled by the LMRA reportedly involved screening for trafficking indicators by trained GPD staff. Representatives of labor-source country embassies reported cases handled by LMRA resulted in expedient and fair disposition of cases. Once contacted by the LMRA or police, employers routinely denied having possession of an employee’s passport. Without an admission, law enforcement did not pursue cases of passport retention as an indicator of trafficking, and the LMRA did not impose administrative penalties. In most cases, the employer returned the passport, once contacted by the police or LMRA. The LMRA reported it received 3,254 phone calls with claims of passport retention through the NRM, although this number did not include all other complaints of passport retention submitted by other mechanisms. The LMRA retrieved and returned 3,844 passports to migrant workers in 2022. Police generally did not consider passport retention to be a trafficking indicator, instead considering it stolen property if the employer refused to return it. In such cases, the LMRA referred the case to law enforcement and could prohibit the employer from obtaining new or renewing existing work permits and could refer the employer to law enforcement for legal action. The government reported a draft labor law amendment was under review to criminalize passport confiscation, but it did not specify penalties and it remained under review at the close of the reporting period.

In partnership with an international organization, the government conducted a national awareness campaign targeting foreign workers on workers’ and employer’s rights and responsibilities, as well as exploitive practices that may lead to trafficking such as passport retention, restriction of movement, long working hours, and lack of medical attention. The LMRA maintained a website (endtrafficking.bh) with information on trafficking and resources for foreign workers; however, NGOs reported key information on the website was only available in English, limiting its utility. The LMRA reported multilingual materials from the awareness campaign would be added to its website but did not report doing so by the close of the reporting period. The LMRA continued to provide booklets outlining labor rights in 14 languages common among expatriate and migrant worker populations and distributed them to such populations upon their arrival at the Bahrain International Airport and at the LMRA when applying for initial or renewed residency cards; the government also provided mobile phone subscriber identity module (SIM) cards to workers upon entry into Bahrain, which allowed the LMRA to maintain contact information for each worker to ensure workers could be notified via short message service (SMS) for updates on their legal status, worker permits, and receive awareness messages. The EPC’s trafficking hotline collected reports and educated workers about their rights and available services in nine languages 24 hours a day, seven days a week. The government advertised the hotline’s number and mandate through pamphlets given to each migrant worker upon arrival in Bahrain and on the LMRA’s social media platforms and website. The government reported the LMRA’s trafficking hotline received 14,169 calls during the year; however, it did not report identifying any trafficking cases or victims through the hotline. One NGO reported the government hotline sometimes went unanswered and did not provide support in Tagalog, despite there being many Filipino workers in Bahrain. The government continued to uphold MOUs with several labor source countries, including Pakistan, that focused on recruitment agency oversight and migrant worker protections, and reported several additional MOUs were in progress. The government partnered with an international organization to begin implementation of orientation programs for migrant workers developed in 2021 – two in a worker’s home country, one upon arrival in Bahrain, and one in preparation to depart Bahrain. The government did not make efforts to reduce the demand for commercial sex acts. The government provided anti-trafficking training for its diplomatic personnel.

							TRAFFICKING PROFILE: 					

As reported over the past five years, human traffickers exploit foreign victims in Bahrain.  Men and women, primarily from India, Bangladesh, Pakistan, the Philippines, Nepal, Egypt, Sri Lanka, Jordan, and Yemen, among other countries, migrate voluntarily to Bahrain to work as semi-skilled or unskilled laborers in the construction and service industries and domestic work sector – which includes agricultural workers, home security guards, nannies, drivers, and cooks.  Men from India and Bangladesh account for the vast majority of Bahrain’s male domestic workers.  The government’s Covid-era decision to lift restrictions on tourist visas to applicants from African countries led to an increase in the number of migrants from African countries such as Cameroon, Kenya, and Uganda, coming to Bahrain to seek work.  The government reported there were roughly 70,000 domestic workers in Bahrain as of January 2023, 85 percent of whom were female, predominantly from the Philippines, Ethiopia, India, Indonesia, Kenya, and Sri Lanka – approximately 10,000 less workers than in the previous reporting period.  Domestic workers from African countries are increasingly at risk of forced labor and arrive in Bahrain via direct recruitment from local employers in which workers pay brokers or middlemen in their home country to match them with a visa sponsor in Bahrain.  Some employers subject migrant workers to forced labor in Bahrain; indicators include passport retention, confinement, contract substitution, non-payment of wages, debt bondage, threats or intimidation, and physical or sexual abuse.  NGOs and labor-source countries continue to report an increase in incidents of unpaid wages and debt bondage, especially among construction and unskilled workers.  Reports of unpaid overtime pay, end-of-service indemnity, and denied vacation time also continued.  Some migrant workers are not given or are not in possession of their employment contracts and are generally unfamiliar with the employment terms contained therein.  Courts still only accepted documents, including contracts, that most migrant workers did not have possession of, in Arabic which many migrant workers did not speak.  Public opinion supporting the practice of employers retaining workers’ passports to ensure they do not flee, coupled with the fact that passport confiscation is not explicitly prohibited by Bahraini law, enabled this pervasive practice to continue.  

Nationals of countries without diplomatic or consular presence in Bahrain, most significantly from African countries, are particularly vulnerable to trafficking, as are domestic workers, who are only partially protected under Bahraini labor law and significantly isolated in their place of work.  Government and NGO representatives report physical and sexual abuse of female domestic workers, controlled freedom of movement, withholding of workers’ identity cards and passports, restrictions on outside communication, and employer coercion to prevent employees from reporting exploitation are significant problems.  Cuban nationals working in Bahrain may have been forced to work by the Cuban government.  Although the government maintained regulatory authority over recruitment agencies, some migrant workers arrive in Bahrain independently of regulated agencies.  Many workers are paired with employers through intermediaries in Bahrain and unlicensed recruiters in their respective countries of origin.  Local press report traffickers recruit women to Bahrain via social media platforms or Bahrain-based acquaintances under false pretenses of high-paying jobs in the hospitality and domestic work sectors and subsequently force them into sex trafficking.  Some unscrupulous employers bring migrant workers to Bahrain through visa trading or the “free visa” scheme – whereby workers pay an employer a recurring fee to sponsor their work visa while performing work for other employers in violation of local labor law – which can render them vulnerable to trafficking due to their illegal working status.  Expatriates residing in Bahrain long-term were also reportedly complicit in the “free visa” scheme.  

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### On This Page

                    -  BAHRAIN (Tier 1) 
                    -  PRIORITIZED RECOMMENDATIONS:   
                    -  PROSECUTION   
                    -  PROTECTION   
                    -  PREVENTION   
                    -  TRAFFICKING PROFILE:    

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BahrainBureau of Near Eastern AffairsHuman TraffickingOffice to Monitor and Combat Trafficking in Persons

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