Neither the UN Trafficking Protocol nor the OSCE Action Plan specifically mentions the need to carry out a risk assessment.40 The OSCE Action Plan does, however, stress that return be carried out with “due regard” for the victim’s safety.41 A similar approach is included in the Council of Europe Trafficking Convention, although the Convention does require that a security and risk assessment be carried out in cases of trafficked child victims.42 Nevertheless, states are still obliged to assess the risks of return in accordance with the principle of non-refoulement.43 This principle is central to the realization of the right to seek and enjoy asylum, as outlined in the Universal Declaration of Human Rights,44 and is a fundamental principle of the 1951 UN Refugee Convention,45 which prohibits states from returning persons to a territory where this threatens their life or freedom and/or exposes them to persecution.46 The UNHCR has issued guidelines on the application of the UN Refugee Convention in cases of victims of trafficking or those at risk of being trafficked.47 While the guidelines do not give technical step-by-step guidance on risk assessment, they do explain in detail the concepts that need to be evaluated when considering whether a victim or potential victim of trafficking falls within the definition of a refugee. These concepts include a well-founded fear of persecution, the agents and places of persecution and the causal link. The causal link is related to the fact that, in order to qualify for refugee status, an individual’s well-founded fear of persecution must relate to one or more of the grounds foreseen in the UN Refugee Convention, including persecution on the basis of race, religion, nationality, membership of a particular social group or political opinion. Pursuant to the UNHCR Trafficking Guidelines, the forcible or deceptive 40  However, risk assessment is a standard promoted by the UNODC Model Law. See UNODC Model Law, art. 33, p. 63-65. 41  OSCE Action Plan, part V, para. 7.1. The 2013 Addendum to the OSCE Action Plan uses a formulation suggesting that “safe” return is a presumed standard (see 2013 Addendum to the OSCE Action Plan, part IV, para. 2.5). 42  Council of Europe Trafficking Convention, art. 16.7. 43  According to the UNHCR, non-refoulement is “a core principle of international refugee law that prohibits States from returning refugees in any manner whatsoever to countries or territories in which their lives or freedom may be threatened.” (UN High Commissioner for Refugees (UNHCR), UNHCR Master Glossary of Terms, June 2006, rev.1, p. 15). 44  UDHR, Art. 14. 45  United Nations Convention Relating to the Status of Refugees (adopted 28 July 1951), 189 UNTS 137 (hereafter: UN Refugee Convention), art. 33. 46  Also the EU Trafficking Directive refers to the non-refoulement principle (EU Trafficking Directive, recital 10). 47  UN High Commissioner for Refugees, Guidelines on International Protection: The application of Article 1A(2) of the 1951 Convention and/or 1967 Protocol relating to the Status of Refugees to victims of trafficking and persons at risk of being trafficked, 7 April 2006, HCR/GIP/06/07 (hereafter: UNHCR Trafficking Guidelines). Part 2: Explanatory Report to the Principles 39