The Coalition of Finnish Women’s Associations NYTKIS thanks for the opportunity to give our statement on the recommendations given by the Committee of the Parties to the Council of Europe Convention on Action against Trafficking in Human Beings for Finland on the issues for immediate action identified in the second report of the Group of Experts on Action against Trafficking in Human Beings (GRETA).
After the issuing of the second GRETA report, several actions have been taken to advance the rights of victims of trafficking in human beings (THB). The Ministry of Social Affairs and Health has set up a Ministerial Working Group, which has been tasked to draw up and submit a proposal for legislation on helping victims of THB. New legislation aims to improve the rights and services of victims of THB. The Ministerial Working Group consists of representatives from several ministries, governmental agencies and municipalities. The only non-governmental organization (NGO) represented in the working group is Victim Support Finland (Rikosuhripäivystys RIKU), which has evidently been tasked with representing all other NGOs in the working group. This objective, however, is unrealistic, as a single NGO is unable to present the viewpoints of all other relevant and specialized NGOs. There is also the concern that an understanding of gender-sensitive issues and gender impacts will be lacking in the new proposed legislation.
Concurrently, the Ministry of Justice has set up a working group tasked with developing the National Action Plan addressing all forms of THB. Positively, there are several NGOs represented in this working group. There is a need to develop and implement a national referral mechanism (NRM) for all sectors of the government to identify victims of trafficking and refer them to the appropriate services. There is a need to implement the NRM as soon as possible and not wait for the legislation proposals of the Ministerial Working Group at the Ministry of Affairs and Health. Legislative improvements may take several years, however there is an immediate need to enhance victim identification and the referral of victims to the Victim Assistance System via the NRM. The roles and responsibilities of NGOs within the NRM must also be defined and made clear.
There are major differences between municipalities in terms of services provided to victims of THB, despite the amplified guidance given to municipalities and social workers. The equal treatment of victims of THB are not realized. In practice, the services provided to victims of THB depend largely on which municipality the victim seeks aid in.
Currently, there is some discussion on if victims benefit from being accepted into the Victim Assistance System, as some municipalities may offer the same services needed for victims as according to the Social Welface Act, whether or not the individual has been accepted to the Victim Assistance System or not. It must also be noted that victims who receive services from the municipality, but are not in the Victim Assistance System, are not officially recognized as victims of THB and are thus missing from official statistics. This also affects the development and maintenance of a comprehensive and coherent data collection system and national database on THB, a recommendation issued by GRETA for Finland in its second report.
Recently, due to investigative journalism by Helsingin Sanomat there has been an increase in public discussions and media reporting on THB, specifically labor exploitation. This is important, but there is a need to raise awareness on other forms of THB, such sexual exploitation and prostitution, and how they are gender-specific and a continuum of gender-based violence.
Forced marriage is considered a form of THB in Finland and its separate criminalization is under review. There has been an increase in cases in recent years, but there have been no convictions in the courts.
The recommendations put forth by GRETA included the need to “increase the number of specialised shelters for victims of THB; if necessary, the Act on Shelters should be reviewed to enable the setting up of shelters catering for male victims of trafficking”. Currently, shelters for victims of domestic violence do not accommodate any victims of trafficking unless they are victims of domestic violence. There is a need to offer short-term specialized shelter services for victims of THB, as well as long-term supported housing accommodation. Shelter services are gender-neutral in Finland, but there is a need for a gender-sensitive approach to services provided to victims of THB. This also requires further training of social workers in shelters.
Adequate funding for NGOs is a constant concern,
especially now under the pandemic. Due to the pandemic there has been an
increase in the exploitation of victims of THB,
which further calls for steps to ensure adequate and long-term funding for NGOs
that provide specialized assistance to victims of THB.
 Ihmiskaupan uhrien auttamista koskevan lainsäädännön uudistamista valmisteleva työryhmän asettamispäätös, STM https://stm.fi/-/tyoryhma-laatii-ehdotuksen-uudeksi-laiksi-ihmiskaupan-uhrien-auttamiseksi
 Ihmiskaupan vastainen työ, Oikeusministeriö https://oikeusministerio.fi/ihmiskaupan-vastainen-tyo-hanketiedot-ja-asiakirjat
 Guidance. Addressing Emerging Human Trafficking Trends and Consequences of the COVID-19 Pandemic. UN Women, OSCE & ODIHR (2020) https://www.unwomen.org/en/digital-library/publications/2020/07/guidance-addressing-emerging-human-trafficking-trends-and-consequences-of-the-covid-19-pandemic