Understanding Labour Trafficking in Canada

Calvin Krause
CRJS 5020: Honours Research Project
Supervised under Dr. D. Scharie Tavcer
Department of Economics, Justice, & Policy Studies
Mount Royal University
May 12, 2023

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Abstract
Labour trafficking in Canada is understudied in criminology. There is an overrepresentation of
sexual exploitation research within human trafficking research and not much is known about
labour trafficking. Even less is known about labour trafficking in Canada as labour trafficking is
a complex crime with a few different theories explaining it. For my Honours research project, I
used an annotated bibliography method to represent the current research available. I searched for
articles related to labour trafficking in Canada and I also borrowed some search strategies and
terms from the research librarians. I looked for a variety of sources including CanLII and
newspaper cases, governmental and NGO reports, and academic research articles to understand
labour trafficking. There has been some research calling for legal reform and policy
recommendations on labour trafficking (Canadian Centre to End Human Trafficking, 2022).
There have been a few labour trafficking cases in Canada which were prosecuted by the judicial
system and reported to the police. There were some cases in the news about labour trafficking
but not found in legal decisions from CanLII. Current Legislation includes the Criminal Code
R.S.C., 1985, c. C-46, the Immigration and Refugee Protection Act S.C. 2001, c. 27. This
legislation is included because it outlines human trafficking and the punishments for it and the
legislation acknowledges this crime and makes direct references to it. There has been some
advocacy work done by non-profit organizations and some suggestions about government
intervention, but the data is complex. This study is exploratory, so limitations include low
generalizability and more generic descriptions of labour trafficking. More research is needed to
understand the specifics of labour trafficking in Canada.

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Acknowledgements
I would like to thank my research supervisor Dr. D. Scharie Tavcer for helping organize my
research project, explaining the research essay format, suggesting edits, answering questions,
and working with me to complete this project. I would also like to thank the Student Learning
Services staff Tiffany Doherty and Lauren Cross, who helped me edit this project and provided
me with suggestions to improve my writing. Thank you to the research librarians Brian Jackson,
Kathleeen James, and Joel Blechinger, who helped me find research sources related to my
project with search strategies. Thank you to professors Doug King and Dr. Harpreet Aulakh for
organizing the seminar in the fall semester which provided the space to discuss Honours
research projects, which included brainstorming search strategies to fill research gaps and
address the research questions with my peers. Thank you to the MRU library help desk for
citation support.

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Table of Contents
Abstract

1

Acknowledgements

2

Introduction

4

Methods Section

7

Annotated Bibliography

7

Search Strategies For Finding Sources

7

Final Sources Included

8

Limitations of Exploratory Research

9

Conceptualization

11

Statistics about Labour Trafficking Globally and in Canada

20

Reported Cases of Labour Exploitation

28

News Article Cases

38

Overall Analysis of News Websites

42

Legislation Section
Commentaries on Legislation

43
46

Detection, Investigation & Prosecution

52

Recruitment Process, Causes & Theories of Labour Trafficking

66

How Are Victims Recruited By Traffickers?

66

Theories & Explanations Of Labour Trafficking In Canada

70

Conclusion

82

References

86

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Introduction
Labour trafficking is defined in Canada as recruiting, holding, and moving victims to
locations for forced labour that is not for sex work or sexual exploitation (Public Safety Canada,
2022). More people are aware of human trafficking for migration or sexual exploitation, but
fewer people are informed about labour trafficking specifically in the hospitality industries for
example. The International Labour Organization (2017, p.5) estimated that “in 2016, 25 million
people worldwide were victims of forced labour”. Lemahieu, Me, & Ye (2022) stated that the
global pandemic had fewer opportunities for victims to be detected by the police. In 2020 59%
fewer victims were detected in the East Asia region, 40% less in the Middle East and North
Africa, 12% less in Sub-Saharan Africa, 32% less in South America, and 36% less in the
Caribbean and Central America region compared to 2020. This was the first time that the number
of human trafficking victims detected decreased globally. Lemahieu, Me, & Ye (2022) suggested
that this could push crime “further underground” (p.3). As the statistics show, criminal justice
agencies are only starting to begin to understand what labour trafficking is and how crime
prevention in Canada must respond to it. Additionally, 3541 human trafficking cases were
reported to the police in Canada between 2011-2021 (Conroy, 2022). The average annual rate for
human trafficking was 0.9 incidents/100 000 in Canada (Conroy, 2022).
What can be shocking to many is that slavery continues to persist in Canada. Despite
abolition movements of the past and human rights movements from social justice advocates,
human trafficking still happens in Canada. People must be grateful for the advocacy work in the
past that has led to our current progress yet more must be done to eliminate it and eradicate its
evils from Canadian society. Just because something is criminalized it does not mean that it does

5
not happen. Labour trafficking specifically is secretive and less is currently known about it.
However, by speaking up based on what research says about labour trafficking progress can be
made. If more criminal justice agencies can be aware of this crime and fight against the evils of
labour trafficking, then perhaps one day that number can be zero.
Different theories have been proposed to describe labour trafficking and why it happens.
However, like most criminological research labour trafficking cannot be explained through one
specific theory nor does it rely exclusively on one set of variables. It did not make sense to offer
a hypothesis as to why this crime happens as this was designed as an exploratory study. With
limited secondary data available, clear predictions cannot be made about specific causes of
labour trafficking. Instead, the focus of my project is to understand the criminal justice system
process and Canadian legislation.
Based on what was discussed in criminal justice classes, labour rights and how
connections to labour trafficking work were not a part of it. In these classes, lots of discussion
existed around equality and legal rights yet labour trafficking affects both of those rights.
Amongst the CanLII literature, I found that most cases of labour trafficking prosecuted in court
involved migrant workers. Migrant workers do not have the same legal protections as citizens
and permanent residents of Canada. In the literature I found, legal scholars suggested that the
criteria for the temporary foreign worker program change to give equal legal protections to
migrants. The worker agreement This would have a significant impact on responses to labour
trafficking in Canada. Explanations around labour trafficking have involved economic
perspectives including Marxist approaches (Meshelemiah, & Lynch, 2019), some have involved
push and pull factors (Ontario Women’s Justice Network, n.d.), some involve laws around

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getting a prosecution, and some involve supply and demand (Catholic Relief Services, 2016).
There was only one “successful” prosecution case in Canada which resulted in the sentencing of
the traffickers (Hastie, & Yule, 2014). The original case was not published on CanLII. It was
written in a commentary that talked about prosecuting cases of labour trafficking in Canada.
From the commentary, it refers to the case but it’s not clear if it is the original case. In the
footnotes, it mentions that there was a bail review hearing and a sentencing hearing. This
commentary is the only source on the case. There’s no consensus over the “best” approach to
combating or preventing labour trafficking. Statistics available do not always have the same data.
Some break it down by demographics, some just include it as part of the crime rate. The data is
organized differently by each source which makes it challenging to compare and contrast causes
and consequences. Furthermore, criticisms of the current legislation suggest that the definition
criteria are too narrow which means it is getting more difficult to pursue prosecutions.
What is the context of labour trafficking in Canada? This research aims to answer that
question. The method is an annotated bibliography. This method allows me to examine the
context of labour trafficking in Canada. This includes statistics, recent case studies, legislation,
detection, prosecution, and theories about why this crime happens. Further analysis of the
methodology is included in the methodology section.

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Methods Section
Annotated Bibliography
My research design was an exploratory study of the topic of labour trafficking. The
presentation of my research is an annotated bibliography. Balso & Lewis (2012) describe what
an annotated bibliography is (p. 63). Annotated bibliographies contain a list of sources which
each offers a brief summary. In annotated bibliographies, the goal is to evaluate and summarize
sources (Balso & Lewis, 2012, p. 63). It encourages critical reflection of sources and can be like
a compacted version of a literature review. Annotated bibliographies ensure that each source is
relevant to the research topic. The benefit of using this methodology is that each source is read
critically and this methodology helps determine themes. It is good for exploring the topic and
then it helps to understand where the research gaps lie.
Search Strategies For Finding Sources
My search strategies included searching library databases, Google Scholar, and news
websites to determine what literature existed on labour trafficking. I used academic journal
articles, newspaper articles, statistical reports, CanLII case reports, and government websites. I
also used non-profit organizations related to fighting labour trafficking to find reports on
statistics as well as examples of labour trafficking, who it targeted, and who was most at risk. I
borrowed search terms from librarian recommendations. Some search terms included the words
“labour trafficking”, Maslow's hierarchy of needs and labour trafficking, “labour exploitation”,
“forced labour”, “conflict theory” and “labour trafficking”. Sometimes I searched directly on
websites to see if any reports were listed. I examined Canadian legislation on labour trafficking
by examining the Criminal Code and Immigration Refugee Protection Act because those are

8
currently the main legislation used by law enforcement to press criminal charges and for a case
to be prosecuted. That way, I could understand the government’s current crime response. I found
policy and law journal articles discussing legislation around labour trafficking and how it was
prosecuted in Canada. One legal commentary mentioned the Domotor case and the response to
labour trafficking in Canada. I examined Statistics Canada to understand how crime is reported
and the statistical reality of labour trafficking.
Final Sources Included
I surveyed multiple sources and each source had different levels of depth. . For example,
on government websites, less information was shown and sometimes would have links to other
reports. However, non-profit websites had more information with research reports which led to
more data to analyze in non-profit sources compared with governmental sources. This goes to
show the limited research existing on labour trafficking and the challenges with finding relevant
data on the research topic. Government sites and reports provide research and policy plans but
they do not always have the same depth. I also included other sources like journal articles,
statistical reports, and non-profit reports. These sources offered insight into the challenges of
detecting labour trafficking in Canada, prosecuting and investigating it. Furthermore, they
provided insight into why the laws could be narrowed or need to be reformed to meet victims'
needs. For this project, I included cases from both CanLII and newspapers to explain labour
trafficking in Canada. Cases could serve as examples of what labour trafficking looks like in
Canada; the cases could illustrate who was involved, and what the outcome was. Similarly, I
included newspapers because they could provide examples. Cases are limited because the
specific case examples do not always represent the details of what happened in each case. Each

9
case has unique circumstances so case examples alone would be too narrow to investigate this
topic within enough depth. However, themes can be pulled out to see if the trafficking signs
described in the definitions above fit each case. That is why I have also examined cases of labour
trafficking in Canada to draw themes from those sources too.
Limitations of Exploratory Research
A book author on research methods warns that a descriptive research design could result
in biased results (Walliman, 2006, p.38). Since my research design is exploratory, it would
qualify as descriptive rather than explanatory. I am not testing theories of labour trafficking, nor
am I using primary data to do so. Instead, I am relying on interpretations from scholars who
describe laws and policies around labour trafficking. I am also relying on secondary statistics so I
do not have control over which variables are measured in the research. The focus is more on
understanding the current research gaps and what scholars are saying about them. Walliman
(2006) says that quantitative data focuses on measuring concepts which can include economics
and population counts. Including statistics allows for that.
However, a limitation of this study is that the secondary data from sources that I found
were designed with different research methods and purposes than my design. The criteria used by
other researchers could be different from mine. Therefore, secondary data might not always
include relevant aspects that I look for. For example, the statistics section discusses different
ways that sources organized their data on human trafficking. Since I did not include primary data
I could not control for specific variables or data to fit my research design. However, there was a
way to work around it. One way to limit this as outlined by this Walliman (2006) is to compare
the data from different sources for the discussion around it (p. 54). I have done that in this

10
research as I surveyed multiple sources. In addition, criminology research is interdisciplinary so
multiple scholars write bringing together different approaches but invested in the same topic. In
descriptive research, design data is selected purposefully by the researcher who could hold bias.
The research design does not have a quantitative focus so the data can be criticized more easily
for bias. Walliman (2006) describes this from a primary research design being interviews or
questionnaires or selective observation. However, this could happen in secondary research where
the researcher selects sources that could bias the data. This is a possibility in my research.
However, I limited that by consulting with librarians and also when I brainstormed research
strategies with my peers in the seminar part of honours. My source choices also were influenced
by external sources who understand this topic differently than me. These people can notice that I
cannot. A benefit to using an exploratory design through an annotated bibliography is that it has
flexibility. There is no specific type of research I am trying to find since I am doing an
exploratory study. Specifically, interviews, experiments, and ethnography to name a few. It is
similar to a literature review but also includes a brief summary of each source. It does not cover
the depth for this reason but does cover the breath. The scope of the research is larger than if I
did a case study or one method such as experimental design or interview or survey.
Wooldredge (2007) begins by discussing the different purposes that research methodologies can
be used for. Some examples include testing theories and explanations of concepts, testing
policies for effectiveness, and if theories can be applied. Criminologists and researchers use the
same research methods as social scientists and behavioural scientists. Within criminology, this
entry suggests that criminologists testing policies and programs favour a quantitative approach
whereas qualitative research focuses on developing theories. Observations are qualitative, then
become tested with a quantitative method (Woolredge, 2007).

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Conceptualization
Public Safety Canada. Labour trafficking. (2022).
https://www.canada.ca/en/public-safety-canada/campaigns/human-trafficking/labour-traffi
cking.html
Labour trafficking is defined by the Canadian government as recruiting, holding, and moving
victims to locations for forced labour that is not for sex work or sexual exploitation. Movement
can be within borders or across borders. It includes signs of labour trafficking: relocation without
enough details and no upfront payment, living and working in unsafe and unhealthy conditions,
employers who threatened employees with deportation or reporting of immigration status to the
police, job offers that are perceived too good to be true, endangered life if the victim left the job.
This webpage specifically talks about labour trafficking and also lists who is at risk for it.
Language barriers can make immigrants and newcomers vulnerable to labour trafficking.
Traffickers may pressure their victims through deception and force. A limitation of this source is
that it does not give specific examples of labour trafficking. It does not describe a situation where
labour trafficking is happening through any kind of case study. So the information on the website
cannot be compared to specific cases without going to external sources.
International Labour Organization. (n.d.). What is forced labour, modern slavery and human
trafficking? https://www.ilo.org/global/topics/forced-labour/definition/lang--en/index.htm
The International Labour Organization website gives a definition of forced labour. It is
non-voluntary work done by intimidation or violence and can include public humiliation of
immigration officials or debt manipulation. They further acknowledge that this can happen to

12
children and adults by individuals, private companies or governmental officials. This source also
acknowledges that mandatory military service, communal services, jail labour, emergency work,
and civic obligations do not count as forced. The work can include the construction, agriculture
industry, domestic work and forced begging. Forced labour includes violence, threats,
withholding of personal identification documents and wages, and restrictions of workers'
mobility freedoms. This webpage does not list specific groups of people who are more at risk
than others. Nor does the webpage describe how victims are trafficked. The limitation of web
pages is that they are not exhaustive descriptions or explanations of all the factors and how they
work. They only provide highlights of information. Compared with research reports I found on
labour trafficking, webpages are starting points for research.
The United Nations. (n.d). Office of Drugs and Crime. Human trafficking.
https://www.unodc.org/unodc/en/human-trafficking/human-trafficking.html
The United Nations webpage gives a definition for human trafficking but not labour trafficking.
It says human trafficking is the transportation, transfer, harbour, and recruitment of people by
deception, fraud, and force resulting in exploitation for profit. Violence and fraudulent
employment agencies are used to coerce victims. It includes links to the UN Protocol. Protocol
to Prevent, Suppress and Punish Trafficking in Persons, Especially Women and Children,
supplementing the United Nations Convention against Transnational Organized Crime. and
newspaper articles which talk about the United Nations' response to trafficking. This webpage is
very short and does not describe any details of human trafficking beyond the definition. It also
does not cite any sources so other sources must be consulted to fact-check this source.

13
Migrant Workers Centre. (n.d). Labour exploitation & trafficking in BC.
https://mwcbc.ca/labour-exploitation-trafficking-in-bc/
The Migrant Workers Centre in BC defines labour exploitation as employers who break the law
which violates legal rights. This includes wage standards, human rights codes involving
discrimination, rights laid out by employment contracts, and health and safety standards. It also
says that labour trafficking is the transportation, recruitment, or harbouring of people for
exploitation. This is done through abuse of power, fraud, and deception forcing employees to
work. Force is not limited to the physical aspects, it can include lies and threats. The primary
industries also mentioned in this source, are agriculture, restaurants, construction, and domestic
work. Some foreign workers might not be eligible for permanent residency so they depend on the
employer to work in Canada. Traffickers take advantage of this. The recruitment turns out to be a
fraudulent offer. The website also lists signs of labour exploitation and phone numbers to contact
them when victims need help.
This source offers a clear definition and it provides contextual information too which is the
harbouring, transportation, and recruitment of people for exploitation. It further elaborates as
shown above. It does not merely give a definition of labour trafficking but looks at multiple
factors. This webpage has links to handbooks and pamphlets to build awareness of labour
trafficking in Canada.
Fudge, J. (2019). Reconceptualizing unfree labour: Local labour control regimes and constraints
on workers’ freedoms. Global Labour Journal, 10(2).
https://doi.org/10.15173/glj.v10i2.3654

14
This article mentions challenges with differentiation between voluntary and forced labour. It
mentioned a spectrum between exploitation and voluntary labour. The similarities were the focus
of researchers who came from a Marxist economic approach. It examined structures as opposed
to “individual pathologies.” Free labour meant the worker had the right to choose who to work
with whereas a slave would follow where the capital led and work for whichever master he
wanted but with limitations. Slavery is also defined as a loss of liberty and controlling movement
of a person. Researchers have rejected a “black and white” approach for a continuum.
Unfortunately, this research article focuses mostly on theoretical approaches to forced labour and
what other academics think about explaining forced versus voluntary labour. This article does not
provide evidence to back up its claims, it merely discusses different theories from the Marxist
paradigm and ideas trying to define terms. The best discussion was from the slavery definition
mentioned above. In addition, researchers suggest that there is a spectrum of exploitation versus
voluntary labour yet they do not back up their claims with data. It does not mention cases of
labour trafficking nor does it justify why researchers seem to agree that this is a spectrum. It does
not reference statistics as it is merely descriptive.
Davies, J. (2020). Corporate harm and embedded labour exploitation in agri-food supply
networks. European Journal of Criminology, 17(1), 70–85.
https://doi.org/10.1177/1477370819874416
This researcher did a study examining the effects of corporate crime and its harms on labour
trafficking. Part of the reason the researcher argues is from structural factors within food supply
networks in response to demands for the product. The article opens by acknowledging that there
is not a universal agreement on labour trafficking and what makes it exploitative. Some people

15
suggest that it is based on a spectrum, while some suggest that it becomes a normalized practice
that does not exist in criminal organizations alone. Furthermore, migrant workers and agriculture
industry workers are more likely to be victims of this crime as mentioned earlier. Victim Services
recommended human trafficking awareness training for staff at Hampton Inn in Bolton, Ontario.
It focused on sexual exploitation but confirmed human trafficking as an underreported crime in
Canada. The researchers conclude with products within supply networks which are in demand
combined with management decisions with multiple layers which encourage secrecy and harmful
labour practices.
This research article focuses on corporate crime and labour trafficking and how they are related
to each other. The research article highlights that the exploitation of labour is a part of labour
trafficking that remains unclear in the literature. This is important because it is likely related to
the reason why labour trafficking is not widely understood amongst the available literature on
this research topic. This identifies a specific gap in how labour trafficking is discussed in the
literature. Without clarity in the literature about what exploitation is, then it becomes a challenge
to understand it. However, there are labour trafficking signs which are discussed on the
Government of Canada webpage mentioned below. It highlights the secrecy involved with
management decision-making in the labour market which encourages poor labour practices to
occur. This same secrecy is consistent in labour trafficking cases and discussions around it in the
literature.
Bowersox, Z. (2022). Union density and human trafficking: Can organized labour discourage
trafficking? Journal of Human Trafficking, 1–14.
https://doi.org/10.1080/23322705.2022.2073095

16
This research article discussed explanations of labour trafficking and will be further discussed in
the theoretical section. However, it provides definitions for labour trafficking. These authors
suggested that multiple definitions have included poor labour practices and chattel slavery in
their definitions. Exploiting someone’s efforts for gain by deception or force is the definition
these authors refer to. Common industries of labour trafficking listed include factories, harvest,
and domestic work and the labour is unseen. People working in these industries that are
trafficked are hidden from what everyone else sees in those industries. Forced labour can often
be seen as a “bad job” since the working conditions are considered dangerous. Not all poor work
conditions are forced labour but all forced labour will have poor working conditions. This article
also recognizes that sexual exploitation is also more known than labour trafficking.
This article explains labour trafficking and the context behind it. It is not merely a dictionary
entry so this source is better than some other sources used for labour trafficking definitions. It
points out that poor working conditions are part of the criteria for labour exploitation to happen.
It points out deception and force which is consistent with other definitions. It highlights the core
industries where labour trafficking can go unnoticed. It mentions that victims are hidden within
these industries which helps illuminate the fact that not much is known about the research area. It
highlights exploitation which is essential to understanding what labour trafficking is. Without
this article labour trafficking cannot be explained correctly.
Canada Border Services Agency. (2020). Human trafficking at the border.
https://www.cbsa-asfc.gc.ca/security-securite/ht-tp-eng.html
This website defines labour trafficking as receiving, holding, concealing, recruiting, transporting,
transferring, harbouring, influencing, controlling, and directing people for exploitative reasons. It

17
uses the term forced labour instead of labour trafficking. Labour trafficking is a complex crime.
How it happens and who is being targeted must be understood. The Government of Canada states
that immigrants and newcomers in Canada are at higher risk than other groups in society for
being victims of trafficking. The main industries that recruit victims are agriculture, hospitality,
restaurants, construction and more.
This definition explains which industries are targeted for labour trafficking in Canada which is
good because that is where the government should focus its resources on preventing this crime. It
also explains who is at risk for labour trafficking. This is important because this can help CBSA
and law enforcement identify potential victims but also employers in these sectors who can
access this website. The limitation of this webpage is that it did not describe methods which law
enforcement used to detect and investigate trafficking. It was very vague. There is also no author
to specifically contact for more information about how this happens and ways to get involved in
crime prevention. This is strange because the government has plenty of resources available and
arguably more funds than non-profit organizations yet nonprofits have more data on this.
McQuade, A. (2019). Labour trafficking. In Clark J.B., Poucki S., (Eds.), The SAGE Handbook
of Human Trafficking and Modern-Day Slavery (1st ed.). SAGE.
https://doi.org/10.4135/9781526436146
This source says labour trafficking means service or work which is demanded from anyone under
threats of penalties through force. Labour trafficking persists despite laws to combat it. It also
considers forced child marriage as a form of non-economic slavery. The article further goes on to
discuss labour trafficking policy and law responses in the international context. It uses a few case
studies to describe victims' experiences of labour trafficking but does not offer explanations of

18
why it happens beyond law and policy. It does have a specific theory. It’s great for describing
what labour trafficking is and what laws exist to combat it along with personal experiences. It
focuses on the international context so this cannot be compared to the Canadian context.
Armendariz, B.N., Nsonwu, M., Heffron, L.C., & Mahapatra, N. Human trafficking: Exploiting
labour. Encyclopedia of Social Work.
https://doi-org.libproxy.mtroyal.ca/10.1093/acrefore/9780199975839.013.1124
This article includes a general human trafficking definition but focuses on labour trafficking in
its research. The definition says human trafficking is the harbouring, recruitment, provision,
transporting or collecting of a person for labour or services, through force, coercion, or fraud for
the subjection to forced debt bondage, peonage, servitude, slavery, or forced commercial sex
acts. It also says that movement within or across borders is not required for this definition (p.2).
Some of these victims may get assaulted or sexually assaulted. Threats of violence against their
families, physical or psychological forced through debt bondage could be present in cases
involving labour trafficking. Not much is known about labour trafficking is confirmed by these
authors. Trafficking and smuggling can get misused but not all forms of smuggling are
trafficking. Force and fraud must be present for human smuggling to be considered also labour
trafficking. Smuggling involves illegal crossing of borders between countries.
This research article lays out a broad definition of labour trafficking but also says that forced
labour must be present. Human smuggling does not always qualify as a form of labour
trafficking. Human smuggling is a crime too but it has separate criteria from labour trafficking. It
separates sexual trafficking from labour trafficking in that not all cases will include sexual
assault. It includes psychological factors and threats of violence as part of it. Movement across

19
borders or within is not required which broadens the criteria. People moving within small regions
might qualify as labour trafficking under this definition. For example, if someone is being moved
between cities but within one province within borders does not count. But it’s not required so the
case could still be considered labour trafficking. The research article aims to equip social
workers to get involved in crime prevention and help survivor needs plus contextualizes the
issue. Although not aimed at criminal justice agencies it still aims to equip workers who may
witness cases of labour trafficking. The researchers are American so this source might not reach
Canadian social workers but having these types of articles is a starting point.
Public Safety Canada. (2022). National Strategy to Combat Human Trafficking. Annual Reports.
2019-2024.
https://www.publicsafety.gc.ca/cnt/rsrcs/pblctns/2019-ntnl-strtgy-hmnn-trffc/index-en.aspx
This report mentions the Canadian government’s action plan to combat human trafficking. It said
an advisory committee would be formed involving survivors and victims to give
recommendations to the government for policies. It also stated that it would increase funding for
community services which provide recovery for survivors. It also said it would target supply
chains and highlight labour rights to employers in those supply chains. This involves private
industries and international organizations. The five-year strategy includes addressing research
gaps used for programs and policies. Training in law enforcement and more public awareness is
the goal too. It said new projects will be aimed to reduce youth exploitation who “live in care”
(p.10). Another action includes hosting an international conference to discuss progress since the
CCC added human trafficking in 2005. Experts from front-line workers, law enforcement,
academics, Indigenous organizations, NGOs, survivors, and government workers with the goal

20
of improving the response. It says there will be an advisor for human trafficking response for the
Canadian government.
Statistics about Labour Trafficking Globally and in Canada
International Labor Organization. (2017). Global Estimates of Modern Slavery.
http://www.ilo.org/wcmsp5/groups/public/---dgreports/---dcomm/documents/publication/w
cms575479.pdf.
The International Labor Organization estimated that “in 2016, 25 million people worldwide were
victims of forced labour (p.5). 15 million people were in forced marriages and 25 million people
were in forced labour. The human trafficking victimization rate was 5.4 victims per 1000 people
in the world. Girls and women accounted for 71% of the victims. ¼ of the victims were children
(p.10). The private sector had 16 million people in forced labour in 2016. 57.6% of victims were
women compared to 42.4% were men victims. 51% of the victims of forced labour were from
debt bondage. Debt bondage referred to forced labour for personal debt. 70% of adults were
coming from the domestic work, manufacturing, and agriculture industries. The largest
categories were domestic workers at 24%, construction at 18%, manufacturing at 15%, and
fishing and agriculture at 11%. 24% of victims were threatened to have their wages taken away
by their traffickers if they left their jobs (p.11). The statistics in this source are organized very
clearly, it lays out labour trafficking statistics in depth compared to the source below. It talks
about the victimization rate and compares it to different sectors, gender, and age. It is also
included in a report which talks about policy initiatives.

21
Canadian Women's Foundation. (2014). No more: Ending sex-trafficking in Canada report of the
national task force on sex trafficking of women and girls in Canada.
https://www.mamawi.com/wp-content/uploads/2016/02/National-Task-Force-FINAL-Repo
rt-NO-MORE.pdf.
Human trafficking has a large impact on Indigenous people. The following reports brought to
light what is happening. The Canadian Women’s Foundation made a task force designed to
respond to human trafficking and found that 51% of trafficked women were Indigenous.
Indigenous children are also overrepresented in the welfare system for children. Over half of the
welfare system is Indigenous (p.32). This statistic identifies who is more likely to be a victim of
human trafficking as this example is evidence. The Canadian Women’s Foundation found that
from cases of reported trafficking which involved Indigenous survivors, 71% of trafficked
survivors reported rape from doctors, 80% from the police, 40% from social workers 60% from
judges.
Omele, C (2016). Human Trafficking. The health of men forced into labour trafficking in the
United States. Walden Dissertations and Doctoral Studies.
https://scholarworks.waldenu.edu/dissertations/1980
This researcher did a research study on whether male victims had higher chances of being labour
trafficked compared to other methods of human trafficking (p.7). In the study sample, it was
found that only 1% of the male victims were sex trafficked. This indicated that there was a
significant difference between the amount of male victims labour trafficked compared to those
sexually trafficked (p.72). This is important because it means that when law enforcement
agencies are looking for signs of labour trafficking, there is a higher chance that the victim will

22
be male. This adds criteria which are backed up by empirical data. Another question answered in
this research study was whether or not male victims have “health conditions” compared to
female victims (p.7). This researcher found that 83% of victims had a minor health illness. 81%
of males had a minor health illness compared to 89% of women. It was also found that the
average amount of health illnesses was not significantly different between males and females at a
95% confidence interval. Females had more health issues (p.75). This is evidence that victims of
labour trafficking have health issues.
Lemahieu, Me, & Yee. (2023). UNODC, Global Report on Tracking in Persons 2022.
https://www.unodc.org/documents/data-and-analysis/glotip/2022/GLOTiP_2022_web.pdf
Between 2019-2020 59% fewer victims were detected in the East Asia region, 40% less in the
Middle East and North Africa, 12% less in Sub-Saharan Africa, 32% less in South America, 36%
less in the Caribbean and Central America region (p.3). Furthermore, the conviction rate during
2020 was 0.28/100 000 people in Central and Eastern Europe, 0.08/100 000 in North America,
0.01/100 000 in South Asia, 0.07/100 000 globally (p.8). There was a previous refugee crisis in
Ukraine during 2014 and the data revealed that there was a relationship between countries in
conflict and victims’ vulnerability to human trafficking. Between 2014-2016 there was a 4.70%
increase in human trafficking detected cases while between 2014-2015 there was an increase
from 10833 application cases to 16209 application cases of asylum seekers (p.9). Based on data
from UNODC court cases, children were twice as likely as adults to be victims of extreme
violence while women were 3 times more likely to be victims of extreme violence (p.12). The
same court case data revealed that 12% of victims were from individual traffickers compared to

23
46% from business-like organized crime types of traffickers (p.13). Of detected exploitation
cases in 2020, 10.2% were forced criminal activity, and 38.8% involved forced labour (p.15).
This source provides global statistics about human trafficking which can show how prevalent it
is in the world. The court case data above stated that women and children are much more likely
to be victims of high levels of violence which means that most human trafficking charges contain
violence. This is important because labour trafficking involves violence like threats or
intimidation. It suggests that the report accurately measures human trafficking. 38.8% is a
significant number of labour-trafficked victims represented in the reported cases of trafficking
for 2020. Resources need to be allocated to help survivors of trafficking. In addition, the case
count used in the sample is fairly large so it would be more generalizable than sources which
have small case counts. A limitation of this source is that it compiles data from different
countries with different laws, customs and policies. There could be some factors that affect each
country differently. For example, if the economic development differs that means that there are
fewer resources available to use to help victims. If law enforcement is corrupt then laws could do
little to no effect. However, despite the limitation these statistics are relevant to understanding
labour trafficking.
Rico & Drydyk. (n.d.). It happens here. Labour exploitation among migrant workers during the
pandemic. Canadian Centre to End Human Trafficking.
https://www.canadiancentretoendhumantrafficking.ca/wp-content/uploads/2023/02/CCTE
HT-%E2%80%93-Labour-Trafficking-Report-ENG-1.pdf
In this report the foreword section mentions that the Canadian government allows more migrant
workers to work in sectors where there are labour shortages. This happened through recent

24
changes to the Temporary Foreign Worker Program. To name a few these include construction,
hospitals and food manufacturing. There is a demand for migrant labour in Canada. The research
report included a study on labour trafficking during the global pandemic. The study included
migrant workers in Toronto, Greater Toronto, Leamington, London, and Hamilton ON. Workers
came from the caregiving, construction, agriculture, and hospitality sectors. Focus groups were
conducted by these researchers. Of the 77 migrant workers, the largest category was from
Mexico at 31%, followed by Grenada at 18% and Thailand at 12% (p.11). 45% of participants
migrated to Canada through the Temporary Foreign Worker Program (TFWP) and worked in
agriculture. The next largest category was migrating to Canada without any government program
at 32%. 44% of workers were employed under the TFWP or SAWP while holding a valid work
permit. 23% reported that they lost their status and 16% were visitors (p.13). Most victims knew
about human trafficking but less than half (48%) knew it existed in Canada. Some participants
wanted to immigrate to Canada so they could leave the abuse in their home country. Participants
were shocked to find out that this occurs in Canada too (p.20). Participants were asked about
their struggles with working in Canada. The majority of respondents said family separation at
57%, followed by low wages at 51%. Another large category was discrimination at 48% and
verbal abuse at 35%. Working without a permit was also at 35%.
Conroy S. (2022). Trafficking in persons in Canada, 2021. Juristat Bulletin Quick Fact. Statistics
Canada. https://www150.statcan.gc.ca/n1/pub/85-005-x/2022001/article/00001-eng.htm
This source said that there were 3541 human trafficking cases reported to the police between
2011-2021. The average annual rate for human trafficking was 0.9 incidents/100 000. Between
2020-2021 there were 32 more incidents under IRPA compared to 33 fewer CCC incidents. Since

25
2011 there has been an increase in offences under IRPA. CCC reported crimes of human
trafficking increased until 2019 where it was about the same until 2020 and then slightly
decreased in 2021. The highest rates came from Saskatchewan, Ontario, and Nova Scotia.
Between 2011-2021 83% of human trafficking incidents reported to the police came from census
metropolitan regions. These census metropolitan regions included Montreal, Toronto, Ottawa,
and Halifax. Most victims were girls and women and about 4/10 human trafficking violations
also include sex trafficking. Between 2011-2021 81% of accusations were men between 18-34.
20% of the accused involved youth between 12-17. Between 2011-2021, 42% of human
trafficking incidents faced criminal charges or even recommendations of some. 54% of cases did
not have a suspect to accuse by the police. Most charges involved CCC charges instead of IRPA.
Statistics Canada also provided court statistics. This involved data from the Integrated Criminal
Court Survey which includes adult and youth courts. The Statistics Canada report begins with
adult criminal court data presented between 2010-2021. 948 cases were prosecuted in Canadian
criminal courts, there were 2992 human trafficking charges that were completed in criminal court
between 2010 & 2021. There were 13% fewer cases in the 2020 category compared to the 2019
category. A “completed” court case had 17 charges on average per human trafficking case in
adult criminal court between 2010-2021. 81% of cases either resulted in a stay, acquittal,
withdrawal, discharge, or dismissal. Of the human trafficking cases that resulted in a guilty
verdict, 78% had a custodial sentence. 11% of guilty cases resulted in probation being the most
severe punishment and 11% other sentences which included community service orders,
conditional or absolute discharge. 6% of human trafficking cases between 2010-2021 were youth
accused of human trafficking. 56 cases contained a charge of human trafficking with 124 overall
cases. Of guilty cases, 47% were supervised or custody sentences, 24% were probation, 24%

26
were supervised and deferred sentences, and 6% had a different type of sentence. The average
time to finish a case of human trafficking in court was 382 days. This source acknowledges the
labour trafficking-specific limitations. Less is known about it and victims depend on labour
human rights laws. Also, labour trafficking is more hidden from public spaces. Forced labour
was only added recently by countries around the world within human trafficking discussions.
Public Safety Canada. (2022). National strategy to combat human trafficking. Annual reports.
2019-2024.
https://www.publicsafety.gc.ca/cnt/rsrcs/pblctns/2019-ntnl-strtgy-hmnn-trffc/index-en.aspx
This report will be discussed in greater detail below in the detection and investigation section.
Here are some statistics it provided about human trafficking in Canada. The definition provided
is consistent with the labour trafficking webpage I mention in another section. Labour trafficking
is “recruiting, transporting, transferring, receiving, holding, concealing, harbouring, or exercising
control, direction or influence over that person, for the purpose of exploitation, generally for
sexual exploitation or forced labour” (p.14). It describes methods of human trafficking which
include “false work pretenses,” and intimidation. Control is maintained by threats, intimidation,
assault, and force on the victims to name a few.
According to the Uniform Crime Reporting Survey between 2009-2016 95% of the victims
identified were girls and women. 44% of victims were between 18-24 and 26% were under 18. In
2017 375 police-reported crimes contained trafficking in the crime. 291 people were accused of
human trafficking. A pie chart shows Ontario which had the highest number of human trafficking
offences between 2009-2016 but does not include a statistic. 44% is a significant part of the
victim population in police-reported crime which means that many resources need to be allocated

27
to help victims between the 18-24 category for human trafficking. Since 95% of victims are
females, most of the victim services should work on addressing other issues like violence against
women, domestic abuse, and barriers that some women may face when accessing victim
services. However, the statistics do not paint a clear picture since it provides statistics about
human trafficking as a whole. The statistics section in this report does not specify labour or sex
trafficking. The report makes multiple references to labour trafficking so it understands labour
trafficking but the statistics do not reveal the entire picture. The statistics do not also provide
statistics on which crimes were prosecuted in court so it does not say whether or not these
reported cases went to court. In addition, it does not describe who the accused traffickers were.
The statistics do not make that clear and it's vague.

28
Reported Cases of Labour Exploitation
Migrant Workers Alliance for Change. (2020). Unheeded warnings. COVID-19 & migrant
workers in Canada. https://migrantworkersalliance.org/wp-content/uploads/2020
/06/Unheeded-Warnings-COVID19-and-Migrant-Workers.pdf
If Canadians ignore labour exploitation then action cannot be taken to prevent it from a key
industry related to hospitality industry: agriculture. There was a report which revealed some
cases of exploited labour in Canada. In Migrant Workers Alliance for Change, there was a report
done which examined some cases of reported labour trafficking in Canada. The work conditions
were described by migrant workers. It was reported by a group of 100 migrant workers in 2018.
Some highlights include working for 17 hours a day, getting paid $5.00/hr (significantly less than
the minimum wage), having unsanitary drinking water, no sleeping privacy, and windows
blocking emergency exits (p. 6). It was also reported that concerns about this labour exploitation
were ignored by the federal and provincial governments in this country during the global
pandemic (p. 6). Before the pandemic, there was a hotline offered by this organization for
farmers in Niagara ON. Between March and May 2020, there were 180 phone calls reported of
labour exploitation, this was estimated to represent 1162 workers being exploited in the Niagara
region of Canada (p.7). Most of the calls were cases of labour trafficking in the Ontario region of
Canada. 1042 incident reports represented cases of men being labour trafficked, while 120
incidents represented females being labour trafficked. All of them were farm workers (p.8). Key
trends found were $57 369.46 unpaid wages stolen from workers where some of the deductions
were illegal, and others were withholding agreements under threats of deportation. There were
issues with gathering physical evidence. Many victims reported being afraid of developing

29
medical illnesses and losing income earnings to share with their families. Traffickers controlled
housing conditions for victims and there were no protections for them under migrant worker
status (p.8). Workers were also threatened with being handed over to the police by employers if
orders were not followed (p.9). Intensive farm labour has grown significantly from labour
trafficking due to cheap labour abuses which target migrant workers in Canada (p.9). The crop
production industry relies on foreign workers who formed 27.4% of workers in 2017 (p.11).
Working towards fair labour practices that criminalize labour trafficking could prevent cases like
this from happening in Canada. The signs of labour trafficking listed by the government website
earlier are consistent with the working conditions reported in these cases.
This report is very good for understanding labour trafficking as the non-profit organization here
describes many details that other sources have not provided. Multiple calls were made from the
Ontario region which is consistent with the statistics section where one of the articles said that
Ontario was the highest place where labour trafficking happened in Canada. The working
conditions being, unsanitary drinking water, and being paid much less than the minimum wage to
name a few, are present. Those fall under poor working conditions which are consistent with the
signs and factors present in labour trafficking. This report is more generalizable because it had a
much larger sample size and included reported calls where victims reported the crime. Not all of
labour trafficking is reported to the police but from these reported incidents more can be revealed
about labour trafficking in Canada. This is also an example of a key industry of labour trafficking
in Canada, the agricultural sector. As I mentioned in the previous paragraph, fair labour practices
can be made to prevent this. However, it is hard to say what that looks like just from this source
and little data to work with.

30
Luis Gabriel Flores Flores v Scotlynn Sweetpac Growers, [2020] 88341 (OLRB).
https://www.canlii.org/en/on/onlrb/doc/2020/2020canlii88341/2020canlii88341.html?searc
hUrlHash=AAAAAQA3THVpcyBHYWJyaWVsIEZsb3JlcyBGbG9yZXMgdiBTY290bHl
ubiBTd2VldHBhYyBHcm93ZXJzIAAAAAAB&resultIndex=1
There was a court case reported where the victim was referred to Migrant Workers Alliance for
change. (p.3). Every year Mr. Flores works in Canada as a seasonal migrant worker and in April
2020 he arrived at Scotlynn farm. The employer owns and runs a farm in southwestern Ontario.
The company hires migrant workers from Mexico for seasonal work. Government authorities
write the contract conditions without migrant workers' or employers' input. 190 Scotylnn workers
tested positive for the Coronavirus. There was a mandatory quarantine in effect at that time for
travellers coming outside of Canada. A professor, Susanna Caxaj, got him connected with the
Migrant Workers Alliance for Change. The living conditions after the quarantine were described
as bad inside the bunkhouse on the farm. On June 20 2020 a worker who personally knew Mr.
Flores died. This was reported to be from catching the Coronavirus after hospitalization (p.4).
Mr. Flores asked his boss for the day off to mourn his loss yet his boss was angry and said
workers would have to wait until June 21. This is important because the living conditions and
work conditions were poor. This makes victims like Mr. Flores vulnerable to being labour
trafficked. Mr. Flores was fired from work after talking to his employer about the working
conditions during the pandemic. Scotlynn was ordered by the judge to pay damages to Mr.
Flores. (p.1). It was ruled that Scotlynn Farms breached the contract and owed Mr. Flores money
for the damages to his health and lost wages (p.22). This case suggests that there was a conflict
between the duties of the employer and the employee along with abuses of labour. This is not a
clear case of labour trafficking but it shows similar signs in terms of illegal labour practices.

31
Hastie, B., & Yule, A. (2014). Milestone or missed opportunity? A critical analysis of the impact
of Domotor on the future of human trafficking cases in Canada.
https://www.canlii.org/en/commentary/doc/2014CanLIIDocs71#!fragment/zoupio-_Tocpdf
_bk_1/BQCwhgziBcwMYgK4DsDWszIQewE4BUBTADwBdoAvbRABwEtsBaAfX2zho
BMAzZgI1TMAjAEoANMmylCEAIqJCuAJ7QA5KrERCYXAnmKV6zdt0gAynlIAhFQ
CUAogBl7ANQCCAOQDC9saTB80KTsIiJAA
There is a commentary on the case of R v. Domotor, the original case is not published on Canlii
but the commentary is provided. More than 19 victims were labour trafficked through a criminal
organization in Hamilton, ON in 2011. This was the first successful prosecution case of labour
trafficking in Canada (p.83). This is the only labour trafficking case in Canada where prosecution
was successful. Men were recruited from Hungary to work in Canada and traffickers promised
these men a better life for their families. Banking documents were stolen from the traffickers
when the victims arrived, often were not fed food, and often worked without pay for 13-14 hours
each day, sometimes they would get paid a little bit. There were at least 2 examples of physical
violence towards these men by the traffickers. The men were forced to deposit stolen cheques
from Canada Post mailboxes and deposit the money into their bank accounts. Provinces in
Canada lost about $1 million dollars. Traffickers made money from the fraud scheme, stolen
cheques in the mail, and unpaid labour for the victims. The first conviction had a previous record
of a three-year sentence of sexually trafficking 2 minors. Another convicted trafficker previously
had a record of human trafficking and assault serving a sentence of 2 years. Another sentence
was 7 years which involved violence. The charges of the traffickers, in this case, were defrauding
Hamilton City under the Ontario Works Act, receiving material benefits from unpaid labour,
refusing to give the victims their immigration, travel, and Identity documents, human trafficking,

32
conspiracy in a criminal organization, and being part of a criminal organization. The sentence
was 9 years before credit reductions are possible. Furthermore, the scholar suggests this case had
“potential effects” on the pretrial detention process in human trafficking cases to come (p.86).
This case set a new precedent and carried with it the strictest sentence in Canadian history
according to the scholar. The accused, Domotor Jr. and Domotor Sr. pled guilty to the conspiracy
of trafficking people, counselling misrepresentation in the Immigration and Refugee Protection
Act, and participating in a criminal organization. Kolompar pled guilty to fraud exceeding $5000
and counselling misrepresentation in the Immigration and Refugee Protection Act. Domotor Jr.
received 5 years ``before credits” for the guilty plea and pretrial custody (p.88). Kolompar was
sentenced to fewer charges where legal counsel agreed. The scholar does not further elaborate on
what that agreement specifically was. (p.89). The scholar suggests that since the victims were
men in this case this shows that there need to be more community services that can be made
available to men. It also references the National Action Plan to Combat Human Trafficking. The
government's action plan mentions a border team but the scholar adds that this does not add
projects or practices for victim services in the Protection section of the plan. The scholar
discusses the Temporary Resident Program Canada offers. It gives “regularized” immigration
status to trafficked people in Canada which gives survivors basic needs, recovery and reflection
time. This scholar recommends that it extends up to three years. Considerations could include,
victims’ willingness to participate and help investigations and proceedings for trafficking crimes
and whether it is safe for victims to maintain permanent residence or start life again back in their
country of origin.
R v Ladha [2013] 2437 BCSC.
https://www.canlii.org/en/bc/bcsc/doc/2013/2013bcsc2437/2013bcsc2437.html

33
The victim M.H. brought the accused, Mumtaz Ladha to court. Ms. M.H. said that she was
tricked into taking a job as an esthetician in a hair salon. Mr. Ladha said she had planned to open
a hair salon in Vancouver. Upon arrival, she said she was working as a maid for the Ladha family
between 16-18 hours every day for 10 months. Mrs. Ladha said she befriended M.H. who
already worked as a housemaid when she was 14-15 years old. M.H. became pregnant and left
her job for a few years then got hired back as a cleaner for a hair salon. The judge noticed the
inconsistencies between the stories of the parties involved. The judge claimed that the evidence
of human trafficking was not beyond a reasonable doubt and the allegations were unlikely true.
From here the judge said that M.H. “[showed] a callous disregard for her benefactor and the truth
in the process.” This source works well because the judge highlights key charges and analysis of
the charges which can be found in detail by reading the full case. It starts with a summary then
followed by an analysis of the case. It is easy to follow and not as long to read as other cases.
Furthermore, it quoted the judge which conveys that judges do not always understand the full
picture. The judge said the victim was callous and does not recognize M.H. as a true victim.
Rather the victim is recognized by the judge as someone trying to take advantage of the legal
process. This highlights the bias and why cases do not always get a successful outcome. The
Domotor case had a successful outcome but this one has not. It also shows the challenges of
evidence being used in court for labour trafficking. The evidence in court will not always result
in a prosecution for labour trafficking. This case makes that clear.
Lang, G. (2018). Human trafficking allegations against bc woman proven false. R v. Ladha
[2013] BCSC 2437. Canlii Connects. https://canliiconnects.org/en/commentaires/63641

34
In the Ladha case, it involved labour trafficking where a Tanzanian woman immigrated to
Canada to work as a slave. Mutaz Ladha was acquitted of all charges involving labour
trafficking. The charges under the Immigration and Refugee Protection Act included: organizing
the arrival of foreign workers into Canada through fraud or deception, illegal employment of a
foreign national, misrepresenting facts of the High Commission of Canada under a temporary
resident visa, misrepresentation of facts to Citizenship and Immigration Canada to extend a
foreign visitor. The judge dismissed the victim's story and saw it as a way to “take advantage of
an opportunity she saw to remain in this country [...];” the judge dismissed the victim as not
credible.
This case shows that there are some cases where injustice persists in our criminal justice system
when judges fail to remain impartial. Furthermore, it describes the challenges with getting
prosecutions as judges do not always give full consideration to victims who come forward with
their stories about labour trafficking. It also highlights challenges when victims are not
considered credible to the judges in the courthouse. The charges laid resulted in acquittal but the
commentary review does not fully describe the case. Without enough information from the case
then generalizations cannot be made nor can this case be an example of labour trafficking very
well. It highlights a case where the victim lost the case. This source provides a direct quote from
the judge and highlights the charges in the case. However, the information is brief and does
explain in the same depth as the original case.
R v Orr, [2015] 88 (BC CA). https://www.bccourts.ca/jdb-txt/CA/15/00/2015BCCA0088.htm
There was a case involving labour trafficking. The victim was from the Philippines and left in
2000 to work in Saudi Arabia, Hong Kong, and Lebanon. After that, she worked for a family in

35
Hong Kong in August 2007. The family told her about moving to Canada and that she could
come with them. The family promised to help her to establish permanent residence status in
Canada after 2 years. She had a temporary work visa and was not required by law to get a work
permit as a domestic caregiver. The police came to visit the house. She told the trial judge that
she was exploited as she worked 16 hours a day for all 7 days of the week, she was banned from
visiting people outside the Orr household and denied her religious freedom. The Orr family
denied her freedom to attend church, her passport was stolen from her, her communications with
her family in the Philippines were controlled by the Orr household, and she was banned from
personal autonomy by not having the freedom to leave the house alone. The Vancouver Police
constable kept notes of her investigation. A criminologist was brought to testify in court and he
described domestic workers who experience learned helplessness when asking for help. He said
victims perceive this to become pointless as done through the manipulation process of the
criminals to the victims. He was asked to explain but was not asked about his research methods
or his incorporation of the evidence to inform his expert opinion. The judge thought this was
“prejudicial” and banned it from being used as evidence in a trial as “irrelevant.” The judge
acknowledged the criminologist as an expert in victimology but thought he had no authority to
express an expert opinion on human exploitation and the methods of criminal activity. His CV
would only count if being proposed as victimology instead of criminal behaviour. The judge
implied that the criminologist's testimony would hold the same weight as other witnesses without
any expertise. The court report quoted the judge: “It is up to you to decide how much weight you
will give to an expert opinion [...] You should consider carefully the testimony and opinion of an
expert witness just as you should consider carefully the evidence of any other witness.” The jury
acquitted Ms. Huen of all criminal charges on June 26, 2013. On October 15, 2013, Mr. Orr was

36
sentenced to 18 months in prison for the first count, 6 months concurrent to the 2nd count, plus
an additional 6 months on a third count. The Court of Appeal judge ordered a new trial as the
defence claimed that the expert testimony was “not qualified”. The appellant claimed that the
hypothetical questions asked to the expert witness were an error of the trial judge. The court of
appeal judge ruled that Ms. Huen’s acquittal was correct, the court of appeal judge also
confirmed the consistency of case law compared with this case.
R v Harlens Trucking, 2018 BCSC 1171.
https://www.canlii.org/en/bc/bcsc/doc/2018/2018bcsc1171/2018bcsc1171.html?searchUrlHash=
AAAAAQApUi4gdi4gSGFybGVucyBUcnVja2luZyBMdGQuLDIwMTggQkNTQyAxMTcAA
AAAAQ&resultIndex=1
There was a court case where Harlens Trucking pled guilty to criminal charges of
misrepresenting facts under the Immigration and Refugee Protection Act. Harlens Trucking was
ordered to pay $352 001.83. The second count was $10 000.00. Mr. Harlens requested the first
fine be reduced to $50 000.00. The Harlens company provided a delivery service to dry goods to
BC, AB, and the USA. Jatinder Kang was the businessman in charge of hiring people for the
temporary foreign worker program as several workers were not from Canada. He does not have
a criminal record. Some workers were Canadian citizens or had permanent resident status (p.3).
Furthermore, workers were entitled to be paid between $22.21/hr-$23.08/hr. 39 work permits
were granted to the workers under the temporary foreign worker program. Kang wrote in the
contract that workers would get paid $23.05/hr, 2 days off/week, and 50 hrs/week (p.5). The
company had planned to pay the workers $.40/mile which was different from the contract. If the

37
drivers got lost during the delivery they would only get paid for the distance travelling the right
way (p.6). There was a forensic accounting report shown by the crown during the court trial.
What is even more ridiculous is what the defence made up. The defence claimed that even
though facts were misrepresented to the government, Harlens and Kang still followed Canada’s
Temporary Foreign Worker Program laws. The defence denied financial losses of the workers
and disadvantages towards the workers (p.7). At least the judge rejected the defence argument;
the financial losses of workers were real. Both Harlens and Kang pleaded guilty to criminal
charges. The judge said that Kang appeared to show remorse and commitment to community
service. The judge also said that the moral culpability was lowered for the guilty parties as the
truck driver workers got permanent resident status afterwards. The judge ordered a 2 year
probation period as a sentence.
This case is not labour trafficking but it counts as labour abuse which can lead to labour
trafficking. The workers were not forced to work as they agreed to a contract of work. This
counts as labour abuse because of the financial harm caused by the employers. They stole
workers' wages and failed to honour the employment contract. The consequence as ordered by
the judge is probation and a huge fine. Justice is served in this case but unfortunately, that is not
always the case in labour trafficking cases. In the previous case with the Orr family, the judge
was biased and denied expert testimony as valid evidence. In the Harlens Trucking case, the
judge not only believed the victims and the impact the crime had on victims but ordered stolen
wages to be paid back through a huge fine.

38
News Article Cases
Alberga, H. (2023). Migrant workers sneak secret menus into Canadian restaurants to expose
exploitation. CTV News Toronto.
https://toronto.ctvnews.ca/migrant-workers-sneak-secret-menus-into-canadian-restaurants-t
o-expose-exploitation-1.6257199
In the Caregiver program provided by the federal government, most migrant workers lost their
employment status and did not receive an employment opportunity. Another criticism was raised
by a speaker in a newspaper article. It stated that while the Prime Minister promised to increase
tracks available for temporary foreign workers to become part of the permanent resident status.
The speaker is disappointed with the lack of action from the federal government. This newspaper
article stated that migrant workers have added QR codes to restaurant menus which link to
labour exploitation abuses as a secret menu (Alberga, 2023).
Senoran, H., & Sharpe, K. (2022). Injured migrant farmworkers fight for fair compensation from
WSIB. CTV News Kitchener. https://kitchener.ctvnews.ca/injured-migrant-farmworkers
-fight-for-fair-compensation-from-wsib-1.6094015
It exposes the realities of the costs of foods eaten by customers. The Migrant worker's alliance
for change was credited for this action. Below each menu item, there’s a survivor's story from
labour trafficking. Another newspaper article highlighted another activist group, Justice for
Migrant Workers, in which migrant farm workers have been harmed coming from dangerous
working conditions. There was a letter sent to the Workplace and Safety Insurance Board in
Kitchener, ON. They want death and injury prevention, stop cutting wages, and a permanent
immigration status option to name a few. The Ontario labour ministry disclosed to the news

39
reporters that over 100 new workplace inspectors were hired. The employment minister in
Canada said that laws were amended in the Immigration Refugee Protection laws that came into
effect in September last year. This suggests that there is a grey area between government
intervention and activist groups advocating for fighting against labour trafficking in Canada.
Brach, B. (2015). Domino's workers in North Vancouver allege exploitation. CBC News British
Columbia. https://www.cbc.ca/news/canada/british-columbia
/domino-s-workers-in-north-vancouver-allege-exploitation-1.2955648
There was a BC case in the news a few years ago that reported about two former domino workers
who were abused in the workplace and perceived the work to be similar to slavery. They reported
that the employer never paid them for their work. They refused to work one time and one of the
workers got violent against the victims. One of the victims, Dearman, submitted a complaint to
the Employment Standards Branch and the worker's compensation board. It was also reported
that the owners stole tip money from the tip jar which was supposed to be for the employees. The
other victim, Brulhart, felt intimidated by the owners. He also said that employees got deducted
from their pay every time a mistake was made. Both of the victims got fired. The news article
states that the RCMP is in the investigation process. The owners refused to talk with the news
reporters and deny the allegations against them. I also did a search of the victims on Canlii and
no cases were found written here.
Comeau, T. (2022, Aug 11). Two charged with human trafficking: RCMP say they've identified
five victims. Chronicle Herald.
https://www.proquest.com/canadiannews/docview/2701079307/E828288724894602PQ/5?
accountid=1343

40
There was a case reported of the RCMP laying charges for labour trafficking and sex trafficking
against two men. Last year on June 9, the Nova Scotia human trafficking unit received a tip
about a woman being trafficked. Information identifying the accused was not released to the
public as the police say this could link to the victims and risk victim information being exposed.
The first man accused was charged with 33 offences which include 5 counts of human
trafficking, assault, and uttering threats to name a few. The second man was charged with human
trafficking and also uttering threats to name a few. As of August 2022, this investigation has
been ongoing. So it is likely not reported in a CanLII case report yet if it does get published.
National Post & The Canadian Press. (2022, May 11). Mountie charged with human trafficking.
Toronto unit. The Windsor Star.
https://www.proquest.com/docview/2662234852/431027EC9AFE402FPQ/13?accountid=1
343
Another case involved an RCMP officer charged with labour trafficking and animal cruelty. The
constable was suspended with pay and arrested. The victim who reported this said that this
officer brought the victim from Mexico to Georgina, Ontario. The work agreement was not
honoured by the trafficker as the working conditions were poor for the victim who was recruited
to work with animals. The police are currently investigating this. It is also believed by the police
that there might be other victims out there besides the one who reported this incident. The article
closes by listing the same factors as listed above in the government web pages examples which
described signs of labour trafficking in Canada. Unfortunately, this newspaper article describes
very limited information. It could be due to the limited information that the reporter found or a
lack of information available. This case was also recent so the investigation might not be yet

41
complete. What is strange about this case is that a police officer was charged with labour
trafficking. The accused in this case is different from the accused in other cases. This case is
unique but continues to suggest that labour trafficking in Canada is widely not understood.
Juha, J. (2019, Dec 24). Rare human trafficking charges laid; Police allege three people created a
scheme to traffic migrant workers. The London Free Press.
http://libproxy.mtroyal.ca/login?url=https://www.proquest.com/newspapers/rare-human-tra
fficking-charges-laid-police-allege/docview/2330267733/se-2
In another reported case from London Ontario, charges of human trafficking were laid by the
police against three citizens in London, Ontario. After a year of investigation, which suggested
that this happened between 2015-2017. The migrant workers were from Guatemala and the
accused would pretend to be a lawyer and property owner who needed workers. The passports
were seized after arrival in Canada. The working conditions would be poor and worked in
multiple different private houses. The water and electricity were turned off in one of the houses.
Workers were threatened by the traffickers that if they did not obey, then the police would be
called and deported back to Guatemala. All three of the accused were released from custody and
are supposed to appear in a court trial in February 2020. One of the people charged with the
crime, Jose Callejas, was sentenced in 2018 for illegally employing 17 foreigners that were not
allowed to work in Canada. He was ordered by the court to pay a fine of $10 000.00. A social
worker from Windsor Ontario commented that labour trafficking charges are rare in Canada. I
did a search in CanLII for both of the accused names that were reported and labour exploitation,
and human trafficking and the accused names; I found no results. This was likely not published
in the court case reports.

42
I did a search in CanLII for both of the accused names that were reported and labour
exploitation, and human trafficking and the accused names; I found no results. This was likely
not published in the court case reports. This is a real case of labour trafficking presented in the
news but it was not found on CanLII. This shows that not all cases reported in the news will be
in court reports. Something to keep in mind is that not all cases presented in the courthouse will
be published on CanLII so there could be cases that are just not known about. Conditions present
in this case include, poor working conditions, recruiter who deceived workers, threats of calling
police and deportation. Furthermore, I mentioned earlier that migrant workers were significantly
impacted by labour trafficking in Canada. This case is an example of that. Lastly, the conditions
of labour trafficking were present in this case example yet not much is known about it.
Overall Analysis of News Websites
Another part to remember is that the credibility of the newspaper reporter does not hold the same
weight as peer-reviewed articles. Newspaper articles are published with different purposes and
intentions behind it. The newspaper companies need to make a profit so the more attention
grabbing the article the more likely citizens will consume it. Newspaper reporters do not have the
same familiarity with legal terminology nor criminological concepts as scholars in criminal
justice. Newspaper journalists also might not know much about the prosecution process so those
details could be missing from the newspaper article. In addition the facts presented and the
methods for presenting them are not the same as academic articles. Newspaper articles do not
cite their sources in a scholarly manner nor do they provide sources which can be used to
fact-check.

43
Legislation Section
Criminal Code. R.S.C., 1985, c. C-46. https://laws-lois.justice.gc.ca/eng/acts/c-46/page-1.html
Labor trafficking violates our laws in Canada as can be seen in our criminal code but also in the
Charter of Rights and Freedoms. The Criminal Code of Canada (CCC) states that: 279.01 (1)
“Every person who recruits, transports, transfers, receives, holds, conceals or harbours a person,
or exercises control, direction or influence over the movements of a person, for the purpose of
exploiting them or facilitating their exploitation is guilty of an indictable offence”.
Some punishments include: 279.0 (1a-b) “to imprisonment for life and to a minimum
punishment of imprisonment for a term of five years if they kidnap, commit an aggravated
assault or aggravated sexual assault against, or cause death to, the victim during the commission
of the offence”; (section b) “to imprisonment for a term of not more than 14 years and to a
minimum punishment of imprisonment for a term of four years in any other case.”; 279.02 (2)
“Everyone who receives a financial or other material benefit, knowing that it is obtained by or
derived directly or indirectly from the commission of an offence under subsection 279.011(1), is
guilty of an indictable offence and liable to imprisonment for a term of not more than 14 years
and to a minimum punishment of imprisonment for a term of two years.” This is the criminal
code version of human trafficking but does not have a specific section dedicated to labour
trafficking or even sex trafficking. The criminal code does not have a specific section indicating
labour trafficking so there’s no specific legislation towards labour trafficking found in the CCC.
It describes generally human trafficking but does not use labour trafficking-specific terminology.
But doesn’t the section describe/include trafficking regardless of the type?

44
Canadian Charter of Rights and Freedoms. 1982. Part 1 of the Constitution Act, 1982, being
Schedule B to the Canada Act 1982 (UK), 1982, c 11.
Labour trafficking infringes on the Charter right section 6. It states in 6(1) “Every citizen of
Canada has the right to enter, remain in and leave Canada”. Not all victims of labor trafficking
will be citizens necessarily but victims who do will have their mobility rights infringed on in
constitutional law. When victims of labour trafficking become victimized, the trafficker controls
the movement of the victims. By controlling the movement of the victims, the traffickers take
away the freedom of the victims to move freely in Canada. Labour trafficking as a crime also
infringes on mobility rights in constitutional law. Understanding labour trafficking also means
understanding how it infringes on mobility rights in Canada. However, since this charter right
(mobility rights) applies to citizens and permanent residents only it cannot be used to explain
labor trafficking crimes when the victim is not a citizen nor a permanent resident of Canada.
Immigration and Refugee Protection Act S.C. 2001, c. 27.
https://laws-lois.justice.gc.ca/eng/acts/I-2.5/page-15.html?txthl=trafficking#s-118
The Immigration and Refugee Protection Act (IRPA) has a section on human trafficking. Section
118-trafficking of persons (1) says that “no person shall knowingly organize the coming into
Canada of one or more persons by means of abduction, fraud, deception or use or threat of force
or coercion”. This is the only section in the IRPA that has a specific reference to human
trafficking in Canada. It does not describe what human trafficking is in the same way that the
Criminal Code does. IRPA describes human trafficking as deception, abduction, fraud and force
which is all a part of exploitation but does not include the terms recruitment, harbouring,
transporting, or controlling movements of people which are included in the Criminal Code. This

45
suggests that IRPA has different applications when compared to the Criminal Code. As discussed
later in the prosecution section, there are different criteria for human trafficking in Canada. The
definitions described in IRPA make this clear. It is also not clear in IRPA whether there is a
specific punishment laid out for people found guilty of this crime. Finally, the offence under
IRPA does not specify labour or sex trafficking so it cannot be clear how effective this law works
to specifically combat labour trafficking in Canada.
The United Nations. (2021). Protocol to prevent, suppress and punish trafficking in persons,
especially women and children, supplementing the United Nations Convention Against
Transnational Organized Crime.
https://www.unodc.org/res/human-trafficking/2021the-protocol-tip_html/TIP.pdf
Article 6 of the United Nations trafficking laws says that it will help and protect victims of
human trafficking (p.43). One of the ways to achieve this includes state parties of the United
Nations will provide victims with legal information about the court administrative process, and
help with the physical, psychological, social, and recovery process for victims of human
trafficking, through counselling, medical help, housing support, employment training programs,
acknowledge unique needs for children, age, help with physical safety and options for financial
compensation (p.44). This legislation was designed to address human trafficking in general so
there is no indication of targeting the response for labour trafficking in the world.
Lemahieu, Me, & Ye. (2023). UNODC, Global report on trafficking in persons 2022.
https://www.unodc.org/documents/data-and-analysis/glotip/2022/GLOTiP_2022_web.pdf

46
The United Nations released a report highlighting a planned response to tackle human
trafficking. Some highlighted findings included that war conflict areas are “hunting grounds” for
traffickers, women and children are the most vulnerable to violence, the more organized the
crime is the more violence and exploitation for extended periods of time, more impunity inside
the home countries so then victims are trafficked to more places (p.2). During the global
pandemic victims were less likely to be detected for the first time in 20 years, and law
enforcement had fewer opportunities to intervene during the pandemic (p.3).
Commentaries on Legislation
Muchka, A. (2021). Traffick stop. Addressing labour exploitation of migrant workers in Canada.
https://summit.sfu.ca/item/34462
A student researcher conducted research comparing labour trafficking to sex trafficking (p. xiv).
She specifically stated that the temporary foreign worker program had a strong influence on
labour trafficking in Canada as Canada relies on temporary foreign workers when the labour
market has shortages. Barriers to reporting this crime include accountability that is ineffective,
poor incentives to report, and data that cannot be relied upon. Policy suggestions included reports
being mandatory, directions for permanent residency, work permits designed for specific
occupations, and employee connections. (p.xiv). The researcher examined protections for
migrant workers in Canada and what legislative barriers could exist. This researcher conducted a
literature review and used semi-structured interviews with labour trafficking experts to identify
alternative approaches compared to the current ones used (p.24). Some of the results included
jurisdictional issues, victim justice, understanding of human trafficking applied, criticisms of the
Temporary Foreign Worker Program, and victims coming forward with their stories.

47
Jurisdictional issues include the decentralization of stakeholders who were in contact with the
victims when they came forward.
This article is relevant because it compares labour and sex trafficking and helps to address the
research gap in labour trafficking compared to sex trafficking. It mentions the Temporary
Foreign Worker Program which appeared multiple times in the literature from other sections of
this project. The researcher suggests that accountability needs to be improved, mandatory crime
reporting of labour trafficking and more help with work permits and permanent residency for
victims of labour trafficking.
Guilmain, L. M., & Hanley, J. (2020). Creative recourse in cases of forced labour: Using human
trafficking, human rights and labour law to protect migrant workers. International
Migration, 59(2), 126-139. https://doi.org/10.1111/imig.12743.
This article offers a commentary on current legislation involving labour trafficking in Canada.
Legal scholars emphasize the need for legislation to broaden to include a specific section on
labour trafficking. Right now the current laws rely on human trafficking as a whole. The
researchers suggest that human trafficking laws do not specifically address the problem of labour
trafficking in Canada. Researchers discussed Bill C-423 which would be the Modern Slavery Act
in Canadian Parliament. This bill would mandate companies to report crime prevention of labour
trafficking in supply chains. The bill was not successful in passing through the stages after in
Parliament. It was narrow as it did not include sectors with large amounts of immigration
examples being agriculture and domestic work. The authors, therefore, conclude that Canada
depends on human trafficking laws when dealing with forced labour cases. This author refers to
labour trafficking as forced labour and suggests that it is possible for foreign workers to be

48
forced labour in Canada due to the temporary foreign worker program. This article focuses on
labour and human rights law for its sources (p.127). Canada signed the Palermo Protocol which
began to come into force in 2002 and human trafficking was not added to the criminal code until
2005 (p.127). Between 2005-2019 there were 581 recorded cases of human trafficking
accusations. 22/581 were international cases, and 559/581 were within Canada. Most Canadian
cases involved sexual exploitation while most international cases involved forced labour.
According to the Trafficking National Coordination Centre. This is all that is included in this
research article. The researcher said that most human trafficking cases were sex
trafficking-related and that convictions are rare (p.128).
This article references Canadian statistics and discusses specifically Canada’s Temporary
Foreign Program. It provides recommendations to improve it and make it better suited to meet
worker protection needs. It discusses the supply chain as a core factor when preventing and
intervening when this crime occurs in Canada. Although the proposed bill did not pass into law it
did offer a solution to dealing with this problem. It said the bill could have been improved by not
making it too narrow. This article is peer-reviewed so it can be trusted with accurate information
about labour trafficking.
Rodgers A. (2018). Envisioning justice for migrant workers. A legal needs assessment.
https://mwcbc.ca/downloads/MWC_Envisioning_Justice_for_Migrant_Workers_Report.pd
f
A report was done examining the legal needs of migrant workers in the temporary foreign
worker program in Canada (p.2). This was focused on BC trying to understand the barriers that
exist for foreign workers to access justice. This was examined through legal services and the

49
information that comes with it (p.2). The research study included semi-structured interviews and
online surveys. The target population was lawyers, union workers in BC, and non-profit
organizations to name a few.
The largest category was 30.8% of migrant workers who reported that they were
unfamiliar with their obligations and rights during work under BC law (p.29). This shows that
not all migrant workers know about their rights during work and could be at risk for labour
trafficking in Canada. ⅓ of respondents reported that they were unfamiliar with minimum wage
laws and overtime pay. Only 10.3% of respondents were familiar with safety and health-based
laws in BC (p.30). This suggests that there is a significant educational gap in labour rights for
newcomers to Canada. Affirming the legal rights of the migrant worker is a challenge. One of the
findings from one of the focus groups included a participant being afraid of what could be lost
when filing a lawsuit against the organization for labour rights violations. This person was
worried about not having a house and being forced to sleep on the streets by the employer if the
lawsuit was filed. If this participant lost employment status then it could take months to find
another job to replace the current one (p.37). This is important as this is one of the reasons why
this crime is underreported. When victims fear the potential consequences of reporting the crime
then they want to be able to survive financially. It takes a risk which the victim may believe is a
worse outcome than leaving the exploited job. One of the labour lawyers explained that victims
might not want to report the crime out of fear of being deported. This can happen with victims
who are aware of their rights (p.37). This could prevent future employment of the victim where
the traffickers throw victims into a trap where they control the choices of the victim.

50
This article explains the barriers which victims face when accessing justice. It compiled data
from both surveys and interviews. Since it used a mixed methods approach it was able to
combine quantitative and qualitative data. This is important because not all of the literature that I
found used mixed methods to examine labour trafficking. By incorporating both approaches it
could address limitations that one method would have. Along with statistics from the report it
describes why some crimes are not reported. It mentioned that victims fear deportation and even
victims who know their rights could be afraid. This article must be included to explore why
labour trafficking is not widely understood. Without victims who reported the crime, it could go
unnoticed and injustice persists. The organization that wrote the report is specifically involved in
advocating for labour rights of previously trafficked victims so the organization is a reliable
source. The legal barriers may differ by province so it cannot be said whether it is greater for
some compared to others. However, these barriers could exist in other provinces of Canada too.
Drydyk, J. (2020). Human trafficking trends in Canada 2019-2020. The Centre. Canadian Centre
to End Human Trafficking.
https://www.canadiancentretoendhumantrafficking.ca/wp-content/uploads/2021/10/ENGHuman-Trafficking-Trends-in-Canada-%E2%80%93-2019-20-Report-Final-1.pdf.
In 2019 a hotline number was released to the public for confidential information offering help in
multiple languages about human trafficking. It has over 900 connections to social and legal
services. It also reported that between 2019-2020 there were 415 cases of human trafficking but
did not elaborate on details of those cases. This is part of a crime prevention strategy started by a
non-profit that is active in the crime prevention process. However, only reported cases are
recorded in that report. There could be other cases that are not known about right now.

51
The report said that 7% of cases which were identified by the hotline of human trafficking were
reported to the police. The hotline will only report when the victim or survivor gives consent,
minors are involved, or if there is an immediate danger to the survivor or victim on the phone
line. If cases reported here outweigh the number of cases brought forward to the police, it means
the data can provide insight into overall cases including ones not reported to the police. This can
help fill a research gap when it comes to analyzing cases of human trafficking in Canada. 71% of
cases were sexual trafficking and 7% were labour trafficking. 20% involved human trafficking
where it was not reported under sexual or labour trafficking. The cases of labour trafficking
represented a minority of reported cases to this hotline compared to sexual trafficking. That
means that even this data cannot be used to generalize labour trafficking trends in Canada as the
dataset is small. The report also stated that friends and family were a significant part of cases
coming forward to the hotline centre. Between 2019-2020 26% of trafficking signals came from
families and friends. This would be during the early luring stages and ongoing human trafficking.
However, oftentimes essential details are missing from the family members that make it harder to
determine whether the case is an example of human trafficking.

52
Detection, Investigation & Prosecution
Canada Border Services Agency. (2020). Human trafficking at the border.
https://www.cbsa-asfc.gc.ca/security-securite/ht-tp-eng.html
The criminal justice system is the main organization in charge of crime prevention. Here
is some context for the current response toward labour trafficking. According to CBSA, they
help combat trafficking by examining signs of trafficking across borders and supporting the
prosecution of criminals and investigation of them. They also help determine potential victims
and give them the referral they need to other public services. The government website includes
actions such as conducting pre-screening for potential victims before arrival, sharing intelligence
with data trends on trafficking, security checks, investigating individuals accused of organized
crime, and being part of criminal investigations. This includes instructions for law enforcement
employees to follow when detecting potential victims of labour trafficking but it does not
provide examples. Without examples that gives more room for discretion and a response that
may be less effective than it could be. This area of policy response could be improved.
Royal Mounted Canadian Police. (2022). Recognizing human trafficking victims.
https://www.rcmp-grc.gc.ca/en/human-trafficking/recognizing-human-trafficking-victims.
The RCMP website included more context on crime intervention which helps with understanding
the context better. The Royal Mounted Canadian Police stated that the identities of traffickers
include small family criminal groups, individuals working to make money from this crime, and
transnational organized crime groups. Victims are deceived through control of money, living
arrangements, relationships, passports and other identifying documents. It is isolating and
manipulating and can be done through extortion.

53
Another concept to understand is the work environment, RCMP officers work in a different
environment so they notice different suspicious activity than CBSA officers. RCMP are not
confined to the airport so they can track crime between provincial borders and notice signs of
human trafficking between provincial borders. CBSA officers work with people entering and
leaving Canada so they can notice signs of labour trafficking that occurs between federal borders.
RCMP officers are not limited to working in one place for their entire shift, whereas CBSA
officers are.
Public Safety Canada. (2022). National strategy to combat human trafficking. Annual reports.
2019-2024.
https://www.publicsafety.gc.ca/cnt/rsrcs/pblctns/2019-ntnl-strtgy-hmnn-trffc/index-en.aspx
The federal government reported on human trafficking. It states a plan to combat labour
trafficking by determining the long-term methods to address forced labour and child labour
within federal procurement supply chains. This involves collaborative work with international
partners, the private sector, and civil society. developing an advisory committee to include the
voices of human trafficking survivors. They will also increase funding for community programs
designed with a trauma-informed lens to help survivors reintegrate into society. This report was
very vague and did not include much beyond collaborative work. This suggests that nonprofits
are more aware of how labour trafficking works within Canada. The government stresses
working with multiple agencies to combat trafficking which is good but it lacks plans. A plan
needs to include specific actions to prevent the crime from happening and how they plan to
intervene when the crime takes place. One reason could be that the government is not as
educated on the topic as academics or non-profit organizations. Perhaps the current government

54
departments overseeing the issue are working with other agencies to figure out the problem
before allocating resources to address it. Regardless of the vagueness of the plan the government
appears to be working on a solution or steps to arriving at a solution as a starting point.
Canadian Council for Refugees. (n.d.). Human trafficking and the law: How to protect trafficked
persons. a guide for legal practitioners.
https://ccrweb.ca/sites/ccrweb.ca/files/human-trafficking-law-guide-web.pdf
Canada’s legislation on labour trafficking describes human trafficking charges. Under the
Immigration & Refugee Protection Act (IRPA), only human trafficking cases which cross
Canadian borders can be prosecuted under this act. The survivor has to be the one who crosses
the border for law enforcement to lay criminal charges. If prosecuted under the Criminal Code,
each province prosecutes the charges (p.7). Other common charges under IRPA include human
smuggling, charges involving officers, abetting, aiding, and counselling another person to breach
IRPA. Part of the criteria to get a prosecution includes the victim claiming a fear of safety. This
has been challenged suggesting that this is too narrow of an approach since traffickers don’t
always threaten safety. It can be deportation or even indirect threats to the victim’s family, not
just the victim. The author suggests that laying charges can be inaccessible from this current
legislation (p.9). The author suggests that the BC model of an open work permit for migrant
workers can help protect trafficked victims.
This source works very well in describing human trafficking and how legal practitioners can
help. It describes the criteria for protection under the Immigration and Refugee Protection Act
and the Criminal Code as each legislation works differently. That is important because in my
case examples above not all are prosecuted under the same piece of legislation. In addition, it

55
describes common charges under the Immigration and Refugee Protection Act when prosecuting
human trafficking in Canada. The scholar mentions that threats are not always directly pointed at
the victim’s safety; they can be threats to families too. This highlights something that appears to
be missing within the scope of the prosecution criteria. If the criteria were expanded as the
scholar suggested, this could help identify victims of human trafficking more clearly.
Furthermore, it makes specific references to labour trafficking under the Temporary Foreign
Worker Program talking about how an open work permit can help protect migrant workers from
labour trafficking.
Government of Canada (2012). National action plan on trafficking.
https://www.publicsafety.gc.ca/cnt/rsrcs/pblctns/ntnl-ctn-pln-cmbt/ntnl-ctn-pln-cmbt-eng.p
df.
This national action plan became Bill C-310 (An Act to amend the Criminal Code (trafficking in
persons) to include human trafficking as a criminal offence in the Criminal Code of Canada.
Police officers also have access to Canada’s Financial Transaction and Report Analysis Centre
which gives financial intelligence. This source provides potential links from money laundering to
suspected human traffickers (p.17). Honourable Toews writes that a training module was
designed for service providers and first responders to respond and become aware of human
trafficking signs. He adds that law enforcement will also help with the crime prevention process
(p.11). The report talks about a plan to address human trafficking but does not specify labour
trafficking specifically and is vague. It mentions bringing agencies together to educate and train
professionals yet does not describe how. It’s a promise by the Canadian government to help
address the crime yet no action plan.

56
Government of Alberta. (2020, April 7). Bill 8: Protecting Survivors of Human Trafficking Act.
https://www.alberta.ca/release.cfm?xID=7002356624840-01AA-3C2B-B128FAB3D44461
9C
There is also another Bill being introduced, Bill C-452. Lastly, legislation has been put into
effect about the process of restraining orders in human trafficking. The provincial government is
also working on providing training resources for Alberta employees (Alberta Government, n.d).
The Alberta government has also released a report which stated that in 2018 there were 12 cases
of reported human trafficking in Alberta. Some measures include standardized meaning for
human trafficking, a warrant which allows police officer entry, and a statutory tort which allows
victims to sue their traffickers.
This is an important source because it describes what Alberta is doing to tackle human
trafficking. It is not specific to labour trafficking but it gives a statistic about the number of cases
in Alberta. It describes specific measures while highlighting it is a starting point for the Alberta
government which is trying to tackle this issue. A limitation of this webpage is that it does not
describe in detail since it highlights the report and also the webpage is difficult to navigate. There
is a link to the action plan and protection plans but the link is not easily accessible. The
Protection Plans Act links to the Legislative Assembly of Alberta but does contain the actual
piece of legislation. In addition, the action plan link just elaborates further describing the same
point in the highlights on the webpage. The limitation of this webpage is that the quality of
information made available is not as good as other reports from the Canadian government or
non-profit organizations.

57
Larios, L., Hanley, J., Cardona, M. S., Henaway, M., Shaer, N. D., & Soltane, S. B. (2020).
Engaging migrant care workers. Examining cases of exploitation by recruitment agencies
in Quebec, Canada. International Journal of Migration and Border Studies, 6(1-2),
138-157. https://www.inderscienceonline.com/doi/epdf/10.1504/IJMBS.2020.108690
There was a study done examining labour exploitation intervention measures by a non-profit
organization. It measured the response the organization had toward providing support to migrant
care workers (p. 141). There has been some provincial regulation across Canada for migrant
workers but the report suggested that more is needed from the federal government. This study
featured a longitudinal design with migrant workers in temporary employment organizations in
Montreal. The data collection was via interviews and it took 3 years to complete. In addition, this
study combined data from the Immigrant Workers Centre and PINAY. The later data focused on
cases with complaints about recruitment practices in Montreal. (p. 146). Recruitment fees were a
common finding in the data collected. A technique of labour trafficking included charging an
expensive fee for workers to connect with employers despite violations of law in Canadian and
international law (p. 148). Care workers were recruited by friends and family. The average cost
was significantly higher for immigrants who have not settled in Canada yet. Foreigners who
want to immigrate here already have to pay a fee for the application process and these
recruitment organizations were adding a fee to pay. The case file report showed that in some
instances immigrants did not receive the services promised and the employers refused to
reimburse the fees. Employers pressured immigrants into working illegally without a permit.
Cases reveal that workers were not getting paid for their work, did not show a contract, and
workers were required to work in multiple different houses. This report also revealed that
workers did not want to leave the abusive worker relationship because of fear of immigration

58
status loss. There was a fear of housing and income source loss. Workers had families to provide
for and they stayed in the abusive employee relationship (p. 149).
Musto, J., Thakor, M., & Gerasimov, B. (2020). Special issue: Technology anti-trafficking and
speculative futures. Anti-trafficking review,(14), 1-14.
https://antitraffickingreview.org/index.php/atrjournal/issue/view/22
This literature review report talks about the role technology plays in combating trafficking as it’s
suggested less is known about technology contributions to trafficking compared with policy and
law responses (p.5). Unregulated technology platforms will likely result in more profit for big
companies and protect user privacy. Some data entrepreneurs have made technology to “disrupt”
suspected trafficking activity. Some say this is taking technology and presenting the trafficking
responses as humanitarian rescuers. Some think that more data can have more prediction abilities
but fewer explanatory abilities (p.7). Some suggest that companies and individual consumers can
combat it rather than policies at the state level in the USA. This author suggests that
technological interventions to tackle trafficking are ideologically based and lack evidence.
Second, the author suggests that current technology interventions have little to no effect in
combating trafficking. It is also suggested that technology-based anti-trafficking interventions
overlook the deregulation of labour markets, “strict” migration policies, and discrimination based
on gender.
This article discusses the role of technology in combating trafficking. It is new and has different
perspectives on its effectiveness in tackling human trafficking. Some think it can be part of a
humanitarian response to address human trafficking and others suggest the data’s explanatory
abilities are lacking. Others suggest that factors like discrimination based on gender or

59
deregulated labour markets can be overlooked. All of this points to the complexities of labour
trafficking. Furthermore, this could be because the technology is new and without much
knowledge about how it could help some may doubt its effectiveness. Finally, this was an
American study so it cannot be generalized to the Canadian context.
Farrell, A., Dank, M., Vries, I., Kafafian, M., Hughes, A., & Lockwood, S. (2019). Failing
victims? Challenges of the police response to human trafficking. Criminology & Public
Policy., 18(3), 649–673. https://doi.org/10.1111/1745-9133.12456
This American article talks about the police response to human trafficking which includes labour
trafficking incidents too. The challenges of detecting trafficking cases include the secretive
nature of the crime and also police bias against victims who break the law like prostitution
activity or undocumented immigrants. Police are less likely to recognize prostitutes or
undocumented immigrants (p.652). Some victims might not report the crime since they have a
negative perception of law enforcement or believe that the police will not understand their
situation. The author says that complex trauma is related to distrust of the police. The researchers
in this study based their findings on data of police-reported trafficking crime and interview
information with service providers and police in American communities. It was found that it was
rare for victims and their families to report the crime. In some cases of human trafficking,
victims are at the pre-contemplative stage of leaving the trafficking scenario. One police
detective said that victims are in the survival mentality so they are not thinking about telling the
police. They want to figure their life out and “move on'' (p.661). Labour trafficking victims
wanted wage remedies instead of arrests by the police of the traffickers. Victims were not

60
satisfied with the prosecution as the sentence was perceived as too lenient. The outcomes of
cases impact victims who are hesitant to request prosecution to intervene.
I think this goes to show that victims coming forward do not believe justice will be served when
criminals are charged, prosecuted, and sentenced. Victims do not believe their voice is heard and
even if it is, the intervention to address it does satisfy their expectations. Victims are frustrated
with the current responses of the criminal justice system so that seems to suggest that the current
response needs to change and improve. It also suggests that victims make their decisions of
reporting crime based on their bad experiences. They do not trust criminal justice workers to
handle it so they try to move on rather than face the problem. This is likely due to the lack of
confidence in themselves after the trauma that occurred from their victimization. Oftentimes they
want to survive and do not think the same way law enforcement does. This is the criticism the
article gives when the response is not victim-oriented. This criticism is valid because
The issue with this article is that it is American, it does not provide Canadian context so
comparisons cannot be made. However, it discusses victimization and why some crime does not
get reported to the police. That is key for understanding labour trafficking responses.
Broad, R., & Muraszkiewicz, J. (2019). The investigation and prosecution of traffickers:
Challenges and opportunities. In Winterdyk J., & Jones J. (Eds.), The Palgrave
International Handbook of Human Trafficking (pp.707-723). Springer International
Publishing. https://doi.org/10.1007/978-3-319-63058-8_43
This entry discusses the prosecution processes during human trafficking in the Canadian context
as well as in other countries. Canada was one of the first countries to ratify the Protocol, and the

61
2012 National Action Plan to Combat Human Trafficking (p.713). In 2012 the human trafficking
minimum sentence increased from 2 years to 5 years. In 2017, traffickers needed to prove that
their property was not obtained through criminal activity. Control had to be part of the criteria for
evidence to prosecute traffickers. The CCC and National Action Plan to Combat Human
Trafficking said there could be helpers to testimonies. This included a different location than the
courtroom and support (ex. Victim representatives support workers). If victims wanted
temporary or even permanent residence they did not need to give evidence in court. This entry
referenced the Domotor case and talked about gaps in human trafficking case responses.
Provincial versus federal level cases did not always have the same legal procedures for gathering
evidence so sharing it was problematic. Between 2012-2016 there were 307 human trafficking
cases yet only 45 convictions were for human trafficking-specific criminal charges. This entry
highlighted that finding data on the prosecution process was difficult due to offences not
consistently being reported under the same definitions, lack of accessible data, and lack of
cooperation from victims with the police. Victims could risk being deported or losing their jobs
when reporting to the police. The Canadian government has focused on sex trafficking crime
intervention instead of labour exploitation. More collaborative work is suggested.
This entry is great as it describes legislation and law enforcement procedures. Although vague it
explains why it is vague and the difficulties of finding data on police evidence gathering and
arrest procedures. It acknowledges the imbalance between sex and labour trafficking in Canada.
It examines other countries for comparison of crime intervention by law enforcement.
Sikka, A. (2013). Labour trafficking in Canada: Indicators, stakeholders, and investigative
methods. Public Safety Canada. https://publications.gc.ca/site/eng/442851/publication.html

62
This archived report specifically separates detection from the investigation. The detection section
of the report stated that in cases involving physical harm workers escaped and called the police.
This was uncommon for victims since often victims were afraid of deportation. Sometimes law
enforcement was called by the police to investigate fraudulent based recruitment procedures or
accusations of workers for misconduct. The case data from this report came from NGOs that
dealt with migrant worker problems. Parliaments and Legislatures in Canada received the
reports. A few cases were detected through victims who wanted to have refugee status at
Canada’s Immigration and Refugee Board. Multiple cases did not indicate whether CBSA or
police agencies were involved. In the investigation section, some victims of labour trafficking
would be afraid of their safety of life but in a few cases, threats of the victim's families existed.
Although victims were afraid of their traffickers, “Criminalization” or deportation threats were
related. Investigators cannot assume that just because there is no physical fear, it does not mean
that there is no exploitation, deception, or force. It’s possible that recruiting, advertising,
transporting, and renting premises to workers are legal. The work contract and what is advertised
is the key part of the evidence. Sources of this data could come from interviews with victims but
also other workers who are called “Canadian nationals” by the report. Standardized procedures
might not be effective since the evidence is not clear whether organized crime “enterprises” are
committing labour trafficking criminal offences. Documents that are fraudulent could give proof
of labour trafficking. Some reports lacked evidence that the documents were fraudulent. The
caregiving and domestic sector have dominated the reporting of illegal work entries.
This Canadian report discusses law enforcement intervention and the challenges of
understanding its procedures. Even though this archived report does not describe specifics of law
enforcement procedures it talks about the challenges where case reports did not mention law

63
enforcement’s involvement. Most of the case data did not come from government sources, it was
from NGOs and only sometimes from the Immigration and Refugee Board. Very little data exists
or it just is not publicly available. It is clear that evidence gathering is unclear and what has
happened to lead to labour trafficking criminal charges.
Department of Justice Canada. (2015). A handbook for criminal justice practitioners on
trafficking in persons.
https://www.justice.gc.ca/eng/rp-pr/cj-jp/tp/hcjpotp-gtpupjp/hcjpotp-gtpupjp.pdf
There was a handbook made for criminal justice workers dealing with labour trafficking. There
have been multiple ways to tackle human trafficking. Some include understanding labour and
development, human rights, migration, violence against women, and organized crime (p.13). The
source makes more references to sex trafficking than labour trafficking. The report handbook
also recognized trauma. It listed symptoms including denial of being a victim of human
trafficking, challenges explaining clear statements to the police, “Depersonalization of the
abusive experience,” coming up with reasonable parts to the traumatic situation in memory
which has blanks, pieces of perception, memory, sense of time, consciousness, and feeling
(p.37). A recommendation in the report is to help the victim feel secure and safe. It also
acknowledges that some NGOs will know more about how to provide support compared with
law enforcement resources. Under the collecting evidence section, it listed signs of labour
trafficking combined with signs of sexual trafficking. It included bad living conditions, fear of
safety and intimidation and control, and deception about the work contract in terms of its legality
to name a few.

64
The benefit of this source is that it provides the multiple ways that labour trafficking is dealt
with. It outlines how labour trafficking is investigated and prosecuted in Canada. It also talks
about symptoms of labour trafficked victims which include memory challenges, denial of
victimhood and explaining clear statements to the police to name a few. Victims with challenges
communicating what happened to the police mean that it is difficult for police officers to report
what they hear from victims. This is likely a part of the reason why the data available on labour
trafficking is so scarce. Without clear statements, the police do not have much data to publish so
the government can then make it accessible to the public. It acknowledges that NGOs will
sometimes know more about resources to help victims than the police. This is consistent with
findings from other government reports where the data does not always reveal the same kind of
information as the non-profit reports.
Surtees R., & Johnson L.S. (2021). Trafficking victim identification: A practitioner guide.
Regional Support Office of the Bali Process. NEXUS Institute.
https://s3.ap-southeast-2.amazonaws.com/assets.baliprocess.net/app/uploads/2021/12/1314
0303/Trafficking-Victim-Identification_-A-Practitioner-Guide-NEXUS-and-RSO-2021.pdf
This source talks about how to identify victims of human trafficking. Some highlights include
intimidation, how victims are afraid of becoming identified when traffickers use intimidation
violence, threats, and control of their victims. It also highlights the psychological and physical
impacts on victims who are trafficked. Sometimes victims do not think reporting the crime will
lead to assistance so they do not report it. Furthermore, victims do not always want to be
involved when helping the police investigate the crime. Also, some victims are independent or
already have other supports so they have no incentive to report the crime to the police. The report

65
also highlighted that practitioners may hold bias based on misconceptions and stereotypes of
victims leading to additional challenges in identifying victims of human trafficking. Victims can
often have experiences with the police where screening is seen as an interrogation rather than an
interview and some stakeholders are not trained well enough to help victims.
The benefit of this source is that it highlights a few challenges that were not specifically
mentioned in other sources I found about the challenges of detecting victims in labour
trafficking. It discusses victims who do not want to get involved with legal investigation aspects
and that some victims are already independent so there is less incentive to report the crime.
These challenges mentioned that were not mentioned in other research reports could help fill the
research gap about labour trafficking in Canada. It shows something that was not previously well
known from other research reports. Unfortunately, the signs police look for are broad and this
guide itself presents many challenges with identifying victims of labour trafficking. This goes to
show that even a well-done report has limitations. Furthermore, it does not make specific
connections between sexual and labour trafficking. It is broad and cannot be used to generalize
about labour trafficking.

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Recruitment Process, Causes & Theories of Labour Trafficking
How Are Victims Recruited By Traffickers?
Royal Mounted Canadian Police. (2022). Recognizing human trafficking victims.
https://www.rcmp-grc.gc.ca/en/human-trafficking/recognizing-human-trafficking-victims
Recruitment tactics by the traffickers include making internet posts for jobs, kidnapping threats,
social media contact and promises of education or work. People at risk include youth,
Indigenous, living in poverty, substance abuse, and migrant workers to name a few. Traffickers
will control living arrangements, relationships, locations of work, money, and Identification
documents. Traffickers could be individuals working for profit, transnational criminal
corporations, small family crime groups, or decentralized criminal groups who harbour,
transport, and recruit victims. Unfortunately, this webpage is brief but this is what is available
from the government. Other government reports as listed in previous sections focus on the crime
response and current legislation surrounding it.
Dandurand, Y., Chin, V., Wilson, L. (2017). Improved response to labour trafficking.
International Centre for Criminal Law Reform and Criminal Justice Policy
https://www.researchgate.net/profile/Yvon-Dandurand/publication/315694809_Improved_
Response_to_Labour_Trafficking/links/58dc5dc9458515152b4e4f0a/Improved-Response-t
o-Labour-Trafficking.pdf
Another report also stated that not many cases of labour trafficking have been prosecuted let
alone reported in Canada and this crime is not often reported to authorities. This source also
confirms that construction, agriculture, and hospitality industries are common industries for

67
labour trafficking in Canada. Some examples of labour trafficking conditions include
undocumented work where employees are paid little to none, experiences of racial or sexual
harassment and fear tactics. The recruitment process into domestic servitude involving labour
trafficking includes dishonest promises, fraudulent job offers, and abusive cultural traditions.
Cases of labour trafficking reported by service providers and community organizations do not
always get investigated by legal authorities. Some challenges to detecting domestic servitude as a
form of labour trafficking is that the crime itself is hidden as the victims are socially isolated
during work. It is more common for the domestic worker to be a migrant worker. The work
environment can then become the living place which forces them to always be available to
provide work-based services. Furthermore, the work agreement is usually not written down in a
contract format.
When work agreements are not written down in a contract format then employers can make up
conditions of employment without consent of the victim. This denies the victim personal
autonomy and can be controlling. With worker protection rights, employers can easily exploit
workers. This report highlights the main challenges with detecting, investigating, and
prosecuting cases of labour trafficking within Canada. This crime is not often reported to
authorities. For example, it mentions domestic servitude in which victims are socially isolated. It
cannot be easily known and sometimes the work contract is not written down. Without key
documents, cases can go unnoticed and crime intervention cannot take place. In addition, it
discusses signs which include fraudulent job offers, dishonest promises, and abusive cultural
traditions. These are signs to be looking for but these signs themselves are not obvious. For
example, there could be multiple fraud jobs existing but victims vulnerable to this will not

68
understand it being fraudulent. Traffickers exploit victim’s vulnerabilities and this is not easy to
detect.
Withers M. (2016). Psychological tactics used by human traffickers. A look at seven common
manipulation tactics used by traffickers. Psychology Today.
https://www.psychologytoday.com/us/blog/modern-day-slavery/201610/psychological-tacti
cs-used-human-traffickers
There was a public health academic who wrote about how human trafficking tactics work.
Traffickers will regularly tell their victims that they are commodities who are forgotten.
Psychological abuse and threats are common through the alienation process during trafficking.
They begin to believe they are helpless and lose a sense of self-worth. Traffickers will threaten
victims by threatening to spread rumours about criminal activity if orders are not followed.
Traffickers will be on close watch of their victims and always be around victims everywhere they
go. Psychological abuse being harder to detect is the type of abuse that traffickers use to avoid
detection by authorities. Traffickers also make false promises of releasing victims when the debt
is paid.
There is a major gap in the research about how human trafficking works and the process behind
it. From a Google search, this article was the most relevant article discussing how human
trafficking works. It is an American author but it focuses on the psychological aspects of
trafficking so it can be used. In addition, the author is an academic in the psychology field which
means that the source is reliable when describing the psychological parts of human trafficking. A
limitation is that this does not describe labour trafficking specifically it is more broad. This is
evidence that labour trafficking is not understood very well and relies much on human trafficking

69
in general. These signs of human trafficking are also similar to signs of labour trafficking
described on the Canadian government webpage. Unfortunately, Psychology Today does not
provide a reference list to compare sources so it cannot hold the same weight as a peer-reviewed
source. However, this source can describe psychological factors associated with signs of human
trafficking.
Hopper, E.K. & Gonzalez, L. D. (2018). A comparison of psychological symptoms in survivors
of sex and labour trafficking. Behavioral Medicine, 44(3), 177–188.
https://doi.org/10.1080/08964289.2018.1432551
There was an American study completed on the mental health effects of human trafficking on
survivors. Survivors were both labour and sex trafficking. There was a high rate of PTSD and
Depression reported by the participants. Survivors of labour trafficking had lower rates of
previous abuse during childhood than survivors of sex trafficking. Researchers indicated that
coercion by human traffickers often includes spoken threats, physical assault, emotional abuse,
and trauma toward the victims (p.177). The interview-based data from the study revealed that
50% of sex-trafficked youth experienced sexual and physical violence during the trafficking
process (p.177). These coercion tactics as mentioned by the researcher are important to
understand so that criminal justice agencies can respond to signs of criminal activity. Although
the focus of my research project is not mental health, this is an important article to explore labour
trafficking within the Canadian context. Unfortunately, I used a library search to find similar
articles that also talk about recruitment tactics of labour trafficking but I did not find anything.

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Theories & Explanations Of Labour Trafficking In Canada
Sikka, A. (2010). Trafficking of Aboriginal women and girls in Canada. Aboriginal Policy
Research Consortium International (APRCi), 57. R.
https://ir.lib.uwo.ca/cgi/viewcontent.cgi?article=1387&context=aprci
This author suggested that early settlers had a bias towards Indigenous women suggesting sexism
directed against women of Indigenous background. The report suggests that this could be
colonial violence due to bias. Indigenous people were sold into chattel slavery by the British
Empire just before 1834 when this practice was abolished (p.207). Since the statistics suggest an
overwhelming percentage of victims of human trafficking are Indigenous, this discussion needs
to be included. Although this article references sex trafficking, it adds to the current context of
labour trafficking in Canada. It shows the limitations of current research in labour exploitation
since this study focuses on sex trafficking instead of labour trafficking. This source mentions a
barrier to understanding why human trafficking persists. The sense of community has been lost
once it has been broken down as a part of overrepresentation as victims of this crime. One of the
harms the Indigenous nations face from this victimization is that some Indigenous have
internalized human trafficking as part of their daily lives and they have not been taught about the
harms this crime brings (p. 201). Adding on to the historical context colonialism has impacted
Indigenous victims of crime. During the colonial period, poverty became more common among
Indigenous people and they relied more on the colonial state to provide for their needs. Some
statistics suggest that there was a lack of crime prevention aimed at protecting Indigenous
women from violence.

71
This perspective is important because there could be a bias when understanding labour
trafficking cases involving Indigenous people. It highlights the focus of sexual trafficking but
acknowledges the gap in labour trafficking. The community sense of belonging can often be
missing within Indigenous communities making them vulnerable to becoming victims of labour
trafficking. Another part highlights the internalized belief that some Indigenous people have
while being trafficked. The final part discusses poverty and how Indigenous communities have
relied on the government during colonialism to provide for their needs. This is important because
while Indigenous people experience these barriers the internalized belief discussed above can
highlight why some crimes might not be reported to the police. If the victims within the
Indigenous communities do not understand the harm of labour trafficking then they will not
report it to the police. Part of the gap in cases of labour trafficking might be because some
Indigenous victims do not come forward with cases of suspected labour trafficking. The last part
about violence is relevant because without proper protections against violence then violence like
labour trafficking of women the crime can persist.
Meshelemiah, J.C.A., & Lynch, R.E. (2019). The cause and consequence of human trafficking.
Human rights violations. The Ohio State University Pressbook.
https://ohiostate.pressbooks.pub/humantrafficking/chapter/chapter-3-theories-and-human-tr
afficking/
This chapter discusses human trafficking and adds theoretical explanations to human trafficking.
Conflict theory is defined as the study of power dynamics and oppression via structural conflicts.
The original theory had its roots in Marxism from the original 19th-century context. Conflict
theorists ask how does the structure contribute to social inequalities? It assumes that conflict

72
creates competitiveness in which people are forced to compete for wealth and resources and are
self-interested. This theory is a part of social work practice. This theory suggests that the main
contributors to human rights violations are classist, sexist, and racist which allow oppression to
continue. The Structural-Functionalism theory states that understanding the purpose behind roles
in society will explain society. Cheap labour maximizes profits from a functionalist perspective.
Human rights violations happen for a purpose. Social work practice suggests that crime
prevention through social work practice is required to stop the demand for labour exploitation.
Labelling theory suggests that crime is understood through labels. Criminal behaviour exists
through labelling criminal activity. Labelling theory also allows law enforcement agencies to
identify and refer victims to the correct services.
These theories would be supportive of legislation changes as suggested previously by the article
on RCMP-reported cases of human trafficking. Why do labour traffickers exploit their victims?
Cheap labour will maximize their self-interested criminal goals. Without laws to protect labour
rights and advocate for victims, they will continue to be silenced. That’s why it matters to talk
about this and use evidence-informed research.
Maslow’s Hierarchy of Needs is identified as a relevant theory to human trafficking according to
this book reference. The bottom needs are safety and psychological needs as basic needs with
self-actualization at the top. The chapter states that people have criticized this for being
reductionist and ignorant of cultural factors. However, since my research is in the Canadian
context that criticism is not very strong. The author suggests that understanding Maslow’s
hierarchy of needs can inform the understanding of human trafficking. Traffickers provide needs
which are missing for victims and use them to lure victims in. This theory suggests that survivors

73
of human trafficking cannot fully heal from trauma until all needs are met from the basic needs
on the bottom to the top reaching self-actualization. Crime intervention must be effective, but
helping survivors recover from the traumas endured during the trafficking will not work unless
Maslow’s hierarchy of needs is addressed. This author offers a reasonable explanation.
Enrile, A. & Aquino, G. (2018). Survivor advocate model: Ending human trafficking and
modern-day slavery. SAGE. https://doi.org/10.4135/9781506316789
This source refers to Maslow’s Hierarchy of Needs. It explains why victims' physiological needs
must be met as the first step towards helping victims and advocating for them. The perceived
sense of safety among victims is different from survivors of human trafficking. People
intervening in this crime need to understand that victims need to have their safety needs met.
They may have not been physically threatened but the safety of their families could have been.
The next level of Maslow’s Hierarchy includes belonging. This can be developed through trust
and being vulnerable with others. This also goes with the fourth level of building confidence.
This research entry suggests that survivors will become self-advocates and empowered to do so
when they become self-actualized. Being able to change society cannot happen if the victims are
not self-actualized according to this research entry. Furthermore, the author concludes by saying
that there is no universal path to self-actualization. Each individual has a unique experience.
This encyclopedia entry works great because it applies Maslow’s hierarchy of needs directly to
victims of human trafficking. It takes theory and applies it so legal officials can work with it. It
explains the basic needs of victims and how that needs to be identified first before helping the
victims become self-advocates as the source mentions. It highlights the different stages of
Maslow’s hierarchy of needs and how that impacts labour trafficking intervention measures. Not

74
all sources describing labour trafficking make references to Maslow’s Hierarchy of Needs. This
source does it effectively.
Smith, A. (2021). Does Economic Development Have an Influence on Human Labor Trafficking?
Thesis. Georgia State University. https://doi.org/10.57709/22642566
A thesis project talked about labour trafficking from an economic development perspective. This
author suggested that poverty causes labour trafficking and that economic development will
determine the amount of labour trafficking within a country (p.1). Further on it is suggested that
if policy changes are made to improve life qualities to lower the number of victims of labour
trafficking (p.2). The author continues to explain the economic conditions of labour trafficking
by referencing Adam Smith. Smith suggested that compensating workers with pay would
increase the incentive to work compared to enslaved populations. The author suggests that since
the 18th-19th century, workers were more productive as the abolition movement spread. She
predicts that measures to end labour trafficking will lead to increased economic development
(p.3). She further goes on to say that some countries will have a high GDP rate because
economic inequality persists. Poor conditions increase the chances that people will become
victims of labour trafficking. The author concludes by mentioning the Human Development
Index Score which was used in the study. The HDI Score was found to influence the amount of
labour-trafficked victims. The author said this could help with policy changes. She suggested that
an area of improvement includes the structural aspects of labour trafficking. This includes scarce
job opportunities, poor education, and poor healthcare. She said that policy needs to tackle
labour trafficking within their supply chains. She acknowledges that there has been legislation on

75
labour trafficking but concludes with economic development increases from crime prevention.
She emphasizes the controlling aspects of traffickers rather than the profit generated.
The study focuses on cases in India and China. A limitation of this source is that it only
explains poverty, economic development, and labour trafficking within countries with very
different socio-cultural aspects than Canada. The Canadian context cannot be explained using
this source because Canada has a very different economic, political, and legal system. A benefit
of using this source is that it mentions economic aspects of labour trafficking which was not
discussed in the same depth as other sources. The conclusion is very generic and she suggests
that her case studies from India and China can be generalized to other countries. However, as
mentioned above I disagree with this. The reason is that the cultural and legal context is
different. Both China and India are at different development stages compared with Canada.
Poverty could have different impacts in Canada as there are different laws in place. For example,
Canada has social services available to help people in poverty but those same social services
might not exist in China or India. They could be run differently since the government operates
differently there. Furthermore, the laws are not the same so the economic impacts from laws
around labour will have different impacts here in Canada. The Canadian context is not explored
in her thesis work. However, despite the limitations in this data, this provides a perspective about
labour trafficking that was not explored to the same extent as this study. Without this thesis
source, the economic aspects of labour trafficking might be less well understood. It also
mentions the HDI Score which was not mentioned in the other sources reviewed in this
annotated bibliography. This source is unique and reveals something that was not previously
considered by other labour trafficking sources. Furthermore, this author is peer reviewed and
provides an exhaustive overview of the economic development features of labour trafficking.

76
Ontario Women’s Justice Network. (n.d.). What is Human trafficking?
https://owjn.org/2018/06/12/what-is-human-trafficking-2/#:~:text=Interrelated%20%E2%8
0%9Cpush%E2%80%9D%20and%20%E2%80%9Cpull,instability%2C%20war%20and%
20conflict%20situations.
This website talks about push and pull factors which increase the risk of being trafficked. Push
factors include gender inequity, political instability, war & conflict, unemployment, poverty, and
lack of access to social programs. The pull factors include promises of money, demand for cheap
labour, and promises of a “better life.” This source also states that most human trafficking
reported cases are sexual exploitation. It goes on to explain specific factors related to sexual
exploitation. It does not have a specific section on labour trafficking. However, these push and
pull factors can be compared with the previous article on economic development. A lack of
economic development within a country suggests that there is unemployment, poverty, and
sometimes political instability or war. If the economic development of one country is low then
labour trafficking can continue to occur within structures. However, as mentioned above this
does not explain the cultural aspects and this website does not explain cultural factors related to
push and pull factors.
Catholic Relief Services. (2016). Trafficking in persons.
https://www.crs.org/sites/default/files/crs_tip_policy_paper_lr.pdf
This report includes references to the causes of labour trafficking. Poverty combined with other
factors including political, economic, and social factors contributes to human trafficking.
Addressing the supply and demand is required to fight against human trafficking. The economic
factors are explained. It is more common in places where people live across regions where there

77
are different economic development levels or where the poor and rich live close by. Without
legalized movement, many victims travel without documentation and cannot be protected.
People are more vulnerable to exploitation under these conditions. Other factors include political
corruption. Some governments in the world have corrupt law enforcement accepting bribes for
trafficking. Traffickers will also target refugee camps and exploit refugees who lost their jobs
(p.6). Sometimes if the traffickers or smugglers do not get immediately paid, the victim could
end up in debt bondage. Specific factors listed include gender stratification, dysfunctional
families which come from families involved in alcohol and violence, prejudice against women
by devaluing them, poor labour market regulation, criminalization of victims of crime, domestic
violence, poverty, and weak rule of law. (p.16). This source lists more factors related to human
trafficking compared with the thesis project source which focused on economic development. A
limitation of this source is that it does not cover much depth of those specific factors. This could
be because charities do not necessarily have the same access to research resources as the
government or universities. This study makes policy suggestions but in the American context so
it will not address the Canadian context.
Sarrica, F. (2022). The use of human trafficking detection data for modelling static and dynamic
determinants of human trafficking flows. European Journal on Criminal Policy and
Research, 28(4), 483–501. https://doi.org/10.1007/s10610-020-09460-5
This source talks about the challenges of measuring human trafficking. The author suggests that
this is part of the reason why quantitative studies are new in human trafficking research and
cannot be used to generate research in the international context. The author takes statistical flow
analysis from official statistics of detected victims to understand why specific countries match

78
more relevant factors than others. Relevant factors include population size, organized crime
levels, and distance to chosen destinations. Key factors that stood out include national wealth
generated from the country of origin and unemployment (p.483). Researchers predicted that
economic changes inside the country of origin can impact the flows between places.
Understanding the economic changes will be able to predict how intense the flow is (p.486). The
researchers suggested that better economic development in the country of origin would likely
result in more careful choices which reduce the risk for exploitation. Their data confirms this.
Victims in Eastern Europe have dropped slowly inside Western Europe for the past 15-20 years.
The Russian GDP/Capita was found to be correlated with fewer Russian victims inside Germany.
The same result of Russian victims is from the Netherlands region.
The limitation of this study is that this focuses on European countries, and human trafficking in
the Canadian context could be different. An advantage of this study is that it does not only focus
on sexual exploitation, it acknowledges the lack of research in labour trafficking. The research
article compares unemployment rates with understanding flow but it talks about European
countries, not Canada or the USA. This research suggests that unemployment is a significant
factor in labour trafficking but only describes it within the European context. Results from this
study cannot be generalized to Canada because the laws and policies work differently there.
Winterdyk, J. (2019). Explaining human trafficking: modern-day slavery. In Winterdyk J., &
Jones, J. (Eds.), The Palgrave International Handbook of Human Trafficking
(pp.1257-1274). https://doi.org/10.1007/978-3-319-63058-8_68
This source talks about theoretical explanations for human trafficking along with the causes of
criminal activity. The push and pull factors are the leading explanation for human trafficking.

79
The push factors include civil conflict, globalization, political instability, poverty, limited
education, social inequalities, and an environment where improved quality of life is unlikely to
happen. Traffickers take advantage of these risk factors and exploit their victims. These factors
are consistent with the source from Ontario’s Women’s Justice Network in terms of the push and
pull factors as they list similar ones. This suggests that the push and pull factors are not merely
made-up ideas but are backed by other research saying the same thing.
The next theory referenced is capitalism theory where Marx discussed the economic changes
from the feudal system to the capitalist system. Private ownership was the new means of
production. Another explanation is that an unequal distribution of resources while economic
greed violates human labour rights. Maximizing profit means that businesses will secure cheap
labour costs. A globalized free market economy offers a competitive environment to fuel greed.
Some people exploit this system of economics toward vulnerable populations. The countries that
suffer the worst from human trafficking have the worst human rights protections for workers.
They become the main targets for traffickers. This explanation is strong for explaining the
economic perspective of labour trafficking and why it continues to persist. It adds a human rights
approach whereas the push and pull factors are more descriptive. The Marxist view explains
labour trafficking well which makes sense considering the time that Marx was writing in. It also
explains the damaging effects of unregulated capitalism and how free market economics can be
taken advantage of by traffickers.
Duque, R. B. (2021). Applying classical theory in a comparative study of the information
revolution in the less developed world. Space and Culture, 24(2), 240–262.
https://doi.org/10.1177/1206331218807087

80
This article explains what functionalism is. Functionalism assumes that modernity develops
when cultures and structures change themselves. The Industrial Revolution is an example of this
shift. These changes include new technologies, globalized markets, increased populations, liberal
economics, economic developments, urbanization and more factory work as opposed to domestic
work. Social displacement results when modern interactions begin. Social environments become
more narrow, social contacts increase, multiple social roles develop, and social reforms continue.
In the past decade, Ghana child slavery has been reported mostly coming from the Cocoa
Plantation sector yet according to this source the primary school enrolment there is near 100%.
Most of Ghana’s population is urbanized and the literacy rate is 76% among adults. Ghanaians
have one of the highest rates of mobile phone subscriptions in Africa so their social contacts
have increased. Society has changed in Ghana and technology there too.
The downside of this source is that it does not apply this theory to crime, it focuses on
technological developments but also in Ghana specifically. It does not explain the Canadian
context or countries which may have similar economic systems and growth rates as Canada does.
This suggests that not much research has been done explaining social theories and applying them
to specific crimes. However, it does explain the environments which could contextualize the
issue of labour trafficking with further research.
Bowersox, Z. (2022). Union density and human trafficking: Can organized labour discourage
trafficking? Journal of Human Trafficking, 1–14.
https://doi.org/10.1080/23322705.2022.2073095
This research article suggests that there are two primary factors which make labour trafficking
possible. Lack of bargaining power and lack of information. Researchers predicted that a

81
stronger labour union presence is suspected to reduce the likelihood of forced labour occurring
by the researchers. Researchers did logistic regression tests and the hypothesis was true (p.1).
This study was done in the American context. The article suggests that without a reduction in the
supply of labour and demand for it labour exploitation will be encouraged. The researchers also
say that labour unions or this research will explain if labour unions will factor in the political,
social, and economic variables that increase victim vulnerabilities (p.9). Within the international
context, more competition in domestic industries can encourage the movement of labour across
borders. This author says that private industry attempts to regulate conditions and practices for
labour make unequal results (p.10). However, the author does not provide further context for
what is meant by “unequal results.”
This research is a good explanation of labour trafficking. It focuses on 2 factors. Lack of
information and lack of bargaining power; both of these factors are available when workers are
unionized. Researchers completed quantitative tests to see if their hypothesis was correct. Results
suggest that it was correct. The researchers also acknowledged limitations about the economic,
social, and political variables that are not answered by the research hypothesis. It discusses
supply and demand which were not discussed by other articles above examining causes of labour
trafficking.

82
Conclusion
This research aimed to answer the question, what is the context of labour trafficking in
Canada? This included understanding appropriate legislation, statistics, relevant cases of labour
trafficking in Canada, the recruitment process of victims into trafficking, and the detection,
investigation, and prosecution of labour trafficking in Canada. Causes and theories of why and
how labour trafficking occurs were examined too. The methodology to explore this topic was an
annotated bibliography. It summarized and analyzed each source briefly answering each section
relevant to the research question. The search strategies included recommendations from
librarians at Mount Royal University and some search terms included, “labour trafficking”,
“forced labour”, “labour exploitation”, “conflict theory and labour trafficking”, and “Maslow's
hierarchy of needs and labour trafficking”. The legislation and cases were Canadian examples,
but the theories were not specific to the Canadian labour context. Nevertheless, I pulled apart
core concepts from sources and emphasized why more research is needed in this area of
criminology.
The benefit of this type of research is that exploratory designs work great for researchers
who do not know much about the topic. The research question was generic because the current
literature on labour trafficking is not yet robust. This research also highlights research that
already exists before suggesting new directions for further research. Another benefit is that there
is no main theoretical paradigm to frame the methodology. It considers both sources from the
qualitative and quantitative approaches while acknowledging the limitations of each source.
The biggest challenge during research on labour trafficking is that very little research has
been done. Most studies are relying on existing legislation around labour trafficking and

83
especially in the international context. There are also very few cases involving labour trafficking
that have been reported to the police in Canada. They do not always result in a conviction and
most of the cases from the news have not appeared in CanLII. Therefore, it is not certain that
those cases went to court. Unfortunately, research gaps continue to exist, and this method of
research cannot address all the research gaps. The limitations of this research method are that it
surveys multiple sources but does not provide an exhaustive list of all the relevant data. It
analyzes multiple sources and tries to find themes in the literature. The research scope broadened
from my original research proposal and had less information than I originally anticipated.
Another limitation of this study is that criminological research is naturally
interdisciplinary and does not have a specific focus when researching specific crimes. Multiple
theories from both psychological and sociological perspectives have been used to explain the
criminality behind human trafficking in general. However, most research does not have a specific
angle from which to examine crime in Canada. It does not limit itself to using one method as it
has that flexibility for examining criminological concepts. A final limitation to my research is
that I am not an expert on this subject and have not worked in this field before. I do not know all
the factors involved in labour trafficking and hold my biases about the subject. Despite this, this
research is a first step towards understanding labour trafficking in Canada.
For example, future researchers could try to understand the risk factors and test which
ones are the strongest. Researchers would need to rely on secondary or primary research data that
could measure those specific factors amongst multiple populations of interest, then compare the
results. Push and pull factors could test specific variables like poverty and supply and demand. A
question could include: How does poverty affect victimization in labour markets? How does it

84
impact exploitation? To what extent is the pull factor of poverty impacted by the supply of labour
and the demand for continued exploitation? Another example is theory testing. If researchers
wanted to test which theory is the best for labour trafficking explanations, then researchers could
design a survey and experimental design to test which theory is the most plausible. Researchers
can test for specific variables and control for factors to ensure the relationship between them is
not spurious. Theories could include Marxist conflict theory and Functionalist theory. Theories
could also include the push and pull factors studies which are not merely descriptive but test the
variables, and economic development within the Canadian context like the study conducted in
the thesis article mentioned in an earlier source. Marxist conflict theory could be tested by
examining inequalities and this could be done by measuring wealth gaps in sectors which impact
labour markets the most. For example, restaurants and hotels. Secondary data from labour unions
could be used since they are already advocating for worker rights. They might have reported on
labour and factors which could impact inequality.
If researchers completed a case study review comparing multiple cases, they could
examine core themes amongst the case studies and try to understand which legal practices seem
to be the most effective for getting a conviction. If researchers completed qualitative research
involving focus groups or interviews, they could understand the experience of each victim from
labour trafficking and get them involved in advocating for this cause. Another research question
could include to what extent are police resources effective in combating labour exploitation. If
not, what are ways to improve the criminal justice response and how can the government help?
The key takeaway from my research project is that labour trafficking in Canada happens.
There are cases and statistics to describe its existence, but the current criminal justice response

85
can improve. A significant way to get involved in this cause is to understand the current
situation, what the research says about labour trafficking, and what can be done to make a more
effective criminal justice system for dealing with crime, in this case, labour trafficking.

86
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