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Consultations for the new EU strategy towards the eradication of trafficking in human beings

Consultations for the new EU strategy towards the eradication of trafficking in human beings

Targeted consultations for the new EU strategy towards the eradication of trafficking in human beings: Comments of the National Rapporteur on Trafficking in Human Beings Finland

The Non-Discrimination Ombudsman serves as the Finnish National Rapporteur on Trafficking in Human Beings, under the Act on the Non-Discrimination Ombudsman. The Non-Discrimination Ombudsman is an independent and autonomous public authority. As a National Rapporteur, the Non-Discrimination Ombudsman follows action against human trafficking in Finland, human trafficking at large, compliance with international obligations and the effectiveness of national legislation.

The National Rapporteur wishes to give following comments on the new EU strategy towards the eradication of trafficking in human beings. The National Rapporteur sees that all the targets and actions in the new EU strategy must be the victim-oriented and human rights based.


Critical review of the initiatives undertaken so far

The National Rapporteur sees that measures taken so far have not been effective enough. The approach to tackle trafficking in human beings in the EU should be more comprehensive. Trafficking in human beings is a serious human rights violation in Europe. It seems that certain decisions and policies may increase trafficking and related phenomenon. For example, strict migration policy creates smuggling industry which includes trafficking as well.

Trafficking in human beings should not be seen too complex to solve. Rather it should be integrated to daily work, for example immigration officers’ or labour inspectors’ work. By being integral part of the daily work trafficking may become more visible for those officials who are in the frontline to identify victims and report the crimes.

Trafficking in human beings should be prioritized in the EU agenda. For example, an evaluation of the key directives would help to identify needs to make necessary amendments.


  • Society structures effect on how much there are people in vulnerable positions economically, socially and based on their residence status. Society must support persons in the most vulnerable positions, including irregular migrants and the Roma, and guarantee their access to basic rights.
  • Trafficking for sexual exploitation is a serious human rights problem and preventing it by reducing demand is still an important issue. In this context there should also be targeted measures to prevent trafficking of Nigerian girls and women for sexual exploitation.
  • Adequate resources should be allocated to prevention of trafficking for sexual exploitation, and the investigations of the crime.
  • Preventing work-related exploitation requires ie. effective supervision and sanctions, and targeted measures on sectors with higher risk of exploitation. Better implementation of existing law is needed on this field, also EU level information about employee’s rights.

Countering the culture of impunity

  • Research is needed to find out the reasons why the number of prosecutions and convictions remains relatively low compared to estimated number of victims in the EU. Is the definition of trafficking as in the directive 2011/36/EU too difficult to meet; what obstacles do the investigations face; should victims be better protected and supported during the criminal proceedings.
  • In many cases the evidence lies heavily on the testimony of a victim of human trafficking and therefore victims must be supported and protected in a timely and effective manner. Victims must be able to trust that authorities take them seriously and protect them when they report exploitation.

Protection of victims of trafficking in human beings                        

  • Critical analysis and research are needed to identify structural racism and normative whiteness in the actions against trafficking. Considering the alarming results of the Fundamental Rights Agency’s study Being black in the EU showed, it is expected that structural racism exists in the work against trafficking.  It effects whose report of an offence is taken seriously, what cases are investigated, how people are met in the social and health services and whose fundamental and human rights are fully realized in the EU.
  • A more intersectional approach to human trafficking, recognizing the effects of both race and gender. In the context of trafficking of women and girls from Nigeria to EU, there is a need to discuss racism as well as gender.
  • This said, the gender and child perspective must stay on the focus of the anti-trafficking actions.
  • Actions to effectively protect victims from re-victimization are needed. Structures that make persons vulnerable to re-victimization must be identified. For example, transfer of a victim from one EU member state to another based on the Dublin regulation may increase victims’ vulnerability to re-trafficking, as the support services are interrupted, and the information of the needed services may not reach authorities in the destination.
  • Compatibility of the international obligations to protect victims from re-victimization and the Dublin regulation must be analyzed, taking strongly into account human rights perspective.
  • Victims should be assisted and protected in the member state where they have been identified. Member states must take responsibility of the victims identified in their territory instead of returning victims to another member state without good reasons, especially if they have been victims of trafficking in that other member state.
  • Evaluation is needed on the directive 2004/81/EC and if it answers to the needs of victims of trafficking in effective manner and protects the victims from re-victimization.


  • Trafficking in human beings must be recognized stronger on different agendas and in the work of all the relevant EU agencies, not only within human rights -based agenda’s and policies. Consequences of different policies, ie. migration policy, must be evaluated taking into account the effect on increasing or decreasing human trafficking.