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Modern Slavery and Environmental Degradation

Modern Slavery

Generally speaking, society does have a propensity to feel that enslavement was a sad situation that occurred in the past but is no longer prevalent around the globe. Slavery continues to exist today, despite the fact that it was banned in the nineteenth century. Modern slavery is characterized in terms of the concept of control, which includes both psychological and physical control.[1] According to the definition of modern slavery, it is considered an act of control over an individual in a manner as to significantly impair that person’s specific freedom with the aim of subjugation by the use of that person for the purpose of profit through the acquisition, selling, exchange, or disposal of such a person.[2]

For the purposes of this report, I will use the 2012 Bellagio-Harvard guidelines as outlined by Jean Allain, which also characterize modern slavery as comprising power above an individual in an approach that substantially denudes that individual of [their] personal rights with the purpose of subjugation through the usages, control, acquisition, financial gains, or transfection of that individual’s body parts or organs.[3] Essential to modern conceptions of modern-day slavery is indeed the concepts of the absence of free choice and immobility, utilisation of aggression (or even the potential violence), and capitalist exploitation, which manifests itself principally in the forms of debt-bondage and contractual servitude in dangerous manual labor.

Modern Slavery and Environmental Degradation Link

There is an increased interest in the modern slavery-environmental biodegradability connection as a study issue. This interest has been fueled by the introduction of the United Nations Sustainable Development Goals (SDGs). Developing an insight among these interconnections has been presented in the literature through the use of examples drawn from many multiple areas, including agribusiness, natural forests, contaminating production settings, and the fishing industry, in addition to the consequences of climatic variations.[4] Several types of modern slavery work in the very same regions that are adversely impacted by climatic variations and are subjected to ecological struggle and climate changes, including deforestation, pollution, and other environmental offenses.

For example, Non-governmental organizations and academics have recognized a number of locations in the Brazilian Amazon[5] wherein illicit deforestation are escalating[6]; in isolated parts of Latin America wherein illicit mining thrives in areas of conflict[7]; within the Democratic Republic of the Congo, whereby mining releases environmental contaminants and deforestation, while industrial-scale hunting harms ecosystems[8]; in Thailand, wherein fish supply is being exhausted due to illegal fishing[9]; and in South Asia, whereby brick kilns are a significant source of pollution of air as well as black carbon pollution.[10] Corruption and inadequate human and environmental privileges administration are common in these regions, where socioeconomic disparities and unequal distribution of power are routinely leveraged, indigenous rights are neglected, availability of resources is unequal, livelihoods are restricted and sensitive to disruptions, and violence prevails. Yet, the existence of hotspots does not suggest that such co-occurrences represent secluded problems.

Research has also begun to alter academic thinking beyond simple co-occurrences, with trends of linkages between contemporary slavery, environmental problems, and climate variability being identified as recurring and irregular in both bi- and multi-directional ways, signaling a connection.[11] In the fields of aquaculture, brick-making, mineral extraction (including fast fashion), forest management (including deforestation), agribusiness, renewable energy, and wildlife smuggling, it is hypothesized that this linkage will be found at play.[12] There are some significant similarities among the actions related to modern slavery in such segments, including the existence of informal sectors as well as processes, low salaries and temporary work, rising manual jobs frequency, essentially unsafe working conditions, functionality in remote and inaccessible surroundings that are not monitored or enforced, a lack of supply of labor that leads to dependence on susceptible migrant workers, and widespread illegal extraction of oil and gas that is progressively attracting slave labor.

In addition, three main trends have been identified in this link. Laborers who are exposed to modern-day slavery are compelled to engage in illegal environmental activity. Whenever committing parties elude supervision and compliance by forcing labor to circumstances of modern slavery, such environmental violations are economically lucrative and pose a low chance of discovery.[13] For instance, it is believed that around 40 percent of deforestation is carried out by laborers who are forced into modern slavery in their work. The fraction of total greenhouse gas emissions caused by deforestation varies between 17 percent and 30 percent.[14] This implies that persons enslaved in ecologically harmful types of modern slavery are indeed responsible for the release of CO2 into the atmosphere, which contributes to global warming.

As a result, by generating an increased demand for cheap labour in such industries, environmental deterioration, and unsustainable exploitation push vulnerable employees into modern slavery situations.[15] Besides that, the procurement of forced labour is less expensive than the conversion to better and more efficient technology.[16] Furthermore, extractive businesses employ modern slavery to maintain a competitive edge in disputes concerning natural assets.[17]

The third evident trend would be when environmental destruction and climatic change are the driving forces behind modern-day slavery. Whereas poverty is commonly seen as the most powerful determinant of modern slavery, a simple picture of insufficiency as the primary cause of modern slavery is oversimplified. Poverty manifests itself in a variety of ways. Among the main aspects of poverty are diminishment, limited supply, and absence of access to natural resources. These are also interconnected with the grossly unequal ideological, social, but also ethnic susceptibility to modern slavery, which includes poor governance, bribery, and discriminatory practices. Moreover, changes in climate do have a compounding impact, aggravating pre-existing differences and circumstances while raising the fluctuation of earnings and subsistence disruptions related to the environmental deterioration. As a result, people are forced into modern slavery by being forced to relocate in search of employment or better living conditions, enter invisible and risky circumstances, and concede below-standard labour environment, all of which increase their risk of falling victim to modern slavery.[18]

However, the mechanisms that permit these fundamental trends, as well as how they translate onto principles of sustainability as well as SDG ecological implications, are not as much known and haven’t been rigorously questioned given the rising wealth of data on modern-day slavery–environmental destruction- climatic changes linkage, as well as increased efforts to elucidate the linkages that underlie the universal applicability concept of the SDGs. In the context of contemporary slavery, the intersection brings together the intricate dual interactions that occur between individuals and the environment. People’s potential of being exposed to modern slavery has been linked to a variety of social interactions that have been recognized as both facilitating and restricting.[19] The nexus is a worldwide problem, so as the effects of climatic variations keep taking their toll, the hazards faced by society will indeed keep expanding.

Slavery has always existed as a component of global markets; whatever has shifted is the expense of obtaining persons who have been forced to modern slavery in labor, which has decreased drastically as the world’s population has grown. This increase in global civilization has resulted in massive shifts in the degrees of global warming and climate change, as well as in the distribution of resources. This precipitous decline in the cost of acquiring slaves, including its particular effects mostly on the lives of slaves and also the earnings of slaveholders, seems to have a profound impact on the type and conduct of slavery.[20] Quite simply, whenever the price of a person is reduced to this point, individuals fail to be considered capital acquisitions so as to become expendable contributions into financial markets or systems of environmental rapacity. In addition to being forced to do a broad variety of exploitative types of labor, the slaves are subjected to employment that is marked by low levels of automation as well as elevated amounts of environmental damage.[21]

However, it’s only been relatively lately that the environmental effect of slave-based wealth creation has been researched and evaluated, particularly in industries like brick manufacturing, mining, and logging.[22] Conflict, which is often fueled by anthropogenic change, frequently leads to the forced movement of non-combatants, increasing their susceptibility to slavery and exploitation.[23] These drastic reductions in the economic worth of enslaved people have far-reaching consequences since they lead directly and indirectly to substantial differences in the manner in which enslaved people are handled and used.

It is increasingly recognized that climate change is indeed a human rights problem, with the significance of climatic changes projected to have serious negative concerns for the fulfillment of people’s rights around the world. In relation to environmental and climatic change’s contribution to modern slavery, a complicated association between two factors (drought and susceptibility to human smuggling) was discovered by the researchers throughout their investigation.[24] Drought enhanced susceptibility to human trafficking in certain places while it decreased vulnerability in others in response to the drought. After becoming impacted by dry spells, peoples’ vulnerability is enhanced if they are situated in a particular socio-cultural layout, such as in a desolate location without infrastructure, no alternate solution to domesticated animals, and also no government involvement; they have encountered violent inter-ethnic dispute, or they have a substantial gap in quality of life between before and after the drought.

Deforestation is indeed the second most significant source of Carbon dioxide emissions in the world, behind fossil fuel combustion, and slave-based deforestation accounts for a major amount of those releases. The frequency of modern slavery is often shown to be correlated with rates of degradation. An average of 12 percent (6–17 percent) of human Carbon dioxide emissions is attributed to deforestation and deterioration of forest ecosystems and trees.[25] Modern slavery seems to do direct harm to forest ecosystems, according to the findings. But trees have indeed been proposed as a natural resource that might aid in reducing and reversing present climate trends. The level of CO2 emission through slavery matches or surpasses the total Emissions of carbon dioxide from many nations and industries once uncontrolled output based on slaves in brick kilns, mines, quarries, fisheries, and food production are taken into account.[26] Both land transformation and slavery are interrelated issues that must be addressed. Land-use changes as a result of climate change, with certain areas becoming unsuitable for agricultural production and others becoming more suitable for intensive farming. Because of the population explosion, the land is being converted to human use, which results in a loss of species diversity and nutrient recycling in forests, aggravating the undesirable effects of climatic changes. In particular, the illegal logging of forest reserves by exploited labour, which results in the emission of massive quantities of CO2 into the atmosphere, has caused widespread deforestation. Forest loss also contributes to inundation, which may be particularly devastating for coastal populations hit by severe storms from cyclones and hurricanes, as well as tsunamis.

Between 2020 and 2050, it is projected that the remaining supplies of wildland that may be turned into agriculture will be depleted.[27] Other negative elements gain more strength as a result of the transfer of habitats from wild to cultivated states. If this is coupled with changing climate and inadequate agricultural practices, it may result in, for instance, forests that are in the process of transitioning into deserts. As a result of the transformation of both the rich and diverse Amazonian rainforests to pastureland, compacted soils are formed, which are unable to absorb large amounts of precipitation or maintain a lush environment. When trees are cut down, they leave behind a depleted and degraded watershed that fails to provide a consistent flow of groundwater to the populations who rely on it for survival. Because of the consequences of land-use changes, the pattern of climate-driven shift is exacerbated, displacing communities and families, reducing their economic and sustenance capabilities, and increasing their susceptibility to exploitation.

Modern slavery sometimes entails the use of toxic chemicals or unsafe working conditions, which may contribute to environmental degradation and pollution as well as expedite it.[28] As part of their duties, enslaved people may be expected to utilize synthetic organic chemicals like insecticides, defoliants, as well as fuel additives. Additional compounds are formed by mining and other operations, including radioactive elements and extremely dangerous metals like cadmium, lead, or mercury that are then dispersed throughout the environment. Supplementary to this is the distribution of sulfur and nitrogen compounds in the atmosphere, which is a byproduct of the combustion of fossil fuels and has negative health impacts as well as contributing to acidification. It is possible that a toxic substance like mercury will accumulate in top predators, including spiders, birds, and even some types of fish like sharks, and afterward flow from them to humans, which would be the peak lifeform within the food chain.

Biomagnification is the phenomenon whereby the levels of an element rise as it advances up the food web.[29] When people are exposed to mercury poisoning, which is frequent amongst enslaved gold miners, they experience a decrease in their ability to fight illness and suffer damage to their organs and neurological system, particularly the brain. Combined, the effect of such contaminants varies from inconsequential to disastrous and lethal – as in the case of the Bhopal chemical plant explosion and tragedy. Working in extraction or other extremely polluting environments without proper protection from inhaling or absorption can turn into a death sentence for those who have already been enslaved by their jobs.[30] Aside from polluting the environment, these exploitative, as well as physically destructive circumstances, typically lead to family poverty and greater exposure to a wide range of other issues, including slavery.

There is a worldwide trend of ecological deterioration in fisheries and a decrease in fish populations, which is being caused by unsustainable and intensive production techniques. Forecasts anticipate that climate change would worsen pressures on fish populations while also diminishing the richness of marine life, especially as a result of acidification of the oceans and increasing frequency and intensity of storms.[31] Aquaculture, also known as “fish farming,” has gone up significantly as a response to reducing wild fish populations. It now accounts for approximately half among all seafood produced worldwide; even so, it is highly dependent on fishmeal, especially for species that are higher up within the aquatic system.

Studies of the complicated relationships involving overfishing, illicit fishing techniques, and debt-bonded labor inside the setting of Thai fisheries have represented the research on the linkage in this industry.[32] The economic forces are driving further utilisation of debt-bonded labour within the Thai fishing sector, relying on first-hand data gathered by EJF.[33] Numerous migrants from neighboring countries have indeed been recognized as being abused and forced into the Thai fishing sector. They are solicited by intermediaries under false pretenses and via deceitful agreements, with many of these employees being women. Thailand’s fisheries have seen the emergence of slave labor, largely a result of debt-bondage. Here, employees acquire a first debt, which is related to recruiting fees and travel and paperwork charges, which would be intentionally kept by fishing vessel operators via deceptive accounting and outrageous rates of interest.[34] It is common for charges to be deducted from employees’ wages in order to repay the loans, and workers are typically prohibited from leaving their jobs until the obligation has been paid off.

Despite the fact that slavery, bonded labor, debt servitude, as well as coerced sexual abuse are all often classified as separate categories, they are really interconnected and represent a spectrum of slavery in the modern-day.[35] Climate change, as well as climate-induced displacement, exacerbates slavery’s already-existing risks. The factors that put people at risk of contemporary slavery are many and complicated, and they are influenced by several levels of risk. While a variety of socio-economic, governmental, social, and organizational concerns influence susceptibility, it is becoming more clear that climate change effects and environmental degradation exacerbate the situation even further. Displacements caused by climate change are increasingly inescapable. In nations like the Solomon Islands, and Sierra Leone, rising sea levels, salinization, and floods are now driving whole coastal populations to evacuate due to the effects of climate change.[36] Furthermore, if climatic shocks continue to deepen, plenty more millions of people will indeed be relocated as a result of climate change during the future years.[37]

Climate change has an impact on relocation and displacement paths, according to a growing body of scientific evidence. Previous studies and data show that there is indeed a link connecting climate change and climate-induced migrations and extreme types of enslavement in at minimum three situations. In the wake of calamities, unexpected phenomena might occur. The first route is a very well and is often quoted in scientific literature. Evidence suggests that people trafficking rose in the following the Indonesian tsunami. [38]

Disasters or calamities with a slow onset whereby the second route suggests that climatic variability – like increasing warmth and unpredictable rainfall – frequently results in droughts, which results in overall agricultural damage, drinking water problems, and food poverty. Communities that are reliant on environmental assets and agriculture are compelled to seek other means of subsistence when faced with such circumstances. The pursuit of unsafe or unsafe migration prospects, as well as the accruing of loans, may be used in the lack of suitable local alternatives. Using meticulous precision, Blood Bricks depicts the fine intricacies about how farmers in Cambodia, for whom lives and careers have been damaged by changing climate, are dragged into multigenerational enslavement by kiln company owners who purchase their debt and compel them to labor in sub-human circumstances.[39]

Phenomena with a slow start, compounded by conflict as well as forced relocation, create a dangerous situation. The last route reveals large-scale gradual forced relocation as a result of conflict precipitated by slow-onset natural catastrophes, like drought and hunger, which results in large-scale progressive forced migration. In spite of the fact that no clear connection has yet been proved connecting climate change and conflicts, it is obvious that nations suffering conflict including elevated levels of instability are less prepared to deal with the detrimental impacts of climatic shocks as well as environmental conditions. As war weakens existing power structures, economies, and livelihoods safety nets, populations are left with no resources they need to adjust or deal with their circumstances. Lost of income, relocation, increased levels of food shortages, and inflation as a consequence push people to attempt riskier coping techniques, which often culminate in debt bondage.

Modern slavery has been linked to climate-induced migrations in two international hubs of modern – day slavery: the Sundarbans delta of Bangladesh as well as Ghana.[40] Research papers in the two places offer evidence of an association for both climate-induced migrations and modern day slavery. These two scenarios demonstrate that changes in climate have resulted in environmental degradation, increasing economic instability, and food shortages, all of which have had a negative impact on the wellness of impoverished families, especially women and children, in both situations. As a result of a lack of viable options and means for livelihood, as well as poor household resiliency, intra- but also transboundary movement has occurred throughout rural and urban regions, subjecting people engaged to slavery as well as slavery-like activities.

Conclusion

Slaveholders are destroying several of the world’s most ecologically significant spots, including those that are essential for keeping a stable climate and conceivably offsetting the effect of global warming. They are doing so with little due consideration for international regulations, treaty obligations, or environmental legislation. Modern slaves are driven to damage their respective livelihoods at the same time as they weaken any possibility of halting global climate change. In the absence of proper climate mitigation and management policies, increasing climate stressors, like severe weather occurrences, may push disproportionately affected people to seek alternate livelihoods as well as survival alternatives, including via dangerous avenues.

Specifically, the analysis found the link connecting modern slavery and ecological degradation, which tend to arise sectorally, with the majority of studies focusing on four significant aspects: fisheries, agriculture, forests, and manufacturing. According to the findings of the review, such areas are linked both geographically (for example, interactions among climate-induced relocation and severe versions of worker exploitation throughout locational spots) and structurally (for example, people might well be pushed into bonded labor in various industries by same variables). Due to the intricate interconnections between worker exploitation as well as environmental change that exist across space and industry, I believe any prospective goal that seeks to investigate these connections should cut across industries and spaces. A comprehensive strategy that recognizes the interconnections between social and environmental issues is required.

Bibliography

Al-Dayel, N., Mumford, A., and Bales, K. ‘Not yet dead: The establishment and regulation of slavery by the Islamic State.’ (2020) Studies in Conflict & Terrorism, 1-24.

Allain J. ‘Slavery and its Definition–Jean Allain and Kevin Bales. In the Law and Slavery 2015 Jan 1’ (pp. 502-512). Brill Nijhoff.

Allain, J. ‘2012 Bellagio-Harvard Guidelines on the Legal Parameters of Slavery.’ (2013) In Slavery in International Law, pp. 371-378. Brill Nijhoff.

Bales, K., and Sovacool, B. K. ‘From forests to factories: How modern slavery deepens the crisis of climate change.’ (2021). Energy Research & Social Science, 77, 102096.

Bharadwaj, Ritu, and others ‘Climate-induced migration and modern slavery.” (2021).

Brown, D, Doreen S. B., Katherine B, Christopher D. I., Nithya N., and Laurie P. ‘Modern slavery, environmental degradation and climate change: fisheries, field, forests, and factories.’(2021) Environment and Planning E: Nature and Space 4, no. 2: 191-207

Boyd, D. S., Bethany J., Jessica W., Giles M. F., Stuart M., and Kevin B. ‘Slavery from space: Demonstrating the role for satellite remote sensing to inform evidence-based action related to UN SDG number 8.’ (2018) ISPRS journal of photogrammetry and remote sensing 142: 380-388.

Bales, K. Blood, and earth: Modern slavery, ecocide, and the secret to saving the world. (Random House, 2016).

Coelho, S. ‘The Climate Change-Human Trafficking Nexus (International Organization for Migration [IOM]). (2016) <https://publications.iom.int/system/files/pdf/mecc_infosheet_climate_ change_nexus.pdf.> accessed 28/03/2022.

Decker Sparks, Jessica L., and Hasche, L.K. ‘Complex linkages between forced labor slavery and environmental decline in marine fisheries.’ (2019) J. Hum. Rights 18, 230–245. <https://nottingham-repository.worktribe.com/preview/3356239/Sparks_JHumanRights.pdf> accessed 28/03/2022.

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Jackson, B., Vicky B., Nicole T. B., and Jessica L. D. S. ‘Modern slavery, environmental degradation and climate change: present and future pathways for addressing the nexus.’ (2021).

Jackson, B., and Sparks, J. L. D. ‘Ending slavery by decarbonisation? Exploring the nexus of modern slavery, deforestation, and climate change action via REDD+.’ (2020) Energy Research & Social Science, 69, 101610.

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[1] David Brown and others. ‘Modern slavery, environmental degradation and climate change: Fisheries, field, forests and factories’ (2019) 2, Saje Journals 191-207. < https://doi.org/10.1177/2514848619887156> accessed 28/03/2022.

[2] Jean Allain ‘Slavery and its Definition–Jean Allain and Kevin Bales.’(2015) In the Law and Slavery, pp. 502-512.

[3] Jean Allain ‘2012 Bellagio-Harvard Guidelines on the Legal Parameters of Slavery.’(2015) In Slavery in International Law, pp. 371-378.

[4] Bethany Jackson and others, ‘Modern slavery, environmental degradation and climate change: present and future pathways for addressing the nexus.’ (2021).

[5] Kelvin Bales, Blood and earth: Modern slavery, ecocide, and the secret to saving the world. Random House, 2016.

[6] Herton Escobar, ‘Brazil’s deforestation is exploding—and 2020 will be worse.’ (2019) Science 22.

[7] Livia Wagner, ‘Organized crime and illegally mined gold in Latin America. (Global Initiative against Transnational Organized Crime)’ 2021.

[8] Kelvin Bales (note 5).

[9] Environmental Justice Foundation (EJF). ‘Pirates and Slaves: How Overfishing in Thailand Fuels Human Trafficking and the Plundering of Our Oceans.” (2015).

[10] Doreen Boyd, S., et al. ‘Slavery from space: Demonstrating the role for satellite remote sensing to inform evidence-based action related to UN SDG number 8.’ (2018) ISPRS journal of photogrammetry and remote sensing 142: 380-388.

[11] Jessica Sparks L. Decker, et al. ‘Growing evidence of the interconnections between modern slavery, environmental degradation, and climate change.’ (2021) One Earth 4.2, 181-191.

[12] Doreen Boyd, S., and others (Note 10) 384.

[13] Eve de Coning, ‘Transnational organized crime in the fishing industry’ (2011) United Nations Office on Drugs and Crime. <http://www.odi.org.uk/sites/odi.org.uk/files/odi-assets/publicationsopinion-files/7686.pdf> accessed 28/03/2022.

[14] Intergovernmental Panel on Climate Change. Summary for policymakers. In Climate Change 2007: The Physical Science Basis. Contribution of Working Group I to the Fourth Assessment Report of the Intergovernmental Panel on Climate Change, (2007), S. Solomon, D. Qin, M. Manning, Z. Chen, M. Marquis, and K.B. Averyt, et al., eds. (Cambridge University Press), p. 3.

[15] Jessica L. Decker Sparks and Leslie K. Hasche. ‘Complex linkages between forced labor slavery and environmental decline in marine fisheries.’ (2019) Journal of human rights 18.2:230-245<https://nottingham-repository.worktribe.com/preview/3356239/Sparks_JHumanRights.pdf> accessed 28/03/2022.

[16] Anke Schaffartzik. Works in favor of extraction: labor in land-use competition. (2018) Sustainability 10, 1961. <DOI:10.3390/su10061961> accessed 28/03/2022.

[17] Liam Downey and others. Natural resource extraction, armed violence, and environmental degradation. (2010) Org. Environ. 23, 417–445. <https://www.ncbi.nlm.nih.gov/pmc/articles/PMC3169238/> accessed 28/03/2022.

[18] Sabira Coelho. ‘The Climate Change-Human Trafficking Nexus (International Organization for Migration [IOM]).’ <https://publications.iom.int/system/files/pdf/mecc_infosheet_climate_ change_nexus.pdf.> accessed 28/03/2022.

[19] Bethany Jackson and others (note 4) 5.

[20] Kevin Bales and Benjamin K. Sovacool ‘From forests to factories: How modern slavery deepens the crisis of climate change.’ (2021) Energy Research & Social Science, 77, 102096.

[21] Kevin Bales and Benjamin K. Sovacool (note 20) 3.

[22] Bethany Jackson and Jessica L. Decker Sparks. ‘Ending slavery by decarbonisation? Exploring the nexus of modern slavery, deforestation, and climate change action via REDD+.’ (2020) Energy Research & Social Science, 69, 101610.

[23] Nadia Al-Dayel and others. ‘Not yet dead: The establishment and regulation of slavery by the Islamic State. (2020) Studies in Conflict & Terrorism,’ 1-24.

[24] Bethany Jackson and others (note 4) 8.

[25] Bethany Jackson and Jessica L. Decker Sparks (note 22) 3.

[26] Kevin Bales and Benjamin K. Sovacool (note 20) 9.

[27] Johan Rockström and others. ‘Planetary boundaries: exploring the safe operating space for humanity.’ (2009) Ecology and society 14.2.

[28] Kevin Bales and Benjamin K. Sovacool (note 20) 13.

[29] Kevin Bales and Benjamin K. Sovacool (note 20) 14.

[30] Kelvin Bales (note 5)

[31] David Brown and others (note 1) 5.

[32] Zhu Zhongming and others. ‘Modern slavery and climate change are in a vicious cycle of degradation, according to experts.’ (2018).

[33] Environmental Justice Foundation (EJF) (note 9) 5.

[34] David Brown and others (note 1) 5.

[35] Ritu Bharadwaj and others. “Climate-induced migration and modern slavery.” (2021).

[36] Ritu Bharadwaj and others (note 35) 1.

[37] Ibid 2

[38] Ritu Bharadwaj and others (note 35) 2.

[39] Ritu Bharadwaj and others (note 35) 3.

[40] Ibid 3-4.

 

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