2019 Findings on the Worst Forms of Child Labor: Rwanda

 

In 2019, Rwanda made a moderate advancement in efforts to combat the worst forms of child labor. The government published its first ever comprehensive study examining human trafficking trends in the country and completed the drafting of a light work framework for children working under the minimum age. The government also removed 316 children from hazardous work situations, and punished 74 employers with fines totaling about $3,000. Children in Rwanda engage in the worst forms of child labor, including in forced domestic work, sometimes as a result of human trafficking. Children also perform dangerous tasks in agriculture. The number of labor inspectors does not meet the ILO's technical advice for the size of the workforce. In addition, Rwandan law potentially allows authorities to place children engaged in labor in transit centers, where children are often subject to physical abuse. Finally, social programs did not address all relevant sectors where child labor was present.

I. Prevalence and Sectoral Distribution of Child Labor

Children in Rwanda engage in the worst forms of child labor, including in forced domestic work, sometimes as a result of human trafficking. Children also perform dangerous tasks in agriculture. (1,2,3) Table 1 provides key indicators on children's work and education in Rwanda.

Table 1. Statistics on Children’s Work and Education

Children

Age

Percent

Working (% and population)

6 to 14

5.4 (156,522)

Working children by sector

6 to 14

 

Agriculture

 

78.9

Industry

 

3.2

Services

 

17.9

Attending School (%)

6 to 14

89.4

Combining Work and School (%)

7 to 14

4.9

Primary Completion Rate (%)

 

86.5

Source for primary completion: Data from 2018, published by UNESCO Institute for Statistics, 2020. (4)
Source for all other data: International Labor Organization's analysis of statistics from Integrated Household Living Conditions Survey (EICV-5), 2016–2017. (3)

Based on a review of available information, Table 2 provides an overview of children's work by sector and activity.

Table 2. Overview of Children's Work by Sector and Activity

Sector/Industry

Activity

Agriculture

Forestry activities (5)

 

Production of tea, including applying fertilizers,† carrying heavy loads,† planting, plucking tea leaves, and weeding (7)

 

Fishing† (5)

Industry

Construction,† including laying bricks (6,2,8)

 

Mining† tantalum ore (coltan) and quarrying (6,2,9)

Services

Domestic work† (6,1,8,10,11)

 

Repair and cleaning of motorcycles and motor vehicles (6,12)

 

Street work, including collecting scrap metal,† carrying heavy loads as porters,† and small-scale vending (12-14)

Categorical Worst Forms of Child Labor‡

Commercial sexual exploitation, sometimes as a result of human trafficking (11,12,15)

 

Forced labor in agricultural and domestic work, each sometimes as a result of human trafficking (8,10,15)

† Determined by national law or regulation as hazardous and, as such, relevant to Article 3(d) of ILO C. 182.
‡ Child labor understood as the worst forms of child labor per se under Article 3(a)–(c) of ILO C. 182.

Data collected in a 2016-2017 national household survey showed that approximately 3.6 percent of all children in Rwanda are engaged in child labor, primarily in the agriculture and service sectors. (5,16) In 2019, the government collaborated with the IOM and the NGO Never Again Rwanda, with funding from USAID, to produce Rwanda's first ever comprehensive study on human trafficking in the country. (17) The report showed that although Rwanda is not a major destination for child trafficking, it is a source and transit country for child victims, primarily those heading to Saudi Arabia, Uganda, Kenya, and elsewhere in East Africa and the Middle East. (17,18) Within Rwanda, young girls are vulnerable to being forced into domestic servitude and commercial sexual exploitation, and boys are exploited in forced labor in the agricultural and industrial sectors, including on plantations and in mines. (11,15,17,18)

Although the Ministry of Education established a policy that provides free basic education for 12 years, of which the first 9 are compulsory, in practice, the costs of uniforms, school supplies, and unofficial school fees may preclude some families from sending their children to school. (16-21) On January 9, 2019, the Ministry of Education issued a statement expressing concern that schools were levying excessive school fees on families and prohibited schools from increasing fees during the first term of the 2019/2020 school year. The Ministry issued the same warning in January 2020. (2,16) Furthermore, children with disabilities face particular difficulties accessing education due to stigma and because schools lack the capacity to accommodate special needs. (16,22)

II. Legal Framework for Child Labor

Rwanda has ratified all key international conventions concerning child labor (Table 3).

Table 3. Ratification of International Conventions on Child Labor

Convention

Ratification

ILO C. 138, Minimum Age

ILO C. 182, Worst Forms of Child Labor

UN CRC

UN CRC Optional Protocol on Armed Conflict

UN CRC Optional Protocol on the Sale of Children, Child Prostitution and Child Pornography

Palermo Protocol on Trafficking in Persons

The government's laws and regulations are in line with relevant international standards (Table 4).

Table 4. Laws and Regulations on Child Labor

Standard

Meets International Standards

Age

Legislation

Minimum Age for Work

Yes

16

Article 5 of the Labor Law; Article 9 of the Ministerial Instruction Relating to Prevention and Fight Against Child Labor (23,24)

Minimum Age for Hazardous Work

Yes

18

Article 6 of the Labor Law (23)

Identification of Hazardous Occupations or Activities Prohibited for Children

Yes

 

Article 6 of the Labor Law; Articles 4–6 of the Ministerial Order Determining the List of Worst Forms of Child Labor; Kigali City Guidelines 2012-02; Articles 7–9 of the Ministerial Instruction Relating to the Prevention and Fight against Child Labor (23-26)

Prohibition of Forced Labor

Yes

 

Articles 3.25 and 7 of the Labor Law; Article 178 of the Penal Code; Article 51 of the Law Relating to the Rights and Protection of the Child; Article 9 of the Ministerial Instruction Relating to Prevention and Fight against Child Labor (23,24,27,28)

Prohibition of Child Trafficking

Yes

 

Articles 3.4, 3.6, 3.7, and 18–20 of the Law on Prevention, Suppression, and Punishment of Trafficking in Persons; Article 28 of the Law on Prevention and Punishment of Gender-Based Violence; Articles 225, 251, and 259–262 of the Penal Code; Article 51 of the Law Relating to the Rights and Protection of the Child; Article 31 of the Law Relating to the Protection of the Child; Article 9 of the Ministerial Instruction Relating to Prevention and Fight against Child Labor (24,27-31)

Prohibition of Commercial Sexual Exploitation of Children

Yes

 

Articles 3.2 and 24 of the Law on Prevention, Suppression, and Punishment of Trafficking in Persons; Articles 190, 211, and 260 of the Penal Code; Article 51 of the Law Relating to the Rights and Protection of the Child; Articles 34–35 of the Law Relating to the Protection of the Child; Article 9 of the Ministerial Instruction Relating to Prevention and Fight against Child Labor (24,27,28,30,31)

Prohibition of Using Children in Illicit Activities

Yes

 

Article 220 of the Penal Code; Article 51 of the Law Relating to the Rights and Protection of the Child; Article 9 of the Ministerial Instruction Relating to Prevention and Fight against Child Labor; Article 263 of the Law Determining Offenses and Penalties in General (24,27,28,32)

Minimum Age for Voluntary State Military Recruitment

Yes

18

Article 5 of Presidential Order 72/01 Establishing Army General Statutes; Article 7 of Presidential Order 32/01 Establishing Rwanda Defense Forces Special Statute; Article 50 of the Law Relating to the Rights and Protection of the Child (33,34)

Prohibition of Compulsory Recruitment of Children by (State) Military

N/A*

 

Article 5 of Presidential Order 72/01 Establishing Army General Statutes; Articles 99(8) and 100(2) of the Law Determining Offenses and Penalties in General (32,33)

Prohibition of Military Recruitment by Non-state Armed Groups

Yes

 

Article 221 of the Penal Code (28)

Compulsory Education Age

Yes

16

Article 47 of the Law Relating to the Rights and Protection of the Child; Articles 34, 36, and 38 of the Law Governing the Organization and Functioning of Nursery, Primary and Secondary Education (27,35)

Free Public Education

No

 

Article 47 of the Law Relating to the Rights and Protection of the Child; Articles 32 and 34 of Law Governing the Organization and Functioning of Nursery, Primary and Secondary Education (27,35)

* No conscription (27,33,34)

Rwanda passed several child labor-related laws in 2018 that entered into force in 2019, but some still required ministerial orders or the implementation of provisions. For example, the Ministry of Public Service and Labor (MIFOTRA) indicated that in 2019, it had drafted a light work framework for children ages 13 to 15 engaged in apprenticeships, but the draft was not yet publicly available. (16)

Although Rwanda has adopted policies to implement fee-free and compulsory education through age 16, national education laws make education compulsory only up to age 12 and provide for free schooling for only 6 years, while basic education is a total of 9 years. (20,27,35) The failure to provide for complete free basic education may increase the risk of children's involvement in the worst forms of child labor. Furthermore, the age up to which education is compulsory makes children between 12 and 16 vulnerable to child labor as they are not legally required to attend school but are not legally permitted to work.

III. Enforcement of Laws on Child Labor

The government has established institutional mechanisms for the enforcement of laws and regulations on child labor (Table 5). However, gaps exist within the operations of MIFOTRA that may hinder adequate enforcement of their child labor laws.

Table 5. Agencies Responsible for Child Labor Law Enforcement

Organization/Agency

Role

Ministry of Public Service and Labor (MIFOTRA)

Enforces labor laws, including laws on child labor. (21) In partnership with the Ministry of Education, reintegrates children withdrawn from child labor with their families and enrolls them in school. Mobilizes other ministries and agencies providing social services, including the Ministry of Gender and Family Promotion, the National Commission for Children, the Ministry of Justice, and the Ministry of Local Government, to take an active role in child labor law enforcement. (2)

Rwandan National Police (RNP)

Enforces criminal laws related to the worst forms of child labor and operates a free hotline to report incidents of gender-based violence or child abuse, including child labor. Through its Child Protection Unit and Anti-Trafficking Unit, enforces laws related to the worst forms of child labor. (2,21,36) It is unknown how many calls to the hotline, if any, were related to child labor.

Rwanda Investigation Bureau

Conducts investigations into criminal matters, including child labor. In the case of the Directorate for Anti-Gender-Based Violence, assists victims of the worst forms of child labor through anti-gender-based violence officers at each of the country's 78 police stations. (2)

National Public Prosecution Authority (NPPA)

Prosecutes violations of labor laws, including laws on child labor. (2) Through its anti-Gender Based Violence unit, 12 prosecutors work with an additional 60 prosecutors trained in handling relevant cases at the district level. (37)

Directorate General of Immigration and Emigration

Receives referrals for human trafficking cases and employs an anti-trafficking specialist. Trains border and immigration officials to identify potential human trafficking victims and verify that children transported across the border are traveling with the permission of their parents or guardians. (2)

Labor Law Enforcement

In 2019, labor law enforcement agencies in Rwanda took actions to combat child labor (Table 6). However, gaps exist within the operations of MIFOTRA that may hinder adequate labor law enforcement, including human resource allocation.

Table 6. Labor Law Enforcement Efforts Related to Child Labor

Overview of Labor Law Enforcement

2018

2019

Labor Inspectorate Funding

$155,287 (2)

$155,000 (16)

Number of Labor Inspectors

35 (2)

33 (38)

Inspectorate Authorized to Assess Penalties

Yes (2)

Yes (23,38)

Initial Training for New Labor Inspectors

Yes (2)

Yes(16)

Training on New Laws Related to Child Labor

Yes (2)

Yes (16)

Refresher Courses Provided

Yes (2)

Yes (16)

Number of Labor Inspections Conducted

912 (2)

2,150 (38)

Number Conducted at Worksite

912 (2)

2,150 (22)

Number of Child Labor Violations Found

51 (2)

393 (38)

Number of Child Labor Violations for Which Penalties Were Imposed

Unknown (2)

Unknown

Number of Child Labor Penalties Imposed that Were Collected

Unknown (2)

Unknown

Routine Inspections Conducted

Yes (2)

Yes (16)

Routine Inspections Targeted

Yes (2)

Yes (16)

Unannounced Inspections Permitted

Yes (2)

Yes (16,39)

Unannounced Inspections Conducted

Yes (2)

Yes (22)

Complaint Mechanism Exists

Yes (2)

Yes (16)

Reciprocal Referral Mechanism Exists Between Labor Authorities and Social Services

Yes (2)

Yes (16)

According to MIFOTRA officials, labor inspectors had adequate funding to carry out inspections. MIFOTRA officials indicated that the number of labor inspections increased significantly from 2018 to 2019 because inspectors were required to conduct three child labor inspections per week. (16) In addition, other ministries and agencies received funding for "child rights protection and promotion." For example, the Ministry of Gender and Family Promotion (MIGEPROF) had a budget of $1.4 million for child rights protection for fiscal year 2018/2019. (16)

The number of labor inspectors is likely insufficient for the size of Rwanda's workforce, which includes more than 6 million workers. According to the ILO's technical advice of a ratio approaching 1 inspector for every 40,000 workers in less developing economies, Rwanda would employ about 156 labor inspectors. (40,41) Despite MIFOTRA's indication that the inspectorate was sufficiently funded, research indicates that low resources, lack of personnel, high workloads, and a lack of training may limit labor inspectors' ability to enforce child labor laws and perform onsite inspections. (4) Reports indicate that officials at the local level had difficulty identifying characteristics of child trafficking and child labor. (37)

Criminal Law Enforcement

In 2019, criminal law enforcement agencies in Rwanda took actions to combat child labor (Table 7). However, gaps exist within the operations of the Rwandan National Police (RNP) that may hinder adequate criminal law enforcement, including investigation planning.

Table 7. Criminal Law Enforcement Efforts Related to Child Labor

Overview of Criminal Law Enforcement

2018

2019

Initial Training for New Criminal Investigators

Yes (37)

Yes (16)

Training on New Laws Related to the Worst Forms of Child Labor

Yes (37)

Yes (16)

Refresher Courses Provided

Yes (37)

Yes (16)

Number of Investigations

Unknown (37)

Unknown

Number of Violations Found

7(2)

Unknown

Number of Prosecutions Initiated

2 (2)

Unknown

Number of Convictions

1 (2)

Unknown

Imposed Penalties for Violations Related to The Worst Forms of Child Labor

Yes (42)

Yes (16)

Reciprocal Referral Mechanism Exists Between Criminal Authorities and Social Services

Yes (2)

Yes (16)

The government has acknowledged detaining thousands of street children per a 2017 law establishing a National Rehabilitation Service to address "deviant behavior" and the accompanying 2018 Ministerial Order, which defines deviant behavior to include prostitution, begging, and informal street vending. (43,44) Under the purview of these laws, authorities may apprehend children for exhibiting deviant behavior and place children in a transit center before transferring them to a rehabilitation center or reintegrating them into the community. Research indicates that children placed in the primary transit center located in Kigali, also known as Gikondo, faced overcrowding, unsanitary conditions, insufficient food or water, and physical abuse. (21,43-45) Research indicates that rehabilitation services were limited and children were detained for prolonged periods at transit centers before being referred to a rehabilitation facility. (46,47) Since some of types of child labor are included in the 2018 Ministerial Order definition of "deviant behavior," children engaged in commercial sexual exploitation, forced begging, and street vending may be penalized for their engagement in child labor. (44)

The RNP did not provide comprehensive data regarding criminal law enforcement efforts related to child labor, but it disclosed that it had arrested at least 10 individuals in 3 different cases involving violations related to the worst forms of child labor in 2019. The GOR reported some individuals were arrested for alleged crimes related to forced labor, but specific information regarding how many arrests, prosecutions, or convictions were achieved during the reporting period for crimes related to the worst forms of child labor was unavailable. Meanwhile, MIGEPROF's National Commission for Children reported that between July 2018 and July 2019, 316 children were removed from hazardous work situations, and 74 employers were punished with fines of about $3,000. (16)

According to MIFOTRA, the National Public Prosecution Authority, and the RNP, investigators received training on the worst forms of child labor, including Rwandan law and international convention commitments; trafficking in persons; and social services available to victims. (16) Law enforcement agencies also engaged in a series of campaigns to educate the public and implement existing policies on child labor. For instance, on October 9, 2019, the RNP in Karongi District conducted a campaign, in coordination with the Gender Monitoring Office, to raise awareness of the fight against child abuse and child labor. (48)

IV. Coordination of Government Efforts on Child Labor

The government has established mechanisms to coordinate its efforts to address child labor (Table 8). However, gaps exist that hinder the effective coordination of efforts to address child labor, including efforts to address all forms of child labor.

Table 8. Key Mechanisms to Coordinate Government Efforts on Child Labor

Coordinating Body

Role & Description

Inter-Ministerial Steering Committee on Child Labor

Coordinates government efforts related to the worst forms of child labor, reviews child labor laws, advocates the inclusion of child labor policies in national development plans, oversees the implementation of child labor interventions, and conducts field visits to assess the prevalence of child labor and raise awareness of child labor. (2) MIFOTRA coordinates and provides monitoring and evaluation, including the publication of annual updates on program and policy implementation related to child labor. (42) Research was unable to identify activities taken during the reporting period.

Interagency Working Group on Human Trafficking

Enables national-level discussion and coordination of efforts to address human trafficking, including child labor. Includes representatives of the Ministry of Gender and Family Promotion (MIGEPROF), the Ministry of Justice, RNP, and NPPA. (2) Held coordinating meetings once every 2 months during the reporting period. (18)

MIGEPROF's National Commission for Children (NCC)

Monitors, promotes, and advocates children's rights; develops action plans to protect children from abuse and exploitation. Overseen by MIGEPROF and supported by a board of directors and an advisory council of 14 institutions. (2) In 2019, conducted numerous trainings and public awareness campaigns to inform local leaders, service providers, law enforcement officials, and the general public on child protection, the dangers of child labor, and restorative justice for children. (16)

Child Labor Steering Committees

Monitors incidents of child labor nationwide and implements policies developed by the Inter-Ministerial Steering Committee on Child Labor in 30 districts by coordinating with district-level officials in enforcing labor laws and providing social services to child labor victims. (2) In the case of Gender-Based Violence Committees, operates at the district level to raise awareness about gender-based violence and coordinate social services to assist gender-based violence victims. In the case of Child Protection Committees, identifies and reports cases of child rights violations at the district, sector, and cell levels. (2,11) During the reporting period, the government continued to expand the presence of committees from the national and district levels to the sector, cell, and village levels. (16) MIFOTRA reported that it collaborated with committees to conduct 187 awareness campaigns between July 2019 and December 2019. (18,38)

Kigali City Council Task Force

Coordinates activities to combat child labor in the districts of Gasabo, Kicukiro, and Nyarugenge. (2) Research was unable to identify activities taken during the reporting period.

Reports indicate that poor coordination and resource constraints hindered efforts to combat human trafficking and that efforts were focused on transnational rather than domestic human trafficking. (2,36,37)

V. Government Policies on Child Labor

The government has established policies related to child labor (Table 9). However, gaps exist that hinder efforts to address child labor, including mainstreaming child labor issues into relevant policies.

Table 9. Key Policies Related to Child Labor

Policy

Description

Strategic Plan for Integrated Child Rights Policy 2019–2024†

Revised in 2018 and implemented in 2019, with a focus on identity and nationality; family and alternative care; health, survival and standard of living; education; protection; justice; and participation. Aims to improve coordination and implementation issues identified in the previous plan that expired in 2016 and includes strategies to address child labor. (49)

7 Years Government Programme: National Strategy for Transformation (2017–2024)

Aims to smooth the transition between the Vision 2020 and Vision 2050 national development plans and improve standards of living for Rwandans, including access to quality education. (53) Research was unable to identify activities undertaken during the reporting relevant to the goals of improving access to quality education.

† Policy was approved during the reporting period.

‡ The government had other policies that may have addressed child labor issues or had an impact on child labor. (20,54,55,56)

The government has not included child labor elimination and prevention strategies in the National Technical and Vocational Education and Training Policy. (57)

VI. Social Programs to Address Child Labor

In 2019, the government funded and participated in programs that include the goal of eliminating or preventing child labor (Table 10). However, gaps exist in these social programs, including the adequacy of efforts to address the problem in all sectors.

Table 10. Key Social Programs to Address Child Labor

Program

Description

Programs to Combat Child Labor and Raise Awareness†

Include MIGEPROF's campaign to teach parents and community leaders to recognize risk factors for human trafficking and to identify victims; and the Friends of the Family Program (Incuti Z'Umuryango), which trains volunteers to prevent and respond to child protection issues and establishes monitoring committees at various levels to combat child labor. (2) In 2019, the government partnered with UNICEF to train more than 10,700 Friends of the Family (Inshuti z'Umuryango) volunteers in 11 districts on child rights, basic psychosocial support, conflict, communication, and referral pathways. (16)

Victim Assistance Programs†

Musanze Child Rehabilitation Center in Northern Province assists children separated from armed groups in the Democratic Republic of the Congo. (21) Gitagata Center provides education, vocational training, and psychosocial support, and aims to reunite former street children with their families. "One-Stop" centers located in 44 hospitals and district capitals assist victims of gender-based violence and human trafficking. (2,36) In 2019, One-Stop centers provided medical care, counseling, legal aid, short‐term shelter, and access to police services. The Musanze Center meanwhile assisted 11 children separated from armed groups. (16)

It Takes Every Rwandan to End Child Exploitation

5-year advocacy campaign against child labor and sexual abuse of children supported by MIGEPROF, the National Commission for Children, and World Vision Rwanda. (2,50) In 2019, the campaign held awareness-raising events at primary and high schools in various parts of the country. (51,52) In 2019 the program provided training to grassroots organizations and that the program had reached 42,803 children thus far. (50)

Strengthening Social Protection Project (2017–2021)

$80 million World Bank-funded project in support of the Vision 2020 Umurenge Program which aims to deliver cash transfers and improve social safety nets. (58) During the reporting period, Rwanda succeeded in ensuring that 100 percent of eligible households were covered by the cash transfer program, surpassing the 2021 target of 70 percent of households. The government also increased the number of project participants from 405,421 in 2018 to 1,520,623 in 2019. (59)

The Children's Forum

Provides a platform at the village, cell, sector, and district levels for children to express their opinions and be heard on matters concerning their lives, family, and country, which are incorporated into government plans of action and considered during the development of policies and programs. Managed by the NCC and Ministry of Local Government (MINALOC), comprises children between ages 6 and 15.(16) Held a nationwide training from April 16 to 18, 2019, of 104,622 children committee members on the committee's responsibilities and child rights. (16)

† Program is funded by the Government of Rwanda.
‡ The government had other social programs that may have included the goal of eliminating or preventing child labor. (60,61)

Although Rwanda has programs that target child labor, the scope of these programs is insufficient to address the extent of the child labor problem in the agriculture sector and domestic work. (36,37) The IOM study on human trafficking also revealed that despite efforts to protect and assist victims of human trafficking, the country lacked a sufficient number of shelters, and assistance was typically short-term. Furthermore, One-Stop centers tended to lack services for male victims. (17,18) In addition, service providers lacked sufficient training to properly identify and categorize victims of human trafficking. (17)

VII. Suggested Government Actions to Eliminate Child Labor

Based on the reporting above, suggested actions are identified that would advance the elimination of child labor in Rwanda (Table 11).

Table 11. Suggested Government Actions to Eliminate Child Labor

Area

Suggested Action

Year(s) Suggested

Legal Framework

Establish by law compulsory education up to the age of 15 and free basic public education.

2019

Enforcement

Disaggregate the number of complaints received by the Rwandan National Police's hotline and the National Public Prosecution Authority's investigations that relate to child labor.

2013 – 2019

 

Publish information on the number of penalties imposed and collected for child labor violations, the number of criminal investigations conducted, violations found, prosecutions initiated, and convictions obtained.

2015 – 2019

 

Increase the number of inspectors to meet the ILO's technical advice.

2009 – 2019

 

Ensure that labor inspectors and criminal investigators receive sufficient training to identify cases of child labor, including its worst forms.

2017 – 2019

 

Cease the Rwandan National Police practice of detaining and beating children who work on the street and ensure that children in detention are not subjected to beatings or unhealthy detention conditions.

2018 – 2019

Coordination

Ensure that all coordinating mechanisms are active and carrying out their intended mandates.

2019

 

Ensure that coordinating bodies receive adequate resources and are able to combat both domestic and transnational human trafficking.

2019

Government Policies

Ensure that actions are taken to implement the National Transformation Strategy.

2019

 

Integrate child labor elimination and prevention strategies into the National Transformation Strategy, the National Social Protection Strategy, and the National Technical and Vocational Education and Training Policy.

2011 – 2019

Social Programs

Remove barriers to education, such as costs for uniforms, school supplies, and unofficial school fees, and ensure access for children with disabilities.

2010 – 2019

 

Expand existing social programs to address all relevant sectors of child labor, including agriculture and domestic work.

2017 – 2019

 

Expand services for human trafficking victims, including the number of shelters, programs for long-term care, and services for male victims.

2019

 

Ensure that service providers are properly trained to identify victims of human trafficking.

2019

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