International and regional policy documents on trafficking provide some limited additional guidance.249 However, more work needs to be done to flesh out the factors that will help to determine whether a State has met the required standard of due diligence in relation to identifying and responding to public-sector involvement or complicity in trafficking. 6.4. THE INVOLVEMENT OF MILITARY, PEACEKEEPING, HUMANITARIAN AND OTHER INTERNATIONAL PERSONNEL IN TRAFFICKING AND RELATED FORMS OF EXPLOITATION The involvement of military, peacekeeping, humanitarian and other international personnel in trafficking and related exploitation has been extensively documented. Studies into this aspect of the trafficking phenomenon confirm that such involvement can be both direct and indirect. Patronage of an establishment that uses trafficked labour is an example of indirect involvement. The sexual exploitation of women and children by international personnel is an example of more direct involvement. The involvement of international personnel in trafficking is a complex issue and one that is not yet fully understood. Certainly, a large, predominantly male international presence can actually fuel the demand for goods and services produced through trafficking and exploitation, in particular prostitution. International personnel are generally deployed to situations of conflict or immediate post-conflict in which populations are vulnerable and basic institutions, including law enforcement, are fragile or non-existent. See, for example, the Brussels Declaration, para. 19, which recommends “[e]ffective legislative and regulatory measures to combat corruption, the establishment of standards of good governance … and the development of mechanisms to curb corrupt practices”. Conflict-related demographic changes can mean that there are more civilian women than men. The absence of male family members; destruction of property or problems in accessing property; and emphasis on the rehabilitation of former combatants can all contribute to increasing the vulnerability of women in conflict and post-conflict situations. In addition, the legal framework governing engagement may be unclear and lines of responsibility and control blurred. The growing privatization of conflict, characterized by the increased involvement of private corporations as contractors and sub-contractors, has exacerbated problems of responsibility and control. These various factors can combine to create a climate of impunity – a legal and procedural vacuum in which international personnel involved in criminal exploitation and trafficking are not investigated, apprehended or prosecuted. The Trafficking Principles and Guidelines focus particular attention on closing this responsibility gap: on identifying the obligations and responsibilities of States and intergovernmental organizations and ensuring that international military, peacekeeping and humanitarian operations do not become safe havens for traffickers and their accomplices. Guideline 10 sets out the steps that those responsible for international personnel, most particularly States and intergovernmental organizations, should take to prevent and deal with direct and indirect involvement in trafficking and related exploitation. The following is a summary of the key points of Guideline 10 which have, in most cases, been affirmed and even strengthened by recent reports, recommendations, commitments and initiatives by the major intergovernmental organizations including the General Assembly;250 the 249 See, for example, “A comprehensive strategy to eliminate future sexual exploitation and abuse in United 250 (Continued on next page) COMMENTARY 123