it comes to upholding the right to return in relation to child victims. In OSCE Ministerial Council Decisions, participating States have repeatedly reaffirmed the need to ensure the safe return of children.12 Although most OSCE participating States have adopted, either formally or informally, the standard of “safe and, preferably, voluntary return” of trafficked victims, the meaning of “voluntary” remains ambiguous.13 There is apparent consensus that, in order for return to be truly voluntary, returnees must be fully informed of all their available options, including returning to their country of origin, remaining in the destination country or resettling in a third country.14 In the case of a child victim, both the child and the child’s guardians should be fully informed and consulted.15 The OSCE participating States have explicitly committed to assisting victims “in – preferably – voluntary return to the country of origin”.16 The preference of voluntary return has also been recognized by the United Nations,17 and reaffirmed in the Council of Europe’s legal instruments.18 The concept is, moreover, recognized by the European Union, which affirmed in a 2009 Declaration that returns shall, as far as possible, be voluntary.19 As such, the preamble to the Directive of the European Parliament and of the Council on common standards and procedures in Member States for returning illegally staying third-coun12  See OSCE Ministerial Council, Decision No. 2/03, “Combating Trafficking in Human Beings”, Maastricht, 2 December 2003, para. 8, <http://www.osce.org/mc/40379?download=true>; and OSCE Ministerial Council, Decision No. 14/06, “Enhancing efforts to combat trafficking in human beings, including for labour exploitation, through a comprehensive and proactive approach”, Brussels, 5 December 2006, para. 4, <http://www.osce.org/ mc/23048?download=true>. 13  See “Programmes and Strategies in the EU Member States fostering Assisted Return to and Reintegration in Third Countries”, the European Migration Network, March 2011, p. 15, <http://rem.sef.pt/PagesPT/DocsPT/EstudosSinteseEuropeus/programmes_strategies_assisted_return_reintegration.pdf>. 14  Both the UNHCR and the EU have highlighted the importance of informed consent as an essential aspect of a genuinely voluntary decision regarding return. See UNHCR, “Handbook on Voluntary Repatriation: International Protection” (Geneva: UNHCR, 1996), part 4.2; and the Council of the European Union, 2683rd Council Meeting, Justice and Home Affairs, 12645/05 (Presse 247), 12 October 2005, p. 23. The Council of the European Union has recommended that information on the possibility of voluntary return should be made readily available and as early as possible. This can include the provision of pre-return information and counselling, including with respect to the conditions and circumstances in the country of return. See the Council of the European Union, 2683rd Council Meeting, Justice and Home Affairs, 12645/05 (Presse 247), 12 October 2005, p. 24. 15  “Report of the Experts Group on Trafficking in Human Beings”, EU Group of Experts, European Commission, 22 December 2004 (hereafter: Report of the EU Group of Experts), rec. 113. 16  OSCE Ministerial Council, Decision No. 2/03, part V, para. 7.1, <http://www.osce.org/mc/40379?download=true>. 17  United Nations Global Plan of Action against Trafficking in Persons, UNGA Res A/64/L.64 (adopted on 30 July 2010) (hereafter: UN Global Plan of Action), para. 34. 18  Convention on Action against Trafficking in Human Beings (adopted on 16 May 2005), the Council of Europe, CETS No. 197 (hereafter: Council of Europe Trafficking Convention), art. 16(2). 19  “2009 October Declaration on Trafficking in Human Beings: Towards Global EU Action against Trafficking in Human Beings” (hereafter: EU Declaration on Trafficking in Human Beings), EU Ministerial Conference, 19-20 October 2009, para. 15. Part 2: Explanatory Report to the Principles 35