In particular, the OSCE commitments require that victims of trafficking and their families are provided with assistance that considers their safety upon return.25 The UN Trafficking Protocol obliges the country of origin to receive its returning nationals without undue or unreasonable delay.26 In addition, their return should be conducted with due regard for the safety of the trafficked person and should, preferably, be voluntary.27 The Council of Europe Trafficking Convention also requires that States Parties take into consideration the victim’s safety and protection needs,28 and that return be undertaken “with due regard for the rights, safety and dignity” of the victim.29 The European Union imposes similar requirements on its member states, which are obliged to conduct returns with due regard to the rights, safety and dignity of the trafficked victims.30 Both returning and receiving states have a clear legal obligation to consider the safety of the trafficked person at all stages of their return. The 2012 EU Strategy on trafficking aims at developing guidelines on safe return and, where return is deemed to be in the child’s best interests, ensuring the safe and sustainable return of trafficked children.31 In the same vein, the European Commission Group of Experts on Trafficking in Human Beings (hereafter: EU Group of Experts) recommends that all member states establish appropriate return procedures “with due regard to the privacy, safety, dignity and health of the trafficked person, in close partnership with NGOs, IOs and, where applicable, embassies and consulates”.32 Moreover, the obligation of safe return was reiterated during an EU Ministerial Conference in 2009, which declared that “return shall be carried out with due regard for the rights, safety and dignity of the victim.”33 Within the CIS, the question of how to ensure the safe return of victims of trafficking has been highlighted as one of the areas of legislation that need to be improved and harmonized.34 25  OSCE Permanent Council, Decision No. 557/Rev.1, “OSCE Action Plan to Combat Trafficking in Human Beings”, Vienna, 7 July 2005, part V, para. 7.1 (hereafter: OSCE Action Plan); and OSCE Permanent Council, Decision No. 1107/Corr.1, “Addendum to the OSCE Action Plan to Combat Trafficking in Human Beings: One Decade Later”, Vienna, 6 December 2013, part IV, para. 2.5 (hereafter: 2013 Addendum to the OSCE Action Plan). 26  UN Trafficking Protocol, art. 8(3). 27  UN Global Plan of Action, para. 34. 28  Council of Europe Trafficking Convention, art. 12(2). 29  Council of Europe Trafficking Convention, art. 16(2). 30  EU Declaration on Trafficking in Human Beings, para. 15. 31  The EU Strategy towards the Eradication of Trafficking in Human Beings 2012-2016, COM(2012)286 final, 2012 (hereafter: EU Strategy), para. 2.1(1), 2.1(3). 32  Report of the EU Group of Experts, rec. 109. According to the EU Group of Experts, these procedures should be set out in specific protocols for the return of trafficked persons and should apply to all involved agencies. 33  EU Declaration on Trafficking in Human Beings, para. 15. 34  “The CIS Program on Co-operation of CIS Members in combating trafficking in Human Beings 2014-2018”, 25 October 2013, para. 1.1 v. Part 2: Explanatory Report to the Principles 37