Pursuing a Culture of Freedom: Combating Modern-Day Slavery in Canada

Human trafficking exists as a modern-day slavery that impacts the freedoms and lives of millions around the globe. Worldwide, countless individuals are held and exploited against their will for the purposes of sexual slavery, forced labour and other forms of involuntary servitude. Canada is by no means immune to this brutal injustice on the individual’s freedom, life and liberty.


Over the past few years, the human trafficking story in Canada has gone from an occasional passing line in a news story to being reported about almost daily in the Canadian media. In large part, this is the result of a number of factors including the introduction of a human trafficking offence in the Criminal Code, persistent efforts by non-governmental organizations (NGOs), increased awareness among law enforcement and the unrelenting advocacy by Canadians such as Member of Parliament Joy Smith.


What would have been interpreted five years ago as the uncovering of a prostitution ring is now being presented to Canadians as home-grown human trafficking networks. For example, human trafficking was among the charges laid in the recent arrests in Montreal stemming from the brazen abductions of young girls for forced prostitution.


With Canadians becoming increasingly aware of the modern-day slavery that exists across our country, the inevitable question arises: how is Canada to respond? Herein lays the challenge of dealing with the blurred lines between the roles and responsibilities of the government and individuals.


Effective action to combat human trafficking must ultimately stem from a determined pursuit of a culture of freedom in Canada, one that is valued and esteemed by both the state and its citizens. Both parties bear a responsibility to establish this culture of freedom through individual and collaborative efforts.


I would submit that meaningful progress towards a culture of freedom in Canada can be made in three fundamental areas: quelling the demand for sexual exploitation; pursuing proactive prosecution of human trafficking; and developing a strong collaborative approach between state and non-governmental organizations.


Culture of Freedom


Former President George W. Bush once opined in a State of the Union address that “a society is measured by how it treats the weak and vulnerable” and as such it “must strive to build a culture of life.”<aname=”_ftnref1″ href=”http://www.c2cjournal.ca/ignition/blog-articles/form#_ftn1″>[1] As an influential representative of social conservatives in the US, President Bush continued to refer to the “culture of life” throughout his presidency.


Over the past decade, the social conservative movement in North America has in large part adopted this term to represent a fuller expression of conservative values. In short, life must be protected from beginning to end. Advances in this movement have been evident, most recently observed through the conservative moment in the Dominican Republic, which was successful in amending the country’s constitution to protect life from “from conception to natural death.”


In light of human trafficking being such an egregious crime that enslaves millions, conservatives must purposefully pursue, in addition to a culture of life, a culture of freedom that includes freedom from captivity, exploitation and slavery.


This culture of freedom has been well established by some of history’s greatest philosophers. John Locke stands out as one of the most influential thinkers to emerge from the Enlightenment who asserted that all humans are intended to be in a natural state of freedom and equality, living without the interference of other humans.<aname=”_ftnref2″ href=”http://www.c2cjournal.ca/ignition/blog-articles/form#_ftn2″>[2] Locke further argues that this freedom does not authorize humans to harm others but rather that we ought to make all efforts to “preserve the rest of Mankind.”<aname=”_ftnref3″ href=”http://www.c2cjournal.ca/ignition/blog-articles/form#_ftn3″>[3] In other words, while individuals are entitled to the right to be free, they also have the responsibility to seek the same freedom for others.


This pursuit of a culture of freedom runs deep within the Canadian conservative tradition. The Right Honourable John Diefenbaker championed freedom throughout his political career; he once stated that “as long as there is a drop of blood in my body they won’t stop me from talking about freedom.”<aname=”_ftnref4″ href=”http://www.c2cjournal.ca/ignition/blog-articles/form#_ftn4″>[4]


This passion for individual freedom was finally realized as Diefenbaker introduced the Canadian Bill of Rights on July 1, 1960. One of the primary declarations of the Bill of Rights was the “right of the individual to life, liberty, security of the person.”<aname=”_ftnref5″ href=”http://www.c2cjournal.ca/ignition/blog-articles/form#_ftn5″>[5] As John Diefenbaker introduced the Bill of Rights in the Canadian Parliament, he proudly declared:

I am a Canadian, free to speak without fear, free to worship in my own way, free to stand for what I think right, free to oppose what I believe wrong, or free to choose those who shall govern my country. This heritage of freedom I pledge to uphold for myself and all mankind.


It is Diefenbaker’s final sentence that ought to resound in the hearts and souls of conservatives today. As Canada faces the reality that criminal organizations are actively trafficking Canadian girls as young as 12 years old,<aname=”_ftnref6″ href=”http://www.c2cjournal.ca/ignition/blog-articles/form#_ftn6″>[6] it is time for the conservative movement in Canada take on the rising challenge presented by the scourge of human trafficking. It is time for us to advocate for a culture of freedom that provides liberty and security for the most vulnerable populations within Canada and abroad.



Freedom from demand


Globally, human trafficking arises out of a number of contributing factors such as poverty, warfare and natural disasters. However, it is the demand factor that drives the global trade in humans. The demand for free labour, sexual services, child soldiers and human organs induces the sale of millions of human beings annually. Without the demand for human exploitation there would be very little, if any, form of human trafficking.


This demand has had a significant impact on the international stage. The International Justice Mission suggests that at any given moment, 27 million people are under some form of bondage or slavery. As a result, it is estimated that up to $30 billion dollars are netted annually from this modern-day slave trade, more than the profits of Google, Starbucks and Nike combined. Within this world of slavery, the vast majority of victims are women and children who are trafficked for sexual slavery or exploitation. This is a monumental abuse of basic human freedoms afflicting some of the world’s most vulnerable populations.


The human trafficking that occurs in Canada mirrors that of the global trade. Victims are primarily women and children and are trafficked to, through and from Canada to fulfill the demand of sexual exploitation. In other words, their loss of individual security and freedom is a direct result of the demand created by a seemingly insatiable market of sexual consumers (or johns) looking to satisfy their cravings. Basic supply and demand theory tells us that if the demand is reduced or eliminated, the market equilibrium will be altered, resulting in a lower or nonexistent supply. Thus, it is essential that efforts to combat human trafficking and pursue a culture of freedom in Canada begin with addressing the demand for sexual exploitation—the johns.


Currently, the exchange of sexual services for financial remuneration—prostitution—is legal in Canada. However, solicitation is illegal, resulting in criminal charges for both the buyer and the seller. It is in this area that conservatives must take a bold approach and consider legal reforms that target the demand. In short, it would be the direct criminalization of the act of paying for sexual services and the decriminalization of the act of selling sexual services.


This is a bold approach because it requires a major legal shift in Canada’s Criminal Code and enters a highly sensitive area with which the political right is not commonly associated. Needless to say, this approach has drawn criticism from both the right and left. Those on the right side of the political spectrum would prefer to keep all aspects of prostitution criminalized, typically stemming from moral or religious grounds. Then there are those on the left who would like to see prostitution fully legalized and regulated, going so far as to initiate a constitutional challenge in Ontario to seek legalization.


A shift to either full criminalization or legalization is not the solution, for both landscapes fail to effectively address the demand. This is evident in examples of legalization of the sex trade in the Netherlands and parts of Australia, where human trafficking and sexual exploitation drastically increased and the demand remained unchecked. Similarly, the US has not seen demand diminish despite widespread criminalization of prostitution.


The Swedish model of addressing human trafficking and sexual exploitation is often pointed to as a success story. As of January 1, 1999, Sweden adopted legal measures that penalized the purchasing of sexual services. The law was predicated on an official position that prostitution was “a form of male sexual violence against women and children.”<aname=”_ftnref7″ href=”http://www.c2cjournal.ca/ignition/blog-articles/form#_ftn7″>[7] Sweden recognized that efforts to combat human trafficking and sexual exploitation must focus on targeting the demand. As a result of criminalizing the johns, Sweden has seen the rate of trafficked victims drop to an estimated 400–600 annually.<aname=”_ftnref8″ href=”http://www.c2cjournal.ca/ignition/blog-articles/form#_ftn8″>[8] This is significant when compared to neighbouring countries such as Finland where 10,000–15,000 women and children are trafficked each year.<aname=”_ftnref9″ href=”http://www.c2cjournal.ca/ignition/blog-articles/form#_ftn9″>[9]


The Swedish model has received significant support in Canada. During a study on human trafficking in 2006 by the Canadian Standing Committee on the Status of Women, witnesses overwhelmingly endorsed the Swedish model. One witness explained that “by cutting off demand from the buyers, governments eliminate the major source of illicit revenue and profit for traffickers, the payment of the buyers, thus reducing the incentive for trafficking.”<aname=”_ftnref10″ href=”http://www.c2cjournal.ca/ignition/blog-articles/form#_ftn10″>[10] The Status of Women Committee subsequently included a recommendation in their final report recognizing that many prostitutes were victims of sexual exploitation and called for the repeal of the solicitation laws in the Criminal Code. Furthermore, the committee urged criminal sanctions for johns, as well as for those who exercised control over prostitutes.


Canada’s international legal obligations also call for a focus on eliminating the demand for sexual exploitation. Article 9 of the United Nation’s Protocol to Prevent, Suppress and Punish

Trafficking in Persons, Especially Women and Children, ratified by Canada in 2002, states that:


Parties shall adopt or strengthen legislative or other measures, such as educational, social or cultural measures, including through bilateral and multilateral cooperation, to discourage the demand that fosters all forms of exploitation of persons, especially women and children, that leads to trafficking.<aname=”_ftnref11″ href=”http://www.c2cjournal.ca/ignition/blog-articles/form#_ftn11″>[11]


While the Swedish model has not been officially adopted by Canada, a number of jurisdictions have already adjusted their approach to prostitutes and now view them as victims. The Peel Regional Police and the Toronto Police Service are two local examples. In fact, the Sex Crimes Unit’s Special Victims Section of the Toronto Police Service is mandated to “recognize sex workers as ‘victims first.’”<aname=”_ftnref12″ href=”http://www.c2cjournal.ca/ignition/blog-articles/form#_ftn12″>[12]


Finally, the importance of criminal sanctions towards johns cannot be underestimated. This is a fundamental principle that was recognized by Diefenbaker when he said: “Goodwill has proven to be wanting in establishing equality of men under law. Statutes are needed to assert that principle… Men cannot legislate for the human heart but can legislate against human weaknesses.”<aname=”_ftnref13″ href=”http://www.c2cjournal.ca/ignition/blog-articles/form#_ftn13″>[13]


What results is a two-pronged approach that focuses criminal sanctions on the demand and decriminalizes the victims. It has the added benefit of producing an invaluable partnership between justice and compassion and producing a culture of freedom for those who would continue to be exploited. This is an approach that falls in line with long-standing conservative values.


Freedom through Vigorous Prosecution and Conviction of Human Traffickers


An essential part of providing a culture of freedom for victims of human trafficking is ensuring a swift and assertive justice system. There are two facets: aggressive investigations into human trafficking cases and tough sentences that reflect the gravity of the crime. The former assists to secure immediate freedom for victims of trafficking; the latter assures a long-term freedom from their traffickers.


Since there are no federal or provincial mandates to aggressively investigate and prosecute cases of human trafficking, it is left up to the regional police forces to make prosecution a priority. Thus, human trafficking investigations only take place as potential cases are discovered. The 2009 US Trafficking in Persons Report noted that Canadian “law enforcement efforts reportedly suffer from a lack of coordination between the national government, and provincial and local authorities, which prosecuted most human trafficking cases.”<aname=”_ftnref14″ href=”http://www.c2cjournal.ca/ignition/blog-articles/form#_ftn14″>[14] This is further compounded by a lack of awareness about human trafficking that exists among a number of police forces—a situation that the RCMP’s National Human Trafficking Coordination Centre is working hard to remedy with law enforcement seminars across Canada.


Admirably, a number of police forces such as the Peel Regional Police and the Toronto Police Service have made it their priority to aggressively pursue cases of human trafficking, resulting in the first few successful human trafficking convictions in Canada. However, they struggle with limited manpower and resources to make a significant foray into the trafficking rings that exist across Canada.


In this area, national leadership and resources are required to support effective and targeted investigations that would envelop all of Canada rather than just a few jurisdictions. Since Section 279.01 of the Criminal Code was introduced in 2005, there have only been five human trafficking convictions. All of these convictions occurred as the result of guilty pleas and the determined work of the law enforcement investigating these cases.


In comparison, the US Federal Government made significant commitments towards combating human trafficking under eight years of Republican leadership. Committed to the pursuit of human traffickers and rescuing their victims, a number of agencies were set to task, including the US Department of Justice, the Federal Bureau of Investigation and Immigration and Customs Enforcement (ICE). The US federal commitment to combating human trafficking has resulted in an impressive number of investigations, convictions and rescued victims over the past few years. For example, in 2008, the US Attorneys’ Offices initiated 183 investigations, charged 82 individuals and obtained 77 convictions in 40 human trafficking cases.<aname=”_ftnref15″ href=”http://www.c2cjournal.ca/ignition/blog-articles/form#_ftn15″>[15] Even more commendable are the 486 arrests, 148 convictions at state and federal levels, and the rescue of 245 children during the FBI’s Innocence Lost National Initiative during the same year.<aname=”_ftnref16″ href=”http://www.c2cjournal.ca/ignition/blog-articles/form#_ftn16″>[16]


Securing meaningful jail time for traffickers is the second half of establishing a culture of freedom for rescued victims. This is an area where the Canadian justice system has largely failed victims of trafficking. The convictions under Section 279.01 have resulted in grossly disproportionate sentences in comparison to the crimes.


§ Jacques Leonard-St. Vil was convicted on November 10, 2008, for trafficking a 20-year-old woman. He received a three-year sentence but walked out after his conviction due to the 18 months of pre-trial time served being credited at a “2 for 1” ratio.


§ Imani Nakpangi was convicted on May 13, 2008, on one count of human trafficking and one count of living off the avails of prostitution after prostituting two young girls (aged 14 and 15 years when they started). One victim was trafficked for two years and the other for two months. Combined, Imani made over $400,000 sexually exploiting them daily. His sentence: three years for human trafficking and two years for living off the avails of prostitution minus 13 months credit for pre-trial custody.


§ Michael Lennox Mark was convicted on November 10, 2008, for selling a 17-year-old girl for sex. He received a two-year sentence but only spent a week in jail following his conviction after he was credited “2 for 1” for the one year of pre-trial custody.


§Laura Emerson was convicted on April 9, 2009, for a number of offences including human trafficking. She and her boyfriend trafficked three young girls and sold them daily for sex. Two of the girls were enslaved for six months and one of the girls was enslaved for one year. The girls were subjected to vicious beatings, sexual abuse and drugging. For this Laura received a seven-year sentence.


These sentences stand in stark contrast to stiff penalties handed out in other countries. For example, trafficking a minor in the US under the age of 14 will net a minimum sentence of fifteen years in prison. Trafficking a minor between the age of 14 and 18 will net a minimum sentence of ten years in prison. The US Department of Justice reports that the average length of a sentence given for human trafficking during the 2008 fiscal year was 112 months or 9.3 years.<aname=”_ftnref17″ href=”http://www.c2cjournal.ca/ignition/blog-articles/form#_ftn17″>[17]


Victims of trafficking are therefore not given any incentive or hope to come forward and testify when there is no guarantee that their traffickers will be incarcerated for a significant amount of time, if any at all. Moreover, during the critical recovery time, victims need to have freedom from the emotional and psychological trauma of knowing their trafficker is loose in the community waiting for them. Timea Nagy, who is a survivor of human trafficking and now helps other victims escape, explains it best:

As a person who has experienced this horrific crime first hand, and as a person who is now helping other victims by giving them hope and courage to go to the police and give a statement, facing the possibility that their keepers will walk or get a light sentence is the hardest part of my job.


Looking in a victim’s eye, and telling her that the Police will do everything they can, but it is now up to the law and the court system to make sure that these guys will never hurt her again can be really scary to rely on.<aname=”_ftnref18″ href=”http://www.c2cjournal.ca/ignition/blog-articles/form#_ftn18″>[18]


Before going further it is important to recognize that Canada’s poor record on human trafficking sentences is not indicative of its government. The Conservative government has been consistent in its attempts to raise the penalties for a host of violent crimes. It has been successful in passing a number of important pieces of anti-crime legislation that directly impacts human trafficking prosecutions. Most notably, the current Conservative government has raised the age of protection from 14 to 16 years and eliminated the “2 for 1” and “3 for 1” credits for pre-trial time served.


Furthermore, Conservative MP Joy Smith has put forward a Private Members Bill which wouldimpose mandatory minimum sentences of five years for those who traffic minors in Canada. Bill C-268, An Act to amend the Criminal Code (minimum sentence for offences involving trafficking of persons under the age of eighteen years), was drafted in direct response to the inadequate sentences being handed out by Canadian courts and is widely supported across Canada. MP Smith recognized that the current convictions did not live up to Canada’s international legal obligations under Article 3(3) of the Optional Protocol to the Convention on the Rights of the Child on the sale of children, child prostitution and child pornography. This document asserts that “Each State Party shall make such offences punishable by appropriate penalties that take into account their grave nature.”<aname=”_ftnref19″ href=”http://www.c2cjournal.ca/ignition/blog-articles/form#_ftn19″>[19]


A culture of freedom for victims of human trafficking requires that Canada take a proactive approach to investigating and prosecuting human trafficking, and ensure traffickers receive sentences that truly reflect the gravity of their offences. This is certainly an approach that conservatives have and must continue to advocate for.


Partnership of the State and Individual


A third crucial component to establishing a culture of freedom is through the cultivation of a strong partnership between the state and non-governmental organizations.


The US 2009 Trafficking in Persons Report found that availability of services to the victims of human trafficking was inconsistent due to varied models of service provided by provinces and territories.<aname=”_ftnref20″ href=”http://www.c2cjournal.ca/ignition/blog-articles/form#_ftn20″>[20] At the present time, it is the NGOs that are carrying out the bulk of providing vital services to victims of trafficking. Organizations such Canada Fights Human Trafficking, Walk With Me, REED and the Salvation Army provide food, shelter, counselling and other important services. The US 2009 Trafficking in Persons Report also noted that many of these services are provided without any government assistance,<aname=”_ftnref21″ href=”http://www.c2cjournal.ca/ignition/blog-articles/form#_ftn21″>[21] requiring these organizations raise funds through private sources.


This has put a significant strain on the quality and quantity of services provided to victims, thus limiting the culture of freedom available to a victim after they are rescued. Without proper care and counselling, victims risk being caught back up into captivity.


It is essential to establish that there is a critical role for the government to play in providing services for victims and pursuing a culture of freedom. Article 6 of the UN Protocol to Prevent, Suppress and Punish Trafficking in Persons, Especially Women and Children states:


Each State Party shall consider implementing measures to provide for the physical, psychological and social recovery of victims of trafficking in persons, including, in appropriate cases, in cooperation with non-governmental organizations, other relevant organizations and other elements of civil society, and, in particular, the provision of:

(a) Appropriate housing;

(b) Counselling and information, in particular as regards their legal rights, in a language that the victims of trafficking in persons can understand;

(c) Medical, psychological and material assistance; and

(d) Employment, educational and training opportunities.<aname=”_ftnref22″ href=”http://www.c2cjournal.ca/ignition/blog-articles/form#_ftn22″>[22]


However, at the heart of this issue lies the philosophical debate over how much involvement and control the state should have in providing services to victims of human trafficking. Those on the political left typically support a “big government” approach where the government is responsible for providing the majority if not all of the required services, whereas the long-standing conservative approach is commonly geared towards less government intervention.


This dilemma was echoed by former US President Herbert Hoover as he spoke out against the rising sentiments towards a welfare state. Hoover provides valuable insights into the importance of strong and healthy non-governmental organizations as he responds to the question “Why not let the government do it all?”


The greatest and, in fact, the only impulse to social progress is the spark of altruism in the individual being… The day when altruism in the individual dies from the lack of opportunity for personal expression, it will die in the Government… The day that we decide that the Government is our brothers keeper, is the day that personal responsibility for our brother has been lost.<aname=”_ftnref23″ href=”http://www.c2cjournal.ca/ignition/blog-articles/form#_ftn23″>[23]


The message for conservatives today remains the same in terms of securing concrete assistance for victims of human trafficking. NGOs must continue as the key deliverer of relief and assistance for victims. However, the government can ensure maximum success by providing much needed financial assistance to NGOs and establishing a national partnership between NGOs and federal, provincial and territorial governments across Canada.


Realistically, this will involve some government funding being directed to religious-based NGOs, since many of the organizations combating human trafficking are faith-based. As we have seen recently in Winnipeg with the funding for the Youth for Christ community centre, it will likely bring criticism and cynicism. However, as former MP Monte Solberg pointed out in an earlier C2C article, social justice is not always about political image but about doing what’s right.



Moving Forward with a Culture of Freedom


I believe human trafficking can be eliminated in our generation. It will not be easy—fighting for freedom never is—but it will be worth it.


The pursuit of a culture of freedom that brings liberty to even the most vulnerable of the world’s population has always existed in the values of conservatives. It is time that we focus this culture of freedom towards today’s modern slaves: the victims of human trafficking.


<aname=”_ftn1″ href=”http://www.c2cjournal.ca/ignition/blog-articles/form#_ftnref1″>[1] George W. Bush, “State of the Union” (Washington, D.C., February 2, 2005).

<aname=”_ftn2″ href=”http://www.c2cjournal.ca/ignition/blog-articles/form#_ftnref2″>[2] John, Locke. Two Treatises of Government. Cambridge: Cambridge University Press, (2004) pp 269.

<aname=”_ftn3″ href=”http://www.c2cjournal.ca/ignition/blog-articles/form#_ftnref3″>[3] Ibid., pp 271.

<aname=”_ftn4″ href=”http://www.c2cjournal.ca/ignition/blog-articles/form#_ftnref4″>[4] Rt. Hon. John Diefenbaker. (Excerpt from a speech, Sudbury, Ontario, June 3, 1962).

<aname=”_ftn5″ href=”http://www.c2cjournal.ca/ignition/blog-articles/form#_ftnref5″>[5] Canadian Bill of Rights (1960, c. 44)

<aname=”_ftn6″ href=”http://www.c2cjournal.ca/ignition/blog-articles/form#_ftnref6″>[6] “Strategic Intelligence Brief – Organized Crime and Domestic Trafficking in Persons in Canada” (2008) Retrieved on Feb. 23, 2010 from http://www.cisc.gc.ca/products_services/domestic_trafficking_persons/persons_e.html

<aname=”_ftn7″ href=”http://www.c2cjournal.ca/ignition/blog-articles/form#_ftnref7″>[7] Gunilla Ekberg. “The Swedish Law That Prohibits the Purchase of Sexual Services.” Violence Against Women. 10 (10) (2004): 1187-1218

<aname=”_ftn8″ href=”http://www.c2cjournal.ca/ignition/blog-articles/form#_ftnref8″>[8] Ibid., pp. 1199

<aname=”_ftn9″ href=”http://www.c2cjournal.ca/ignition/blog-articles/form#_ftnref9″>[9] Ibid., pp. 1199

<aname=”_ftn10″ href=”http://www.c2cjournal.ca/ignition/blog-articles/form#_ftnref10″>[10] <spanlang=”EN-US”>Barbara Kryszko. “Testimony.” Standing Committee on the Status of Women. October 26, 2006.

<aname=”_ftn11″ href=”http://www.c2cjournal.ca/ignition/blog-articles/form#_ftnref11″>[11] Protocol to Prevent, Suppress and Punish Trafficking in Persons, Especially Women and Children, Supplementing the United Nations Convention Against Transnational Organized Crime, G.A. res. 55/25, annex II, 55 U.N. GAOR Supp. (No. 49) at 60, U.N. Doc. A/45/49 (Vol. I) (2001), Article 9.

<aname=”_ftn12″ href=”http://www.c2cjournal.ca/ignition/blog-articles/form#_ftnref12″>[12] Special Victims Section. Toronto Police Service Sex Crimes Unit. Retrieved on February 24, 2010 from: http://www.torontopolice.on.ca/sexcrimes/svs.php

<aname=”_ftn13″ href=”http://www.c2cjournal.ca/ignition/blog-articles/form#_ftnref13″>[13] Hon. John Diefenbaker. (Excerpt from speech in Montreal, Quebec, Feb. 14, 1962.)

<aname=”_ftn14″ href=”http://www.c2cjournal.ca/ignition/blog-articles/form#_ftnref14″>[14] US Department of State “Trafficking in Persons Report 2009” (Washington, USA) pp. 99

<aname=”_ftn15″ href=”http://www.c2cjournal.ca/ignition/blog-articles/form#_ftnref15″>[15] Ibid., pp. 57

<aname=”_ftn16″ href=”http://www.c2cjournal.ca/ignition/blog-articles/form#_ftnref16″>[16] Ibid.

<aname=”_ftn17″ href=”http://www.c2cjournal.ca/ignition/blog-articles/form#_ftnref17″>[17] Ibid.

<aname=”_ftn18″ href=”http://www.c2cjournal.ca/ignition/blog-articles/form#_ftnref18″>[18] Timea Nagy. “Message to Members of Parliament.” (Email message to Members of Parliament, Ottawa, ON, September 30, 2009)

<aname=”_ftn19″ href=”http://www.c2cjournal.ca/ignition/blog-articles/form#_ftnref19″>[19] Protocol to Prevent, Suppress and Punish Trafficking in Persons, Especially Women and Children, Supplementing the United Nations Convention Against Transnational Organized Crime, G.A. res. 55/25, annex II, 55 U.N. GAOR Supp. (No. 49) at 60, U.N. Doc. A/45/49 (Vol. I) (2001), Article 3.

<aname=”_ftn20″ href=”http://www.c2cjournal.ca/ignition/blog-articles/form#_ftnref20″>[20] US Department of State “Trafficking in Persons Report 2009” (Washington, USA) pp. 99

<aname=”_ftn21″ href=”http://www.c2cjournal.ca/ignition/blog-articles/form#_ftnref21″>[21] Ibid.

<aname=”_ftn22″ href=”http://www.c2cjournal.ca/ignition/blog-articles/form#_ftnref22″>[22] Protocol to Prevent, Suppress and Punish Trafficking in Persons, Especially Women and Children, Supplementing the United Nations Convention Against Transnational Organized Crime, G.A. res. 55/25, annex II, 55 U.N. GAOR Supp. (No. 49) at 60, U.N. Doc. A/45/49 (Vol. I) (2001), Article 6.

<aname=”_ftn23″ href=”http://www.c2cjournal.ca/ignition/blog-articles/form#_ftnref23″>[23] Herbert Hoover. “The Government cannot do it all: Address to the Greater New York Fund’s Twelfth Annual Campaign Dinner.” (New York, April 25, 1949)

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