PART 2.2 abuses occur should be regulated by the State, or whether market relations should apply in these areas.”171 It is also important to acknowledge a distinction between the causes or factors that shape demand and the demands themselves. This distinction becomes highly relevant when considering the roles and responsibilities of different actors including countries of origin, countries of destination and individuals. As noted by the authors of a major study on this issue, “to explore ‘the demand side of trafficking’ is not simply to enquire about the individuals who exploit or consume the labour/services of trafficked persons, but also to question the way in which States – through a combination of action and inaction – construct conditions under which it is possible or profitable to consume or exploit such labour/ services.”172 States can of course play a more direct part in the demand cycle. Many countries of destination derive great benefit from cheap foreign labour which, deliberately unprotected by law, can be moved on if and when circumstances require. Countries of origin may rely heavily on the remittances of overseas workers and be reluctant to interfere with a system that brings economic benefits – even if it is clear that some of their citizens are being severely exploited. Finally, demand cannot be considered separately from supply – not least because supply may well generate its own demand. For example, the availability of a cheap and exploitable domestic labour force (made possible through the factors further considered below, and more extensively under Principle 5 and related guidelines) can itself help generate demand for exploitative domestic labour at a level that might not otherwise have existed. Similarly, in relation to prostitution some argue that demand 171 Anderson and O’Connell-Davidson, op. cit., p. 54. 172 Anderson and O’Connell-Davidson, op. cit., p. 5. 98 actually fuels the market for persons trafficked into prostitution. In keeping with the purpose of this Commentary, the emphasis of the following discussion is on human rights and on identifying ways in which rights violations linked to the demand for trafficking and related exploitation can be prevented and addressed. 4.2. AN OBLIGATION TO ADDRESS DEMAND? Principle 4 identifies demand as a root cause of trafficking and requires States to address demand in their response to trafficking. It is reinforced by Guideline 7.1, which requires States and others to “analys[e] the factors that generate demand for exploitative commercial sexual services and exploitative labour and tak[e] strong legislative, policy and other measures to address these issues.” The issue of demand is taken up by the major trafficking treaties. Article 9 (5) of the Trafficking Protocol requires States parties to “adopt or strengthen legislative or other measures, such as educational, social or cultural measures, including through bilateral and multilateral cooperation, to discourage the demand that fosters all forms of exploitation of persons, especially women and children, that leads to trafficking.” As noted in the Legislative Guide to the Protocol, this provision is mandatory. States parties to the Protocol are required to take at least some measures towards reducing demand that leads to trafficking.173 In its article 6, the European Trafficking Convention requires States parties to adopt or strengthen legislative, administrative, Legislative Guides to the Organized Crime Convention and its Protocols, para. 70. 173 RECOMMENDED PRINCIPLES AND GUIDELINES ON HUMAN RIGHTS AND HUMAN TRAFFICKING