A/HRC/23/48 B. The role of demand as a factor in fostering exploitation and trafficking of persons, especially women and children 12. 52): As noted in the earlier report of the Special Rapporteur (A/HRC/10/16, paras. 51– “The definition of demand, which is an economic term, can be adapted to the context of trafficking to describe it as the desire „for labour that is exploitative or services which breach the human rights of the person delivering those services‟. It includes demand for sexual exploitation; for cheap labour and domestic workers; for organ removal and sale; for illicit adoption and forced marriages; for criminal activities or begging or for exploitation within the army … „The demand side of trafficking generally refers to the nature and extent of the exploitation of the trafficked persons after their arrival at the point of destination, as well as the social, cultural, political, economic, legal and developmental factors that shape the demand and facilitate the trafficking process‟. As such, it does not have to be „properly understood as the demand for a trafficking victim‟s prostitution, labour or services. Rather, demand must be understood expansively, as any act that fosters any form of exploitation that, in turn, leads to trafficking‟.” 13. The Global Initiative to Fight Human Trafficking (UNGIFT) has identified three levels of demand related to human trafficking: employer demand (employers, owners, managers or subcontractors); consumer demand clients or prostitute-users (in the sex industry), corporate buyers (in manufacturing), household members (in domestic work); and third parties involved in the process.4 14. In the context of demand that fosters exploitation of persons and leads to trafficking in persons, one can differentiate direct and derived demands. Direct demand is for a service which is specifically provided by a person who has been subjected to one of the forms of exploitation listed in the Protocol to Prevent, Suppress and Punish Trafficking in Persons, Especially Women and Children, supplementing the United Nations Convention against Transnational Organized Crime (Trafficking in Persons Protocol). Demand is also direct when it is for goods produced by a person who has been trafficked and subjected to one of these forms of exploitation. Examples of direct demand are: for domestic workers or care workers who have no alternative but to obey. Such demand is routinely for either migrants or children, in conditions where the workers concerned are unable (or unauthorized) to leave their employer – conditions which are sometimes due directly to legislation in force in the State concerned and sometimes a lack of protection measures, particularly child protection measures – for particular commercial sexual services which are not available from someone who has not been trafficked. “Derived demand” is not directly for the services of a trafficked or exploited person or for a commodity which they have helped produce, but for something else, usually for products or services that are particularly cheap. However, in some circumstances it is apparent that the service or commodity in question is highly unlikely to be available unless provided by trafficked persons. Examples of derived demand are: employer demand for cheap and docile workers; demand from businesses or institutions for the products or services of others (i.e., with what is called a “supply chain”), sometimes in other countries; consumer demand for cheap goods or particular services.5 15. On the basis of commissioned research in five Asian countries (in six sectors of income-generating activity), an International Labour Organization (ILO) report concluded that “the trafficking phenomenon is to a very high extent a result of employers‟ 4 5 Toolkit to Combat Trafficking in Persons (United Nations publication, Sales No. E.08.V.14), p. 457. See Recommended principles and guidelines: Commentary, p. 97. 5