EUROPEAN COMMISSION Brussels, 3.12.2018 SWD(2018) 473 final COMMISSION STAFF WORKING DOCUMENT Accompanying the document REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND

THE COUNCIL

Second report on the progress made in the fight against trafficking in human beings (2018) as required under Article 20 of Directive 2011/36/EU on preventing and combating trafficking in human beings and protecting its victims {COM(2018) 777 final}



Contents 1. INTRODUCTION 1.1. Methodology and information sources 1.2. Member States and National Rapporteurs or Equivalent Mechanisms (NREMs) 1.3. EU Civil Society Platform and e-Platform against trafficking in human beings 1.4. EU Agencies, and international and regional organisations 2. EMERGING TRENDS AND PATTERNS IN ADDRESSING TRAFFICKING IN HUMAN BEINGS 2.1. Statistical data for 2015-2016 2.2 Patterns and Emerging Trends 2.2.1. Trafficking for the purpose of sexual exploitation 2.2.2. Trafficking for the purpose of labour exploitation 2.2.3. Other forms of exploitation 2.2.3.1. Trafficking for forced criminality and forced begging 2.2.3.2. Trafficking for forced and exploitative sham marriages 2.2.4. Emerging patterns of trafficking 2.2.4.1. Internal trafficking 2.2.4.2. Child trafficking 2.2.4.3. Vulnerability of Roma victims

2.2.4.4 Persons with disabilities and dependencies and emerging patterns 3. TRAFFICKING IN THE CONTEXT OF INTERNATIONAL MIGRATION 3.1. Conceptual clarity – Trafficking in human beings and migrant smuggling 3.2. Trafficking and international protection 4. PROFILES AND HOW THE TRAFFICKERS WORK 4.1. The use of information and communication technologies 5. PREVENTING TRAFFICKING IN HUMAN BEINGS BY COUNTERING THE CULTURE OF IMPUNITY 5.1. Encouraging the criminalisation of the use of services provided by the victims 5.2. Increasing accountability and results through effective investigations and prosecutions 5.2.1. Financial investigations 5.2.2. Freezing, seizing and confiscation of proceeds of crime 5.2.3. Joint Actions 5.2.4. Cross border cooperation 5.2.5. Links of Trafficking in Human Beings with other crimes 5.2.6. Special Investigative Techniques and Specific Competences 5.3. Awareness Raising and Training 5.4. Due diligence and responsibility of legal persons in the trafficking chain 6. ACCESS TO AND REALISATION OF RIGHTS FOR VICTIMS 6.1 Identification of Victims of Trafficking in Human Beings 6.1.1. National and Transnational Referral Mechanisms (NRMs and TRMs)

6.1.2. Transnational cooperation 6.2. Assistance and protection of victims of trafficking 6.2.1. Assistance and protection of child victims 6.3. Cooperation with civil society and other actors 6.4. Compensation to victims 6.5. Application of the non-punishment principle 7. INTENSIFY A COORDINATED AND CONSOLIDATED RESPONSE 7.1. EU Network of National Rapporteurs or Equivalent Mechanisms on Trafficking in Human Beings 7.2. EU Civil Society Platform and ePlatform against trafficking in human beings 7.3. Working with EU Agencies 7.4. The external dimension 8. Crosscutting Priorities 8.1. Statistical Data Collection 8.2. National Estimates 8.3. Funding ANNEX I UPDATE ON THE IMPLEMENTATION OF DIRECTIVE 2004/81/EC 1. Targeted Consultations 2. Member States’ contributions List of referenced documents





1.INTRODUCTION This staff working document complements the second Commission report on the progress made in the fight against trafficking in human beings as required under article 20 of Directive 2011/36/EU on preventing and combating trafficking in human beings and protecting its victims (hereafter ‘the Report’). It aims to provide a factual overview of the progress made in addressing trafficking in human beings in the EU, including statistical data, as reported by Member States, EU Agencies, civil society and international or regional organisations. The document additionally takes into consideration actions implemented by the European Commission and other relevant stakeholders in the context of the EU Strategy towards the eradication of trafficking in human beings 2012-2016 (hereafter "the EU Strategy") and the 2017 Commission Communication ‘Reporting on the follow-up to the EU Strategy towards the eradication of trafficking in human beings and identifying further concrete actions’ (hereafter “the 2017 Communication”). The targeted priority actions stipulated in this Communication include (i) disrupting the traffickers’ business model and untangling the trafficking chain, (ii) providing better access to and realising the rights for victims and (iii) intensifying a coordinated and consolidated response, both within and outside the EU; and two cross cutting priorities (iv) actions for a sound knowledge base and (v) actions to support anti-trafficking priorities in EU and non-EU countries. The staff working document elaborates on the topics presented in the Report in selected areas of the ‘four Ps’, prosecution, protection, prevention, and partnership/cooperation, which are not only the main pillars of the Directive 2011/36/EU (hereafter “the Anti-Trafficking Directive”) but also reflect the targeted priorities set forth in the 2017 Communication. The first section of this staff working document describes the methodology and information sources used for drafting both the Report and this document. The following sections mirror the structure of the Report by providing detailed elements on: emerging patterns based on data and trends; specific anti-trafficking actions; funding; implementation of the EU Strategy and the 2017 Communication, brief analysis of statistical data provided by the Member States, and an update on the implementation of the Directive 2004/81/EC on residence permits for victims of trafficking. 1.1. Methodology and information sources The Report and this accompanying staff working document are based on a wide range of information and sources, including: ·information gathered by the national rapporteurs or equivalent mechanisms and transmitted to the EU Anti-Trafficking Coordinator by the Member States pursuant to Article 19 and 20 of the Anti-Trafficking Directive; ·actions taken by the Commission and other stakeholders under the EU Strategy and the 2017 Communication; ·contributions submitted by civil society organisations participating in the EU Civil Society Platform and the e-Platform against Trafficking in Human Beings; and ·information from relevant EU agencies, and international and regional organisations. The report and its accompanying staff working document, presents emerging patterns based on data and trends, actions taken under the EU Strategy and the progress in implementing the 2017 Communication, in line with the commitment undertaken therein. The report also contains statistical data provided by the Member States and presents an update on the implementation of Directive 2004/81/EC on residence permits for victims of trafficking. The narrative information submitted by Member States mainly covers the period 2014-2016, while the report and staff working document draw on information from sources such as Member States, civil society, international organisations and Commission publications.

The methodology and sources used to gather this information are detailed below. 1.2. Member States and National Rapporteurs or Equivalent Mechanisms (NREMs) Article 19 of the the Anti-Trafficking Directive states that the tasks of the NREMs should at least include ‘the carrying out of assessments of trends in trafficking in human beings, the measuring of results of anti-trafficking actions, including gathering of statistics in close cooperation with relevant civil society organisations active in this field, and reporting". Article 20 of the Anti-Trafficking Directive further stipulates that ‘Member States shall transmit to the ATC the information referred to in Article 19, on the basis of which the ATC shall contribute to reporting carried out by the Commission every two years on the progress made in the fight against trafficking in human beings’. The methodological aspects followed are in line with the approach taken for the first Commission progress report adopted in 2016 and it builds on that previous experience. Thus, a template was discussed and agreed with the EU Network of National Rapporteurs or Equivalent Mechanisms on trafficking in human beings to facilitate reporting. The template provided a general direction for the reporting and aimed at ensuring a coordinated approach for a coherent report at the EU level. The information gathered by the NREMs and transmitted by the Member States is extensive and includes reporting on national developments, new patterns and trends in the field of anti-trafficking, statistics and funding. National examples are presented throughout this paper in order to enrich available information at EU level. 1.3. EU Civil Society Platform and e-Platform against trafficking in human beings The report and staff working document take into consideration contributions submitted by civil society organisations participating in the EU Civil Society Platform against trafficking in human beings (hereafter ‘the Platform’) and the complementary e-Platform. As per the process followed for the publication of the first progress report (2016), these contributions relate to the input received from the EU Network of NREMs Network or other relevant information. Reports transmitted by 26 Member States have been made available for comments via the EU Civil Society e-Platform. This process continues to represent a concrete example of implementation of the requirement of close cooperation with civil society organisations set forth by the Anti-trafficking Directive, which recognises their key role in the joint efforts to address trafficking in human beings, as equal partners. Civil Society Contribution to the Report For this report, 14 contributions (single and joint) were submitted for consideration through the described process, including 88 civil society organisations participating in the Platform, in the e-Platform or other. Contributing NGOs are based in 18 Member States (AT, BE, BG, CZ, DE, DK, EE, ES, FI, FR, IT, IE, LV, NL, PL, RO, SE, UK), including European and international offices, with NGOs from non-EU countries (8) also participating in joint submissions. 1.4. EU Agencies, and international and regional organisations The Report and this staff working document take also into account information provided by the following EU Justice and Home Affairs Agencies in the context of the work delivered under the Joint Statement signed by the Heads of seven Justice and Home Affairs Agencies in 2011: European Asylum Support Office (EASO), European Police Office (Europol), EU Judicial Cooperation Unit (Eurojust), European Institute for Gender Equality (EIGE), European Border and Coast Guard Agency (Frontex), EU Agency for Fundamental Rights (FRA), EU Agency for Law Enforcement Training (CEPOL). A relaunch of this Joint Statement was marked in 2018, which brought on board further relevant EU Agencies joining the effort, as a key action under the 2017 Communication. More information on this can be found in Section 7.3 of this staff working document. 2.EMERGING TRENDS AND PATTERNS IN ADDRESSING TRAFFICKING IN HUMAN BEINGS

2.1. Statistical data for 2015-2016 The fourth exercise in the collection of statistics on trafficking in human beings, mainly focusing on the period 2015-2016, presented in this second progress report, provides more data than the previous ones. All Member States have provided statistical data, though at varying levels of detail. Eurostat published two working papers on EU-level statistics in 2013 and 2014, updated in 2015, followed by a limited data collection exercise by the Commission for 2013-2014, reported in the first progress report. The data for 2015-2016 show similar patterns among registered victims and traffickers in contact with the police and criminal justice system to those found in previous reporting periods. These data concern those in contact with authorities and other organisations. There are reasons to believe that many victims and traffickers remain undetected and are therefore not included in these figures reported here. There are substantial differences in the way that Member States collect and record data, so there is a need for caution in any comparisons between them and over time. For 2015-2016: ·There were 20 532 registered victims of trafficking in the EU. ·5979 prosecutions and 2927 convictions for trafficking in human beings were reported. ·7503 people had formal contact with the police or the criminal justice system, that is were suspected, arrested or cautioned for a criminal offence concerning trafficking in human beings. ·Over half (56%) of trafficking in human beings was for the purpose of sexual exploitation and this remains the most widespread form. Around one quarter (26%) was trafficking for labour exploitation, while other forms (such as forced begging, organ removal) (18%) made up the remainder. The majority (61%) of the registered victims of trafficking for labour exploitation are found in the UK, so data from the UK significantly changes the proportion of trafficking that is for labour at the EU level. If the UK data are not included, then the proportions change to: sexual 65%, labour 15% and other 20%. ·Females (women and girls) were over two-thirds (68%) of the registered victims (if UK data were not included this rises to 77%). ·Children were almost one quarter (23%) of the registered victims. ·EU citizens were (44%) of registered victims. ·The top five EU countries of citizenship of registered victims were Romania, Hungary, the Netherlands, Poland and Bulgaria. These are the same countries as in 2010-2012 and in the first Commission progress report. ·The top five non-EU countries of citizenship of registered victims were Nigeria, Albania, Vietnam, China and Eritrea. The Commission has worked with Member States, Eurostat and statistical authorities to improve the data available. There is more detail, as well as new information, on the different ways that state services engage, support victims and act to reduce the impunity of traffickers. This work included requests for information in relation to victims, such as, the use of international protection status and in relation to reducing impunity, such as, the criminalisation of the use of services of victims of trafficking. However, there remain gaps in the provision of data by Member States, which place limits on the reliability and comparability of the information. The Commission will continue supporting the Member States in their efforts to improve availability, recording and registration, reliability and comparability of data on trafficking in human beings in order to monitor the phenomenon and ensure better policy-making.

2.2 Patterns and Emerging Trends Article 19 of the Anti-Trafficking Directive requires that Member States take the necessary measures to establish national rapporteurs or equivalent mechanisms. The tasks of such mechanisms shall include the carrying out of assessments of trends in trafficking in human beings, the measuring of results of anti-trafficking actions, including the gathering of statistics in close cooperation with relevant civil society organisations active in this field, and reporting. Information following below contains such trends and patterns as reported by the Member States and the civil society in narrative reports. Trafficking in human beings is a complex social phenomenon that takes many forms. It develops over time, often according to the demand of users and the inventiveness of traffickers. It should be recalled that the list of different forms of exploitation in the Anti-trafficking Directive is non-exhaustive so that new exploitative forms can be included under the definition of trafficking in human beings. 2.2.1. Trafficking for the purpose of sexual exploitation Trafficking in human beings for the purpose of sexual exploitation continues to be the most reported form. In 2015-2016, there were 9 759 registered victims of sexual exploitation. making up over half (56%) of the registered victims who had a recorded form of exploitation, and predominantly women and girls (95% of registered victims of sexual exploitation).A sharp increase has been noted in the number of women and girls trafficked through the Central Mediterranean route for sexual exploitation in the EU. Victims are exploited in the sex and entertainment industry, facilitated by the rapid technological development and the internet. Emerging patterns reported include pornography, the use of live web cameras and live distant child sexual abuse. Europol states that ‘Trafficking in human beings for the purpose of sexual and labour exploitation remains a key threat in the EU. Cases of trafficking in human beings for sexual exploitation are the most predominantly reported.’ Nigerian Women and Girls potential Victims of Trafficking for Sexual Exploitation In 2017, the International Organisation for Migration (IOM) reported a 600% increase since 2014 in the number of women and girls potential victims arriving by boat from Libya to Italy, predominantly from Nigeria. IOM highlights that sexual exploitation increasingly involves younger girls – often minors – who are already subject to violence and abuse on their way to Europe. IOM estimates that 80 per cent of girls arriving from Nigeria – whose numbers have soared from 1 454 in 2014 to 11 009 in 2016 – are potential victims of trafficking for sexual exploitation. According to Member States, sectors where trafficking for sexual exploitation has been reported include street prostitution, prostitution in private flats (with reference also to short-term rentals), escort agencies, and the entertainment industry. The rapid development of the Internet and new means of communication (social media et al.) influences the modus operandi associated with trafficking for sexual exploitation and renders the diffusion of advertisement of services by victims more widespread (small ads on websites and advertisements). The use of new information and communication technologies is linked to recruitment of victims, including through intra-community sites. Member States reports further mention pornography, the use of live web cameras and live distant child sexual abuse as emerging patterns. The gender specific nature of this criminal phenomenon is clear in that its victims are predominantly women and girls. The United Nations Inter-Agency Coordination Group against Trafficking in Persons (ICAT) underlines that ‘the Secretary General Report on trafficking in women and girls acknowledges that the harms of trafficking are known to be more severe for women and girls than for men and boys given the exposure of the former to specific forms of exploitation such as sexual exploitation and violence, domestic servitude and forced marriage.’ 2017 Communication Deliverables The European Institute for Gender Equality in cooperation with the Office of the EU Anti-Trafficking Coordinator in the European Commission delivered the report on gender-specific measures in anti-trafficking actions, which undertakes a comparative analysis of the Victims’ Rights Directive and the Anti-Trafficking Directive, from the perspective of women and girls trafficked for sexual exploitation purposes. The report aims to provide guidance to practitioners in a practical and tangible manner.

At the same time, some Member States report also on male victims of trafficking for sexual exploitation (e.g. AT, IT, NL). For example, in Austria, MEN VIA assisted 4 male victims of trafficking for the purpose of sexual exploitation during the reporting period. In the Netherlands, research was conducted on boys becoming victims of sexual exploitation. Europol reports that boys have been reported to be exploited in even more clandestine locations than female child victims. In one case, suspects would transport the male victims to specific bars where sexual encounters with clients would be organised. In other cases, they would be forced to meet potential customers in parks and be sexually assaulted there. The gender specificity of this form of exploitation is also relevant to the role of female victims, who, Member States report, are increasingly involved in this criminal activity in specific phases (e.g. RO). Member States further report that a growing number of victims of trafficking for sexual exploitation has learning and/or developmental disabilities and are recruited from care or youth institutions (e.g. NL). Europol highlights that ‘the sexual exploitation of EU nationals no longer relies predominantly on the use of violence and coercion towards victims. Some Organised Crime Groups (OCGs) are increasingly relying on threats of violence towards victims and their families rather than attacking the victim. Victims originating from outside the EU are still routinely subjected to violence, debt bondage, passport confiscation and other forms of coercion as an integral part of trafficking modi operandi’. Deception and abuse of the position of vulnerability are reported to be used as means of recruiting victims. Often traffickers approach victims, create an emotional dependency to the victim and channel them to sexual exploitation (so-called ‘lover boys’, mentioned by BE, BG, DE, NL, PL, RO). Europol’s finding that ‘there are MS where prostitution is legal, making it much easier for traffickers who wish to use a legal environment in order to exploit their victims’ is still valid, with traffickers tending to drive their victims in countries where prostitution is regulated and lawfully practiced (e.g. reported by RO). In this respect, according to Europol’s operational intelligence in some EU Member States, where prostitution is legal, suspects were able to exploit children alongside adults victims in legal businesses such as brothels, red light districts, sex clubs, often with the support of the business managers, since prostitution of minors can be very profitable, as ‘clients’ are generally prone to pay more to have sex with a child. Further, Europol finds that the traditional flow from Eastern to Western Europe of trafficking for the purpose of sexual exploitation, has been replaced by multiple and diverse flows of victims all over the EU. Pertaining particularly to the role of the Internet, identified patterns with respect to contiguous crimes are also important to note. Europol reports that ‘Child Sexual Abuse (CSE) perpetrated online is increasingly profit driven. (…) Child Sexual Exploitation Material is increasingly produced for financial gain and distributed through the Darknet. Coercion and sexual extortion are increasingly being used to victimise children. (…) Children are sexually exploited largely to satisfy the sexual appetites of those with a sexual interest in children. However, there is a growing trend in the production of CSEM for financial gain. A particular activity associated with commercial production of CSEM is that of Live Distant Child Abuse (LDCA). LDCA is a significant threat in this area of criminality. LDCA involves a perpetrator paying to direct the live abuse of children on a pre-arranged specific timeframe through video sharing platforms’. The online advertisement of sexual services is an increasing phenomenon relating to THB for sexual exploitation, with children being advertised as adults. The Council of the EU identified trafficking for sexual exploitation as part of the key priorities of the EU Policy Cycle for organised and serious international crime and European Multidisciplinary Platform against Criminal Threats (‘EMPACT’) during both periods of 2014-2017 and 2018-2021. While the majority of Member States’ reports mention trafficking for sexual exploitation as the most frequent form, information on the actions taken in the Member States demonstrate a tendency to focus on other forms of exploitation. Civil society organisations have expressed concerns that trafficking for sexual exploitation is not being made a priority, with its implications for gender inequalities. Civil society organisations also express concerns on victims of trafficking for sexual exploitation not being identified and cases not investigated.

The Commission is currently monitoring the implementation by Member States of Directive 2011/93 on combatting the sexual abuse and sexual exploitation of children, and is supporting Member States by facilitating the exchange of best practices. If needed, the Commission will make use of its enforcement powers under the Treaties to ensure correct and complete implementation of the Directive. The data collected for this report and other sources suggest that, despite the efforts made so far, trafficking for sexual exploitation has not been tackled effectively and there are no indications of this form of exploitation decreasing. It is only by prioritising trafficking for sexual exploitation that this crime can be adequately addressed. EU-wide Joint Action Day against trafficking for sexual exploitation and child trafficking An impressive number of 28 countries teamed up with Europol in October 2016 to deliver a major blow to organised crime groups involved in trafficking in human beings across the European Union and beyond. During the operational activities of the EU-wide Joint Action Day (JAD) named Ciconia Alba, one part of the intelligence-led police actions and controls focussed explicitly on sexual exploitation and child trafficking. During the span of the action week co-ordinated by Europol and under the lead of Austria, 11 161 locations (red-light district areas, brothels, private flats, massage parlours, airports and reception centres) were controlled, alongside 43 405 persons were checked, and 549 victims/potential victims identified. In addition, police controls checked 5 126 vehicles and 35 848 ID documents. Data gathered during the operations led to the launch of 102 new investigations in order to identify further suspects and victims linked to trafficking cases across the EU. The nationality of the victims of trafficking identified, and the suspects arrested during the JAD Ciconia Alba, confirm the prominence of trafficking network originating from Nigeria, Asia and Eastern-Europe as being the most active in the EU. Fourteen underage victims were reported. Overall fifty-two countries and four international organisations were involved in the JAD Ciconia Alba, and joined Europol in its fight to disrupt the most dangerous criminal networks currently active. During the JAD investigators put an emphasis on cases related to facilitated illegal immigration, trafficking in human beings, drug trafficking (cocaine, heroin and synthetic drugs) and cybercrime (payment card fraud – Global Airport Action Day). Law enforcement officers in the field were supported 24/7 from an operational coordination centre located at Europol’s headquarters in The Hague. There, Europol officers, liaison officers and national experts from the participating countries, working with specialists from other international partners, offered fast and smooth information exchange using Europol’s secure channels, and constantly analysed intelligence gathered. In the crime area of trafficking in human beings, in addition to the national delegates present at Europol’s operation coordination centre, an exchange of law enforcement officers from the countries of origin and the countries of destination of the trafficked human beings was paramount for the success of the operation. 2.2.2. Trafficking for the purpose of labour exploitation Trafficking for labour exploitation affected around one quarter (26%) of registered victims. Labour exploitation primarily affects males (80% of the registered victims) although in certain sectors of labour victims are predominantly women (such as domestic work). Several Member States have reported that trafficking for labour exploitation is on the rise. Sectors reported by Member States (e.g. by AT, BG, FR, HU, LT, LU, LV) where victims are exploited concern construction, agriculture and forestry, manufacturing, catering industry, care services, cleaning services and domestic work, entertainment, fishing, hospitality, retail and transportation. At the same time, trafficking for the purpose of domestic servitude appears to affect predominantly female victims (e.g. PL), including in diplomatic households (PL). The Group of Experts on Action against Trafficking in Human Beings (‘GRETA’) notes that: ‘[…] Trafficking for the purpose of exploitation in domestic and care work more frequently concerns women and is more difficult to detect, as it takes place in private households where victims can be subjected to a combination of labour and sexual exploitation, sometimes in the context of forced or sham marriages (…). Domestic and care workers are particularly vulnerable to exploitation due to the fact that in many countries the development of the private domestic and care market has been mostly uncontrolled, there are gaps in the labour legislation, and private households are usually not subject to labour inspections without a search warrant’. The Council of the EU identified trafficking for labour exploitation as part of the key priorities of the EU Policy Cycle for organised and serious international crime and EMPACT during both periods of 2014-2017 and 2018-2021. According to Europol, ‘The involvement of OCGs in trafficking for labour exploitation is increasing in the EU. OCGs cater to the growing demand for cheap labour across many Member States and have access to a large number of potential victims. Trafficking for labour exploitation threatens to infiltrate the legal economy, where it lowers wages and hampers economic growth’. The same report, notes that that the migration crisis has not had yet a significant impact on trafficking for the purpose of labour exploitation in the EU. Numerous reports refer to the role of labour inspectors to detect victims and/or increased cooperation between law enforcement and labour inspectorates (e.g. AT, BE, EL, FR, HU, LT, LU, LV, NL, UK).

The role of debt bondage as a means has been stressed (e.g. IT), as well as that of bogus self-employment. BE reports that ‘According to the Social Inspectorate, so-called “P.O. box companies” are a real problem as regards posted workers. This kind of company is set up in a sending country, with the goal of purposefully circumventing the social security legislation and labour law in a very specific host country in general. It is therefore obvious that this type of structure has absolutely no place in the ideology of the European legislator and completely erodes the principle of the free movement of services. This bogus form of posting implies that the posting is false; in reality, the workers only provide their services for a Belgian company. Therefore, this means that these workers must be covered by Belgian social security’. Joint EU-wide operation by labour inspectorates and law enforcement authorities Europol has supported an EU-wide operation carried out by labour inspectorates and law enforcement authorities targeting organised crime groups trafficking vulnerable people for the purpose of labour exploitation. During the operational activities taking place between 28 May and 5 June 2016, two crime areas - trafficking in human beings and facilitated illegal migration - were targeted with actions carried out in dozens of key geographical hotspots (airports, border crossing points, etc.) where the likelihood of identifying potential victims of trafficking as well as traffickers and smugglers was higher. During the span of the action week, 6 709 individuals were controlled, alongside 4 156 vehicles and 2 271 companies. As a result of these checks, 47 suspects were arrested for labour exploitation and 275 victims identified and safeguarded. Data gathered during the operation has led to the launch of 23 new investigations in order to identify further suspects and victims linked to trafficking cases across the EU. Law enforcement authorities, immigration services and labour services from 21 countries joined forces for this operation. This was the first time that labour inspectors across the EU cooperated so closely with law enforcement authorities in a coordinated way to identify, safeguard and protect victims of labour exploitation. The operational activities targeted different sectors such as transportation, agriculture, construction, textile, food and catering industry as well as commercial activities. The competent authorities looked not only into key industries where victims are being exploited or are at great risk, but also into recruitment websites that may be being used to advertise jobs that result in victims being exploited and into suspect businesses operating across the borders. Moreover, controls took place at border crossing points in countries of origin, transit and destination. The exchange of labour inspectors between countries of origin and destination and the deployment of Member States delegates to the coordination centre set up at Europol's headquarters during the action week have significantly contributed to the success of the actions linked to trafficking in human beings. TeamWork! Manual Strengthening EU cooperation against trafficking in human beings for labour exploitation was a priority of the Netherlands presidency of the Council of the European Union. The TeamWork! Manual for experts on multidisciplinary cooperation against trafficking in human beings for labour exploitation, published during the presidency, contains suggestions and advice based on contributions from all EU Member States, and more than 80 examples of cases and working practices. They cover many different aspects of addressing trafficking for labour exploitation through multidisciplinary cooperation, both at the national level and across borders, including prevention, investigation and prosecution of trafficking in human beings for labour exploitation and support and assistance for victims. The manual contains advice for twelve types of organisations, both governmental and non-governmental. The workshops held during the TeamWork! conference on 18-19 January 2016 and the council conclusions subsequently adopted by the JHA Council cover a similar range of aspects of addressing trafficking in human beings for labour exploitation and of roles that different kinds of organisations can play. Substantial funding has been allocated by the EU to address this form of exploitation in the last decade. In terms of funding, as demonstrated in the Commission’s Comprehensive Policy Review: ‘A higher proportion of EC funding is awarded to funded projects on trafficking for labour exploitation (14%) than to those on trafficking for sexual exploitation (7 %). This is despite the fact that an equal proportion of funded projects focus on trafficking for labour exploitation (12 %) as trafficking for sexual exploitation (14 %). The average EC funding per project on labour exploitation was double the average EC funding per project on sexual exploitation (EUR 569,308 and EUR 231,429 respectively)’. 2017 Communication Deliverables On global value and supply chains, in 2017 the Commission presented the Staff Working Document on ‘Sustainable garment value chains through EU development action’, which presents an overview of the complex garment sector and the challenges it faces, and outlines a strategy for an effective EU development cooperation response. It focuses on three priorities: economic empowerment of women, who are 75 % of garment work-force; decent work and living wages; and transparency and traceability in the value chain. Transparency is particularly important due to the fragmented production of the sector and the widespread practice of subcontracting. In this context, the Commission approved four new projects related to the garment sector, targeting in particular Bangladesh, Burkina Faso, Mali and Pakistan. These projects of around €45 million will contribute to improve sustainable business practices and working conditions in producing countries. The Commission is further finalising a call on ‘Increasing Knowledge, Awareness, Transparency and Traceability for Responsible Value Chains in the Cotton and Garment Sector’ incl. action on enhancing the knowledge, awareness, and global advocacy on social and environmental conditions in the garment value chains (of EUR 5.5 million). To this end, the EU will focus its development cooperation and financial support to improve sustainable business practices and working conditions in producing countries, promote best practices for social and environmental standards, and reach out to consumers to raise awareness about how clothes are made and promote responsible choices.

2.2.3. Other forms of exploitation 2.2.3.1. Trafficking for forced criminality and forced begging A number of Member States observe that trafficking for forced criminality and forced begging being is increasing. In 2015-2016, other forms of exploitation accounted for around a quarter (18%) of the registered victims. This form included forced criminality and forced begging among others. The involvement of minors is also reported (e.g. AT, EL, FR). Regarding trafficking for forced criminality, Member States report on victims increasingly used in many areas of petty crime such as pick pocketing, property crime, shoplifting, and benefit fraud. Other types of forced criminality linked to crimes related to customs and borders have also been reported (e.g. LV). Regarding trafficking for forced begging, Member States report that victims originate predominantly from Eastern European countries (for example, BG, RO, SK) and that persons with substance and alcohol use disorders, physically disabled, and homeless people are particularly vulnerable, while physical and psychological force is inflicted upon them. Addressing forced begging in Sweden The intelligence unit at the Swedish Policy Authority’s Department of National Operations (NOA) collaborated with the government’s National Task Force for work with vulnerable EU citizens and the Country Administrative Board of Stockholm (CABS) – as well as with other authorities and NGOs that had come into contact with the vulnerable EU citizens with regard to begging. In the light of the current situation update presented by the Swedish police, staff at the intelligence unit also made two international study visits. One visit was made to Bulgaria and one to Romania, the aim being to collaborate and exchange information relating to the situation regarding begging and the vulnerable position in which those begging find themselves. Work meetings were held with the national units of the police authorities and NGOs in Sofia and Bucharest. 2.2.3.2. Trafficking for forced and exploitative sham marriages Europol highlights that there has been an increasing number of incidents of sham marriages in several Member States, with victims being women who are EU nationals and links this to the migration context and the increase in the number of irregular migrants seeking to transition to legal residence status after failed asylum applications. This phenomenon is reported in several narrative reports of the Member States as a growing business (e.g. BG, CY, CZ, IE, LV, SK, and PL). Victims of this form are reported to be subsequently subjected to sexual exploitation, forced child bearing and/or labour exploitation. Member States report of increasing instances of victims having entered into sham marriages or being forced into marrying non-EU nationals in order to legalise the residence in the European Union of the latter. However, they are further forced to take loans or apply for social benefits, exploiting gaps in legislation and practice. For example, BG reports that the IOM mission to Sofia observes a rising trend of marriages of convenience of Bulgarian nationals with non-EU nationals for legalizing the stay of the latter, often followed by labour exploitation or domestic servitude. Furthermore, LV reports that several cases were detected where third country nationals have used a form of marriage certificate issued by Cyprus with visible signs of falsification (names, surnames of Latvian nationals were used, as well as fictitious personal identification numbers; documents with the same registration number were issued to the various persons) to obtain residence permit in Sweden and Ireland. Spain, also, reports on a relevant pattern of different nature, whereby members of organised criminal networks select municipal authorities in which it is easy to constitute a common law marriage/cohabitation s between Nigerian women and Spanish citizens, as well as locating EU citizens willing to form such unions with trafficked women, facilitating the trafficking chain and their exploitation. Member States report having taken action, including information and awareness campaigns, as well as targeted training for civil registrars and other officials likely to come into contact with such victims (e.g. CY, IE). Addressing exploitative sham marriages in Ireland

The Civil Registration (Amendment) Act 2014 was enacted on 4 December 2014. The Act contains a provision to make it more difficult to broker a marriage of convenience thereby protecting vulnerable persons, usually women, from trafficking for the purpose of sham marriages. This provision is designed to counter the abuse of Irish marriage laws to gain an automatic right of residency in Europe. There have been a number of contacts from embassies about this and the dangers of trafficking of their nationals for the purpose of sham marriages to non-European Economic Area nationals. The provision gives Civil Registrars the power to ask questions and to inform immigration authorities or An Garda Síochána, if they have reason to believe a marriage is a sham. A Superintendent Registrar will also offer advice, ensure clarity and make the determination. The decision may be appealed to the Circuit Court. The provision also applies to civil partnerships. Operation Vantage in August 2015 and the coming into effect of new regulations in August 2015 under the Civil Registration (Amendment) Act 2014, and updated Free Movement Regulations, which came into effect in February 2016, improved situation in the response to sham marriage, with a disruptive effect on the organisers and facilitators as over 500 marriages have failed to proceed due to Garda investigations. 2.2.4. Emerging patterns of trafficking 2.2.4.1. Internal trafficking Internal trafficking, within the territory of a Member State, is reported to be on the increase. Several reports highlight that identified victims of trafficking within the country are their own citizens (e.g. BE, BG, DE, EL, EE, ES, HR, IE, FI, FR, PL, RO, SK). Some refer particularly to women and girls (e.g. ES, FR), Roma victims (e.g. BG), children (e.g. IE, PL, RO), and often with specific reference to trafficking for the purpose of sexual exploitation. For example, DE and HR report their own citizens are the vast majority of identified victims for some years during the reference period. Factors such as the economic crisis, poverty and various other vulnerability factors are reported by Member States as linked to the increase of domestic trafficking. As mentioned, 44% of the victims are EU nationals, and it is important to note that, while the migration context brought a focus on non-EU victims, Member States reports highlight patterns of domestic trafficking of their own nationals. It should, thus, be reminded that efforts to address trafficking must continue to be taken in a comprehensive manner, equally focussing on all victims, as trafficking is crime fuelled by the profits it brings to perpetrators and by the demand for services exacted by the victims. 2.2.4.2. Child trafficking Children were almost one quarter (23%) of the registered victims. Europol underlines the role that families and kinship play noting also that traffickers also target minors without family such as homeless children, those in juvenile foster care, and in orphanages, from where they are encouraged to escape with their assistance. Member States express concerns over child trafficking, reporting that EU and non EU children are predominantly trafficked for the purpose of sexual exploitation, disproportionately affecting girls (e.g. BE, DE, IT, FR, RO), including for the production of Child Sexual Abuse Material (CSAM), as well as forced begging, forced criminal activities, forced marriage (e.g. BE, EL, FI, SI), and more. Member States generally report that the age of victims is dropping, and all the more younger victims are identified. The particular vulnerability of children from Eastern European countries is also mentioned (e.g. BE, IT, DK), as well as that of children from Roma communities (e.g. AT, BE, BG, FR, IT, NL), with traffickers reportedly being from the same community. BE highlights that Roma girls are also often trafficked for multiple forms of exploitation at the same time, such as: forced marriage, domestic servitude, sexual exploitation (and/or abuse). Civil society echoes this concern, highlighting that forced marriage also facilitates further exploitation. Child Victims of Sexual Exploitation According to national data referred to in GRETA reports the majority of girls fall victim to trafficking for the purpose of sexual exploitation, including the production of child abuse material, but this form of trafficking affects boys as well. Children are also subjected to trafficking for the purposes of forced labour, forced begging, forced criminal activities and domestic servitude. Further, some countries report cases of trafficking of girls for the purpose of forced marriage. Children are being trafficked transnationally as well as internally; for example, in Romania the share of internal trafficking amongst children identified as victims amounted to 78%. In Bulgaria, the share of internal trafficking is also considerable (around 45%). The number of UK children trafficked internally for the purpose of sexual exploitation has been on the increase. (…) Amongst particularly vulnerable groups, Member States list children in social care institutions (e.g. HU, LV, NL, SK). Furthermore, in the context of migration, the European Border and Coast Guard Agency highlights that girls are disproportionately victims of trafficking for the purpose of sexual exploitation.

The EU legal and policy framework is gender specific and child sensitive. A number of provisions of the Anti-trafficking Directive are based on the best interest of the child, and establish additional protections for all child victims, regardless of their nationality or status. Addressing child trafficking has been at the core of EU anti-trafficking agenda since 2012, and key deliverables of the EU Strategy concerned children, and the 2017 Communication further takes into account their vulnerability. Funding continues to support relevant action. According to the Commission’s Comprehensive Policy Review, 23% of the projects funded in the period 2004-2015 concerned children, including on identification, child protection systems, asylum, guardianship, and provision of information, receiving 19% of the total EC funding allocated, and counting as the second most funded group of projects. As set forth as a cross cutting priority in the 2017 Communication, the Commission will continue supporting anti-trafficking priorities and objectives, taking into account vulnerable groups, such as children, as well as addressing the gender dimension of the crime. The Commission values the role of civil society organisations in the joint efforts to address trafficking in human beings, and continues to engage with NGOs working in the field of child trafficking as well as child rights organisations, including in the context of the EU Civil Society Platform against trafficking in human beings. To this end, a targeted call for expression of interest was dedicated to organisations working with child victims, and workshops concerning child trafficking have been organised in the context of the biannual meetings of the Platform. Child trafficking remains one of the priorities of the EU policy cycle for organised and serious international crime 2018-2021, which largely determines the work of Europol for the coming years. This is in line with Commission's policy priorities and the Commission continues to support Europol and law enforcement authorities, as well as other relevant EU Agencies in their efforts. 2017 Communication Deliverables As per priority B ‘Provide better access to and realise the rights for victims of trafficking’, work is ongoing for developing, in cooperation with the European Agency of Fundamental Rights, a practical guidance to enhance inter-agency and transnational cooperation aiming to prevent child trafficking of EU children, ensure protection of child victims, find durable solutions and safeguard their rights under EU and international law. EU-wide Action week against child trafficking During the week of 2 July 2018, law enforcement officers from 22 Member States, other European countries and partner agencies actively participated in a European Multidisciplinary Platform Against Criminal Threats action on child-trafficking. As a result, 51 children and 72 adults were identified as potential victims of trafficking. The youngest child was only two 2 years old. The children were exploited for labour, forced begging and sexual purposes. Several links to migrant smuggling and document forgery were also identified. 45 new cases have been initiated; 24 suspects were arrested for trafficking in human beings offences; and a further 61 suspects were arrested in relation to other crimes. The actions focused mainly on hotspots for sexual exploitation, forced begging and forced criminality (e.g. pickpocketing and minor thefts), and intensified activities at border crossing points. As the identification of victims of trafficking in human beings remains very challenging, particularly the identification of child victims, many participating countries also undertook prevention and awareness raising activities. 2.2.4.3. Vulnerability of Roma victims Over the years, the European Commission has highlighted the need to address the trafficking in Roma people, including the first Progress report, the Study on High risk groups, the study on Comprehensive policy review of EC funded anti-trafficking projects and in the 2017 Communication.

While the Commission has no available statistical data on victims of trafficking based on ethnic backgrounds, several Member States reports highlight the heightened vulnerability of people from Roma communities, especially women and children (e.g. BE, BG, FR, NL, SI), with traffickers exploiting kinship. Women and girls with Roma background are reportedly victims of trafficking for sexual and labour exploitation, but also for the purpose of exploitative sham marriages. Regarding trafficking for sexual exploitation, FR for example reports that prostitution from Eastern European countries concerns almost exclusively the Roma community from BG and RO. Member States report (e.g. FR, IT) that the recruitment is often intra-community, and organised around the head of the clan. According to Member States, the analysis of the investigations on sexual exploitation cases in Roma communities once more indicates the strong gender dimension of this phenomenon. It demonstrates that the exploitation in prostitution is often perpetrated by the men in the group, and the profit generated are paid directly to the pimps, who re-invest in luxury cars or real estate in their home country. Girls and women often of Roma origin that have lived in an unhealthy family environment, of low social status and education, are forced into street prostitution (e.g. BG). Member States also report on Roma female victims of trafficking for the sale of new-born babies (e.g. BG) and a new pattern of trafficking for forced underage marriage of girls usually in Roma communities (e.g. SI). Regarding the latter, SI reports that in 2015 the first final judgment was recorded on trafficking in human beings for the purpose of slavery, which reflected the circumstances and exploitation purposes of forced marriage. Roma children from Eastern Europe being forced to thefts and pick pocketing by adults are also reported (e.g. NL). In this context, GRETA reports that ‘Although the lack of official disaggregated data according to ethnicity precludes a reliable assessment of the occurrence of human trafficking in the Roma communities, there is evidence that Roma, in particular Roma women and children, are highly vulnerable to trafficking due to structural forms of ethnic and gender discrimination, poverty and social exclusion which result in low educational achievement, high levels of unemployment, domestic violence and difficult living conditions that affect predominantly women and children’. GRETA further underlined that several of its reports published in 2016 refers to cases of trafficking for the purpose of forced begging of Roma children (e.g. BG, HR), and for the purpose of early/forced marriage of Roma girls (e.g. HR) Unregistered children are at higher risk of being trafficked. GRETA’s reports note that the absence of registration at birth affects mainly children from the Roma communities. Methodological Guidance for the Identification of Victims of Trafficking in Roma Communities The Office of the Plenipotentiary of the Government of the Slovak Republic for Roma Communities in cooperation with the Ministry of the Interior prepared the publication ‘Methodological Guidance for the Identification of Victims of Trafficking in Roma Communities’. The aim of this handbook is to address prevention and raise awareness by working with this vulnerable group in order to improve the identification of victims of trafficking and to participate in a specialized programme as well as to strengthen preventive activities by raising awareness of this vulnerable group. This Methodological Guidance was distributed to all field social workers within the Field Social Work national programme. In June 2016, the Commission adopted a Communication assessing the implementation of the EU Framework for National Roma Integration Strategies and the Council Recommendation on effective Roma integration measures in the Member States. It further highlights that Roma women face multiple forms of discrimination (violence, trafficking in human beings and underage and forced marriages, and begging involving children), highlighting a need for targeted measures as part of a gender specific and child sensitive strategic approach. Amongst other things, the Communication underlines that action in these areas is largely lacking, despite indications of an increase in the trafficking of Roma for these purposes, and calls on Member States to address several urgent priorities, including: to enforce anti-discrimination and anti-racism and xenophobia legislation and safeguards at national and local levels by, amongst others, addressing trafficking in human beings with gender specific and child sensitive measures. According to the Commission’s Comprehensive Policy Review, one of the often identified vulnerable groups to trafficking in the funded projects in the data set was people of Roma descent, especially Roma children. A number of funded projects addressed trafficking of Roma people, especially children. The types of activities included in these projects were awareness raising, training and the development of various toolkits for a multi-agency audience. Underpinning most funded projects was a desire to improve harmonisation and coordination between source and transit/ destination countries. Some funded projects had the safe return of Roma children to their country of origin as their primary focus. All positioned children of Roma origin, principally from Bulgaria and Romania, to be especially vulnerable. The Communication of the European Commission on the Midterm review of the EU framework for national Roma integration strategies highlights its work to tackle multiple discrimination against Roma children and women, as groups exposed, among others, to high risks of violence and trafficking in human beings and to ensure that they are better protected. In its 2016 resolution, the European Parliament highlighted the fact that Roma people are particularly vulnerable to trafficking in human beings due to their social and economic marginalisation, and pointed to the need of data regarding Romani women and children. 2.2.4.4 Persons with disabilities and dependencies and emerging patterns Member States (e.g. AT, BG, FR, HU, IT, LT, LV, NL, PL, SK) report that traffickers increasingly target persons with physical or mental disabilities and persons with substance and alcohol use disorders. These categories are reported to have been trafficked for forced begging with perpetrators often sharing the same nationality of the victims (mainly Romania, Eastern Europe), but also sexual exploitation (e.g. NL). Homeless (e.g. HU, SK) and people addicted to drugs or alcohol (e.g. FR, HU, SK) are also indicated as targeted. Victims are trafficked domestically and internationally. Exploitation of these categories of people is further reportedly linked to drug trafficking and criminal gangs in their pursuit of profit maximisation. In addition to the emerging patterns and trends highlighted above, Member States have mentioned cases of trafficked pregnant women for the purpose of selling their new-borns (e.g. BG), “bitumeurs” travellers (e.g. FR), trafficking for forced criminality with crimes in the sphere of customs trafficking for organs or human tissue removal (e.g. BG, PL), heavy loan commitments became new vulnerability factor (e.g. BG), and the increase in the number of young perpetrators (e.g. NL) at the time of committing the crime. Another pattern reported is a shift from random to targeted recruitment, focusing on specific groups (e.g. IT, SI) in response of changes in the demand (e.g. IT, RO) or as a means of deceiving controls by law enforcement (e.g. IT).

3. TRAFFICKING IN THE CONTEXT OF INTERNATIONAL MIGRATION Member States and other sources report concerns on criminal networks involved in trafficking in human beings taking advantage of the irregular migration routes. Traffickers take advantages of opportunities and vulnerabilities, including the migration challenges, but it is also important to note, further to recalling that many of the registered victims are EU nationals, including those trafficked within their own Member State, that non EU victims registered in the EU do not only come from countries of first arrival. Some Member States report on increasing numbers of Nigerian victims trafficked mainly for sexual exploitation, and on decreasing age (e.g. BE, DK, EL, ES, FI, IT). Member States experiencing arrivals of mixed migration flows (e.g. EL, IT) point out to the difficulties in establishing identities of migrants and identifying or detecting victims or potential victims of trafficking. They would also welcome more focus on victims of trafficking in the context of responses to the migration crisis (e.g. EL). Frontex Risk Analysis Report 2018 In the Risk Analysis Report 2018 the European Border and Coast Guard Agency underlines that: [Victims] come in large numbers from Nigeria, but also from such countries as Cameroon, Ghana, Guinea, Côte d’Ivoire and Sierra Leone. (…) The Nigerian victims are mostly women and increasingly younger girls, many of whom are minors. Although trafficking from Nigeria has, for decades, supplied the European sex market, the spike in the number of Nigerian females arriving in mixed migration flows to Italy (and, to a lesser extent, Spain), has brought the phenomenon of trafficking in human beings from Nigeria to light. Currently, Nigeria represents the top nationality of third-country victims of trafficking in human beings in the EU. The need to address trafficking in human beings in the context of international migration has been recognised in the New York Declaration, and the negotiations leading to the adoption of the Global Compact for Safe, Orderly and Regular Migration (GCM) with a dedicated objective and actionable commitments. According to UNODC 2016 Global Report ‘Although many cases of trafficking in persons do not involve the crossing of international borders – some 42 per cent of the detected victims are trafficked domestically - there are some links between cross-border trafficking and regular migration flows. Certain trafficking flows resemble migration flows, and some sizable international migration flows are also reflected in cross-border trafficking flows. The analysis of country-level data on detected trafficking victims and recently arrived regular migrants reveals that trafficking in persons and regular migration flows broadly resemble each other for some destination countries in different parts of the world. Many factors can increase a person’s vulnerability to human trafficking during the migration process, however. The presence of transnational organized crime elements in the country of origin, for instance, is significant in this regard, and a person’s socio-economic profile can also have an impact’. 2017 Communication Deliverables The Commission continues to publish calls for proposals to support the integration of non-EU nationals who are victims of trafficking under the Asylum Migration and Integration Fund (AMIF). Priority five of the 2017 AMIF call for Union grants followed up to the findings of the first progress report, and the Comprehensive Policy Review , including in encouraging proposals targeting, but not limited to, trafficking for the purpose of sexual exploitation, as well as taking into account the Commission’s decision of designating 2017 as year of focused action to combat violence against women and girls. Out of 21 proposals for this call, for 8 proposals the signing of the grant agreement is under process for up to a total amount of EUR 3.548.111. Priority three of the 2018 AMIF call further aims at strengthening relevant stakeholders in implementing the Anti-Trafficking Directive, with respect to provisions on assistance and support for victims (Art. 11, 13 and 14), taking into consideration the gender specific nature of this phenomenon as well as the high-risk groups, including children, and the sectors it affects. Considering the outcomes of the first progress report, further efforts have been promoted to support national authorities in addressing trafficking in human beings in the context of the hotspots approach. Two thematic workshops have been organised in close cooperation with the EU Regional Task Forces in Italy and Greece, including relevant EU Agencies and national authorities (respectively, on 13 December 2017 and 7 May 2018). The focus was placed on operational efforts to improve early detection and appropriate referral of presumed victims, ensuring a gender specific and child sensitive approach, and on enhancing investigations of cases of trafficking in human beings in mixed migration flows. It is encouraging to witness progress in identifying non-EU national victims of trafficking. At the same time, the Commission underlines the importance of ensuring that this is not done to the detriment of other victims, including EU nationals. 3.1. Conceptual clarity – Trafficking in human beings and migrant smuggling

In order to ensure better policy and funding allocation, the Commission has consistently stressed, in line also with the findings of the first progress report, the need for conceptual clarity when it comes to trafficking in human beings and migrant smuggling. As the UNODC 2016 Global Report notes ‘not all trafficking victims are smuggled migrants […] While trafficking in persons is a crime that aims to exploit a person who may or may not be a migrant, smuggling of migrants is always cross-border and does not, by definition, involve the exploitation of the migrant’ It is thus important to stress that while linked, they are different crimes that require different responses with regard to the protection and assistance needs of trafficking victims and smuggled migrants. Civil society submissions further stress the need to ensure conceptual clarity, and the significant implications on the rights of the victims and the obligations of the Member States. Europol indicates that in 25% of the cases migrant smuggling suspects have also links with trafficking in human beings, referring to migrant smuggling, together with document fraud, as supporting offences for trafficking in human beings, a way of enabling the different stages of the trafficking cycle. In this respect, Europol also underlines that “it is important not to confuse the two concepts of smuggling and trafficking in human beings, as trafficking involves the use of threats or force, or other forms of coercion to exploit the person”. It has to be ensured that trafficking in human beings is appropriately addressed in the context of migration, taking into account emerged patterns, such as the disproportionate targeting of women and girls trafficked for the purpose of sexual exploitation. 3.2. Trafficking and international protection Links between trafficking and asylum continue being reported by the Member States (e.g. AT, EL, ES, IT), either in instances of increase in numbers of victims of trafficking found in asylum systems or where organized criminal groups abuse asylum systems. In this respect, Europol has warned that ‘OCGs involved in trafficking in human beings also continue to exploit asylum provisions in order to traffic non-EU nationals into the EU. In many occasions, victims are provided with fraudulent documents to conceal their real identity and age’. Member States report of instances where traffickers require victims to apply for international protection, in an attempt to regularise their status in the country (e.g. ES), or victims are instructed by traffickers to apply for asylum under false declarations (e.g. AT). Pending a decision on the asylum claim, traffickers reportedly take advantage of the circumstances, as exploitation might still take place while victims receive accommodation in temporary reception centres (e.g. IT). AT reports on victim protection services identifying links with asylum procedures: a) victims escape from their traffickers in Austria, or another EU Member State, and subsequently apply for asylum in Austria; b) victims are instructed by their traffickers to apply for asylum in Austria, with false declarations (see section on Nigerian or Chinese women above); c) victims are recruited by traffickers after their asylum application due to their precarious situation; and d) people who resorted to smugglers to bring them to a specific location in Europe, that end up being trafficked and heavily exploited on their way. Issues arise as to the recognition of the status of victim based on exploitation that took place outside the country in which the victims are present (e.g. AT, EL, FI, IT, SE). IT reports that, to address these challenges, Territorial Commissions use guidelines developed in 2016 with UNHCR for identifying and granting victim status. FI reports of new legislation having entered into force in 2015, enabling the assistance system for victims of trafficking to formally identify persons as victims of trafficking, if they have been subjected to exploitation abroad. In this respect, FI reports that an increasing percentage of decisions by the Finnish immigration Service's concern Nigerian women subjected to trafficking for sexual exploitation in Italy. In the autumn of 2016, the Finnish Non-Discrimination Ombudsman published a report on the practices in applying the Aliens Act to victims of trafficking with a Nigerian background. Based on the data consisting of residence permit decisions (2015 – July 2016), the Finnish Non-Discrimination Ombudsman concluded that the practice in applying the Aliens Act is partially unpredictable and inconsistent. IT reports that asylum claims lodged by (potential) victims of trafficking show common patterns, depending on the gender and the origin of the victim: women from Nigeria mainly base their claims on fear of persecution related to sexual and gender based violence, including: forced marriage, domestic violence, female genital mutilation and rape, cult-related violence, inter-religious conflicts, sexual orientation and gender identity, presence of terrorist groups in parts of their countries of origin, such as Boko Haram. Men (potential) victims of trafficking from Bangladesh, are reported claiming they left the country of origin fearing persecution on the grounds of their political opinion or family disputes. EASO continued its work on the asylum and trafficking nexus, and organised its annual conferences on trafficking in human beings with thematic focuses on common challenges and possible practical responses to the current situation of asylum-seeking victims of trafficking with a focus on the migratory crisis, as well as on trafficking in human beings in mixed migration flows. Victims of trafficking in human beings who are refugees The UN Inter-Agency Coordination Group against Trafficking in Persons (ICAT) notes that while not all victims of trafficking are refugees, depending on the circumstances, some victims of trafficking will qualify for refugee status under the 1951 Refugee Convention or regional refugee instruments. It goes on to stress that “Refugees and asylum-seekers are particularly vulnerable to abuse and exploitation at different stages of their flight, including at their destination. They may be compelled to use smugglers as their only means to flee persecution, conflict and violence without travel or identity documents, to cross dangerous terrain and to circumvent border controls that prohibit access to asylum-seekers, exposing them to risk. Once at their destination they may encounter discrimination, restrictions on freedom of movement, inadequate or non-existent livelihood or educational opportunities, and experience limited access to humanitarian assistance or other support systems. This can push them to solicit smugglers in order to move in search of better protection and/or opportunities, or into the hands of traffickers who may prey on refugees and asylum-seekers residing in camps, reception centres or other settlements”.

4. PROFILES AND HOW THE TRAFFICKERS WORK Traffickers adjust constantly the way they operate. Member states have reported extensively on the how traffickers operate. Some reports observe a shift towards limiting the use of physical force and using more psychological control. Nevertheless, the use of severe physical violence is also reported. Member States highlight changes in the modus operandi with respect to less visible forms of coercion, a certain degree of possibility for movement, less evident forms of intimidation, threats, and a shift towards psychological violence (such as BG, CY, IT), threat or menaces to the victim or the family of the victim (e.g. IT), especially in trafficking for sexual exploitation. Some Member States (e.g. LT) report that victims were recruited through direct, eye to eye contacts or through phone-calls. Regarding trafficking for sexual exploitation, Member States’ reports indicate the coexistence of well-structured organised crime networks (.g. ES, IT), with ‘cells’ in origin, transit and destination countries (e.g. IT), with smaller groups (e.g. RO) and less structured methods (e.g. BE), and individual offenders (e.g. AT), loosely formed criminal groups (e.g. LT). Some Member States (e.g. CZ) also report that alongside subtle forms of coercion in case of sexual exploitation, the offenders used threatening and physical assault as a means to coerce the victim. Moreover, the victims were forced by the offenders to make use of drugs in order to ensure their obedience as a means of coercion. According to Europol ‘the sexual exploitation of EU nationals no longer relies predominantly on the use of violence and coercion towards victims. Some OCGs are increasingly relying on threats of violence towards victims and their families rather than attacking the victim. Victims originating from outside the EU are still routinely subjected to violence, debt bondage, passport confiscation and other forms of coercion as an integral part of trafficking modi operandi’. Some Member States report on using deception and emotional dependency of victims (some refer to it as ‘loverboy method’). For example, AT reports that under the pretext of a future life together and the prospect of earning a considerable amount of money in a short time, victims are persuaded to work in prostitution in Austria. When the victims realize that they are not allowed to keep any income or when they express the wish to stop working in prostitution, traffickers use threats or physical violence. Member States also stress the role of kinship in recruitment, such as families, relatives, friends or acquaintances. Many Member States report that traffickers come from the same background as victims. There is also an increase in own nationals treated as suspects by Member States. In one case (e.g. DE) this was indicated as the largest reported nationality group. Transnational organised crime is highlighted in reports by Member States (e.g. ES, IT, AT, FR), and some underline that multinational networks, at times consisting of different ethnic groups, are often specialised (e.g. IT) on a territory or a specific phase of the trafficking chain (transfer, document fraud, exploitation). According to analysis by the IT authorities, with respect to trafficking sexual exploitation, investigations have also documented the actual sale of young victims between groups of different nationalities (for example, between Albanian and Romanian groups). The criminal markets of destination are also those of drug trafficking, sexual exploitation and prostitution, labour exploitation in agriculture and construction, begging and criminal activities that bring profits to traffickers. In this context, Romania reports having also observed the mobility and flexibility of criminal groups that tend to act concurrently in several countries, especially in countries where there is demand in the sex industry, labour market, and where conditions conducive to juvenile delinquency exist. There is also a shift of criminal groups to the sexual exploitation of victims internally, with minor victims being preferred because they are easily recruited and controlled/exploited (e.g. RO). With regard to the new trends, Member States report on the increasing participation of women in the criminal organizations for trafficking in human beings assuming increasingly skilled roles in the recruitment, transfer, subjugation and surveillance of the victims. This trend involves all ethnic groups, albeit with varying intensity, predominantly in Nigerian criminal groups. United Nations Office on Drugs and Crime Global Report 2016 The UNODC Global Report 2016 report states that ‘Traffickers and their victims often come from the same place, speak the same language or have the same ethnic background. Such commonalities help traffickers generate trust to carry out the trafficking crime. Being of the same gender can also enhance trust. Data from court cases indicate that women are commonly involved in the trafficking of women and girls, in particular. Most of the detected victims of trafficking in persons are females; either women or underage girls. While traffickers are overwhelmingly male, women comprise a relatively large share of convicted offenders, compared to most other crimes. This share is even higher among traffickers convicted in the victims’ home country. Court cases and other qualitative data indicate that women are often used to recruit other women. Family ties can also be abused to carry out trafficking crimes. For instance, this is seen in cases of relatives entrusted with the care of a family member who break their promise and profit from the family member’s exploitation’. 4.1. The use of information and communication technologies

According to Europol, the internet provides offenders and potential offenders with an environment in which they can operate with an enhanced level of safety and anonymity. Member States highlighted the use of internet and social networking tools by traffickers for the recruitment of victims (e.g. BE, BG, CY, FR, IE, IT, LV, NL, PL, RO), including children (e.g. HR), for organizing transportation and logistics (e.g. BG), for the exploitation of the victims (e.g. IT, DE), including through dissemination and production of pornographic material (e.g. RO), and as a marketing platform for prostitution in particular when the sexual exploitation of the victim takes place in flats and hotels (e.g. DE) and for controlling victims (e.g. BG). The use of encryption technology by traffickers is also reported as a challenge to be addressed (e.g. PL). Europol reports that ‘a growing amount of illicit trade now has an online component, meaning that cybercrime investigative capabilities are increasingly in demand in all serious organised crime investigations. Dark net markets remain a key crosscutting enabler for other crime areas, providing access to, amongst other things, compromised financial data to commit various types of payment fraud, firearms, counterfeit documents to facilitate fraud, trafficking in human beings, and illegal immigration’. EIGE furthermore stresses that the gender dimension of cybercrime and the various forms of cyber violence against women and girls, from trafficking of women and girls, to cyber stalking, non-consensual pornography (or ‘revenge porn’), gender-based slurs and harassment, ‘slut-shaming’, unsolicited pornography, ‘sextortion’, rape and death threats, ‘doxing’. EIGE highlights the importance for EU level institutions and agencies combatting cybercrime to tackle gendered forms of cybercrime; particularly the online luring or ‘recruitment’ of women and girls into harmful situations such as trafficking. GRETA further notes the growing trend of recruitment via the Internet, including on social media, through which a larger number of potential victims can be targeted. 5. PREVENTING TRAFFICKING IN HUMAN BEINGS BY COUNTERING THE CULTURE OF IMPUNITY Countering the culture of impunity and increasing accountability remains one of the key priorities areas of the 2017 Communication. Disrupting the business model, following the money and untangling the trafficking chain remains in focus, as this Communication stresses that profits on lawful and illicit markets and demand for the services and goods provided by victims of trafficking in human beings remain high wherever a culture of impunity for both perpetrators and users prevails. As noted in the 2017 Communication ‘given the harm caused to the victims, prevention should remain a cornerstone of the EU anti-trafficking action’. Furthermore, prevention remains a pillar of Anti-Trafficking Directive and Member States have a legal obligation as per its Art. 18 to take appropriate measures, such as education and training, to discourage and reduce the demand that fosters all forms of exploitation related to trafficking in human beings; to take appropriate action, including through the Internet, such as information and awareness-raising campaigns, research and education programmes, where appropriate in cooperation with relevant civil society organisations and other stakeholders, aimed at raising awareness and reducing the risk of people, especially children, becoming victims of trafficking in human beings; to promote regular training for officials likely to come into contact with victims or potential victims of trafficking in human beings; and to consider taking measures to criminalise the use of services exacted by victims of trafficking. As the first progress report notes ‘Trafficking in human beings is a demand and profit driven crime. Prevention must be placed in the wider context of a crime being driven by profits and demand. A human rights-based approach focusing on victims needs to address prevention appropriately and effectively, and discourage the demand that fosters all forms of trafficking, as clearly stipulated in the Anti-trafficking Directive. This means not only addressing the root causes that make people more vulnerable to trafficking – such as poverty, gender inequality and violence against women, ethnic discrimination, societal marginalisation, irregular migration – but also ensuring that those who profit from the crime and exploit the victims are brought to justice’. Addressing trafficking in human beings is also part of the EU wide efforts towards the realisation of an effective and genuine Security Union, aimed at guaranteeing a high level of security for the people living in the EU. 2017 Communication Deliverables As per priority A of the 2017 Communication ‘Stepping up the fight against organised criminal networks by means including disrupting the business model and untangling the trafficking chain’, the Commission has encouraged and assisted EU national authorities through its coordination activities (including the meetings of the NREMs), as well as with funding. The 2017 ISF-Police a call for proposal for Union grant was published to support priorities on ‘Profile/modus operandi of traffickers/criminal organized groups/links with other forms of serious and organized crimes, prosecutions and convictions’ and for ‘Actions focusing on the wider trafficking chain, including the profits involved in trafficking in human beings’. Funding has thus become available to national authorities and civil society for transnational actions in this context. For the 2017 call, four proposals were awarded a total budget of 1.293.361 EUR. Many Member States (e.g. BG, FR, LT, LV) report on vulnerability factors making people prey of traffickers, such as socio-economic vulnerabilities, including poverty, poor education, difficult material circumstances, homeless, addicted, disabled, minority origin, migration, children in institutional care and gender inequalities. It is important to note, however, that vulnerabilities do not alone result in trafficking. Trafficking is also driven by huge profits it renders to OCGs. As Europol notes the use of legal businesses to cover the exploitative activities is quite common for traffickers. Suspects often buy, rent and make use of legal companies to cover their illicit activities and launder the profits. Among the cases reported, restaurants, hotels, cocktail bars, dance clubs, shops, car retailers, car washes, etc., were used to organise sexual encounters and for money laundering purposes. Some of the reported groups systematically used complicit employment companies to obtain legitimate work contracts for their victims. In countries where prostitution is legal, suspects were able to exploit minors alongside adults in window prostitution, sex studios, nightclubs, etc., often with the support of the business managers, as prostitution of minors can be very profitable for human traffickers, as clients are generally prone to pay more to have sex with a child.

As Frontex Risk Analysis 2018 highlights ‘trafficking in human beings is currently one of the most profitable forms of organised crime, generating billions of euros for traffickers. Europe, which comprises some of the wealthiest nations in the world, has long been an important market for the exploitation of victims, particularly through sexual exploitation, forced labour, exploitation of criminal activities, begging and illegal adoption. The high levels of supplying origin countries, coupled with the demand for cheap labour and sexual services in the destination countries, are among the most common root causes of human trafficking’. This section examines progress in investigating, prosecuting and convicting the crime, as well as measures taken to address prevention and demand reduction. 5.1. Encouraging the criminalisation of the use of services provided by the victims Further encouraging those Member States, to the extent they have not done so, to criminalise those who knowingly use the services provided by victims of trafficking is at the core of the European Commission priorities to prevent trafficking in human beings as per the 2017 Communication. Article 18(4) of the Anti-trafficking Directive encourages Member States to consider criminalising the use of services of victims of trafficking in the knowledge that they are trafficked. Furthermore, the analysis in the Commission’s ‘Users’ Report , which assesses the impact of existing relevant national legislation, reveals a diverse legal landscape within the EU and notes that national law fails to effectively contribute to discourage demand for services, which are the objects of exploitation of trafficking in human beings. A new question in the Commission data collection exercise was to ask member states for information on the police contacts, prosecutions and convictions related to the criminalisation of the users of services exacted from victims. These may be users of services provided by victims of trafficking for sexual or labour exploitation or other forms. Member States have reported mainly on measures related to trafficking for sexual and labour exploitation. Three Member States provided data on this offence: Italy, Romania and Finland. In 2015-2016, 2 suspects (persons brought into formal contact with the authorities), 135 prosecutions, and 18 convictions were made in the EU concerning the use of services, which are the objects of trafficking in human beings. Enforcing the law has a preventive effect, as Eurojust states in its contribution for the progress report its support to Member States in investigating and prosecuting trafficking cases, and thus assisting them in holding the perpetrators accountable, increases both general and specific deterrence and thus constitutes an element of prevention. 2017 Communication Deliverables As per the 2017 Communication, the Commission will further encourage those EU Member States, to the extent they have not done so, to criminalise those knowingly using services of victims of trafficking.

As noted in the Commission first progress report, such form of criminalisation, though with a specific and narrower scope, has already been introduced and implemented in another EU legal instrument, the Employers’ Sanctions Directive, which has established that Member States must impose criminal sanctions on employers, who use the work or services of illegally staying third-country nationals in the knowledge that they are victims of trafficking. In addition, the Child Sexual Abuse Directive obliges Member States to criminalise engaging in sexual activity with a child where recourse is made to child prostitution and to provide for minimum levels of imprisonment penalties depending on the age of the child, thus targeting the client of children in prostitution. This should in turn help indirectly the fight against child trafficking for sexual exploitation, as national authorities do not need to prove the existence of the different components in the trafficking offence, nor the awareness of the client about the trafficking condition of the victim. The report by RO stresses that in absence of measures for discouraging demand organised criminal groups demonstrate flexibility and turn into new destinations for sex markets with higher demand, rendering investigations less effective. The Italian report notes that a legislative amendment to this regard would be an important step forward in the fight against trafficking, as it would discourage and reduce demand. Specifically on trafficking for sexual exploitation, some Member States reported on new legislation enacted during the reference period on criminalising or associated with those who knowingly use services extracted by victims of trafficking (e.g. CY, DE, EE, IE). Some of these Member States note that it is generally too early to assess impact of such measures. Other Member States (e.g. AT, NL) fully support the aim of Article 18 of the anti-trafficking directive on prevention, including by discouraging demand, but consider that non-legislative measures, such as the provision of information and training, raising awareness and commissioning research can be very effective in this regard. The difficulty in proving the element of knowledge that the services were provided by victims of trafficking (e.g. AT, IT) is stated. Germany reports on the Prostitute Protection Act in force since 1 July 2017, introducing regulations on contracts between prostitutes and operators of a brothel or an escort agency, which aims at contributing to better preventing exploitation and trafficking in human beings. In particular, the introduction of an official licensing obligation for the operation of a prostitution establishment and the recording and documentation requirements, as well as the extensive control of the authorities, should prevent and restrict crime in prostitution, such as trafficking in human beings and forced prostitution. Furthermore, DE makes reference to a new law amending the Federal Central Register Act (Bundeszentralregister Act) and the Eighth Book of the Social Code, on the one hand, which contain a provision on the criminalisation of users of sexual services of victims of trafficking. France reports on the Act of 13 April 2016, which has strengthened the fight against the prostitution system and supports persons in prostitution. This law introduced penalisation of purchasing sexual acts provided by an adult. Furthermore, where the victim is a minor or vulnerable person, the offence of purchasing sexual act is more severely punishable. The purpose of these measures is to reduce demand, to prevent prostitution, trafficking in human being and ‘proxenetism’ (pandering) and thus make the French territory less attractive for pimps and networks. The law extends protection and rights of victims of trafficking in human beings and prostitution, putting in place measures to support them exiting prostitution, including setting up an ad hoc departmental commission for this purpose. Further, the law intends to strengthen the work against trafficking networks, as internet suppliers have to signal sites proposing paid sexual services. Ireland reports on the new Criminal Law (Sexual Offences) Act 2017, which is the most comprehensive and wide ranging piece of sexual offences legislation introduced in Ireland in almost a decade. Part 4 of the Act provides for two new offences of purchasing sexual services, in the context of prostitution and is linked to demand that fosters trafficking for sexual exploitation. The Act itself and its provisions, recognise the exploitation experienced by those involved in prostitution and decriminalises them. It enacts a more serious offence of paying for sexual activity with a trafficked person, in the context of prostitution, an offence which carries a potential penalty of up to 5 years’ imprisonment and/or a fine. In both cases, the person selling or, in the case of a trafficked or exploited person being forced to sell, the sexual service will not commit an offence. Of note, Section 27 of Part 4 requires a report after 3 years on the number of arrests during that period in respect of the new offences, as well as an assessment of the impact of the offences on those who provide sexual services for payment. According to the IE report, three years is the minimum period in which systems and practices can be effectively bedded down and operated, so that reliable conclusions can be drawn from the information gathered for the review. In this context, another example is Greece, where a Committee against Commercial Sexual Exploitation in April 2017 was established. The General Secretariat for Gender Equality, in cooperation with the Office of the National Rapporteur, has set up a Committee of Experts to review the existing legal framework on prostitution and advocate against sexual exploitation and demand for commercial sex acts. The Committee includes legal experts, academics, the anti-trafficking police unit and representatives from NGOs. The overall task of the Committee is to examine closely best practices aimed at targeting buying and selling of sexual services and put forward specific proposals for applying these practices in Greece. The Netherlands further reports that during the reference period a bill has been introduced in Parliament that aims to allow police officers to pretend to be adolescents on the internet. This should make it possible for them to catch those who try to groom children before they are able to sexually abuse these children or to exploit them in forced prostitution. Furthermore, NL informs that in 2015 the Public Prosecution Service increased the priority on the prosecution of customers paying for sex with a minor. In June 2015, the Directive for Sentence Recommendations regarding article 248b Criminal Code of the Public Prosecution Service came into force, which formulates guidelines for the prosecution of these customers. Subsequently, some prosecutions of clients of minors (under art. 248b Criminal Code) have led to a lot of publicity because of the active press policy by the Public Prosecution Service . GRETA on the criminalisation of the use of services GRETA stresses that the criminalisation of the use of services which are the object of exploitation as defined in Article 4 of the Convention, with the knowledge that the person is a victim of trafficking in human beings, can have a normative effect and increase public awareness of human trafficking issues, in addition to having a punitive function. GRETA further notes that the majority of the 25 Parties to the Convention so far evaluated under the second evaluation round have adopted provisions criminalising the use of the services of victims of trafficking, with the knowledge that the person is a victim. However, there have been very few related convictions. Taking into consideration the country reports on EU Member States published by GRETA in the period after the adoption of the Commission’s first progress report, GRETA encouraged national authorities to establish such criminal offence in all those cases where national legislation does not criminalise the use of services with the knowledge that the person is a victim of trafficking, and encouraged to extend the provision to cover all forms of exploitation in those case in which such provision exists limited to specific forms. This is the case of the country reports on Belgium France, Ireland, Poland, Spain, and Sweden. For those Member States in which such provisions exists, but limited or no information was available on implementation, GRETA encouraged to ensure they are applied, such as in the case of Latvia, Malta, Portugal, Slovenia. In two cases, further information was provided on implementation regarding Bulgaria, and Romania.

Various Member States reported on action to address impunity for users of victims of trafficking for labour exploitation. Pertaining to trafficking for labour exploitation, IT reports on the Law No. 199 of 29 October 2016, on the so-called “caporalato”, which addresses labour exploitation. The Law provides for serious sanctions (1 to 6 years imprisonment and a fine of 500 to 1000 Euros for each exploited worker) for any person recruiting, using, hiring or employing the workforce in conditions of exploitation. It establishes aggravating circumstances, if the offence is committed with violence or threats, when the number of exploited workers is more than three, when the victims are minors not of working age, when the workers are exposed to serious dangers for their health. The Law also contains indicators to detect labour exploitation, with respect to very low wages, excessive working hours, lack of rest, poor health conditions, and degrading conditions). With respect to addressing forced labour, PT reported that the Labour Code has been amended in 2016, extending the scope of the provisions on liability for relevant violations to include a broader range of entities, which are also liable for breaches committed by, as an example, subcontractors. EL further reports on joint special operations to detect victims and uncover traffickers, between the Greek Labour Inspectorate (SEPE) and the Greek Police aimed at combating trafficking in human beings for labour exploitation within the framework of joint actions. Audits were carried out in 206 companies and agricultural fields, with the total audited workers reaching 1,152. Forty-six (46) undeclared workers were identified, while 148 employees were found to be employed on a different timetable than what was declared to SEPE. SEPE imposed the appropriate administrative penalties for specific violations of labour law. EL further reports on the so-called “Manolada case” (Chowdury and others v. Greece, 30 February 2017), where Greece was found in violation of Article 4, par. 2 (prohibition of forced labour) of the European Convention on Human Rights, for not providing adequate protection to the application. According to the EL report, competent State agencies study challenges and opportunities for improvements both in the institutional framework and in the procedures, so to prevent future violations of the Convention for Human Rights Another practice comes from SK, where the National Labour Inspectorate issued a Methodological Guideline in 2015 governing the process of performance of labour inspections as a supervision over the compliance with legal regulations regulating the prohibition of illegal work and illegal employment. The Methodological Guideline contains indicators of the forced labour, which labour inspectors are obliged to observe in the course of the inspection. In the case of a trafficking suspicion, labour inspectorates are required to report the facts to the law enforcement authorities. Civil society concerns on impunity for those who use the services of victims of trafficking In Member States that have criminalised the use of services of victims of trafficking for sexual exploitation, civil society reports concerns on the implementation of such laws. They report that investigations remain scarce and that generally the issue is not prioritised. In other instances where such legislative framework is rather recent, civil society is eager to see how the future will develop, and the efforts that will be put on implementation. In Member States where no such criminalisation exists, civil society reports that this results in fostering a culture of impunity for those who abuse victims and to the normalisation of violence, especially against women and girls, since this crime has a strong gender specificity. Civil society notes that in absence of criminalisation of those who use the sexual services of victims of trafficking, the onus is placed on the victims, who are those treated as criminals and at times at the expense of their privacy. Civil society asks for a comprehensive approach that places the principle of equality at its core. While considering a step in the right direction the move towards criminalising those who knowingly use the services provided by victims of trafficking, civil society expresses concerns that the requirement of knowledge make its application more difficult, and call for considering options that would render more effective the criminalisation of users and abusers, especially of chil