For the past six years, New Zealand has treated prostitution as a normal business. Brothels operate legally, and sex workers are subject to ordinary employment and health and safety rules.
Some European governments, by contrast, have chosen to restrict the trade. Sex workers are calling for New Zealand-style liberalisation, but as Henri Astier reports in the second of two articles, they stand little chance of being heard.
Even the liberal Dutch want to clamp down on the sex industry
When Norway criminalised the purchase of sex services in January, it took its cue from next-door Sweden, which pioneered the policy in 1999, rather than far-off New Zealand.
Wholesale decriminalisation may work in a South Pacific island nation, but the suggestion that it could work on a continent where ruthless gangs move all too freely strikes many as fanciful.
"New Zealand might be different because it is so isolated," says Anna Narit of the Nadheim Women's Centre, a church-run shelter in Oslo that looks after prostitutes rescued from traffickers and criminals.
"We have a lot of migration in Europe, and the borders are open," she says, defending Norway's new law under which those caught paying for prostitutes can face a heavy fine or six months in prison.
The idea behind the approach is not to target prostitutes, who are regarded as victims, but to empower them.
Clamping down on demand for their services is expected to weaken the hold of those preying on them.
The same rationale applies to a bill making its way through the British parliament, which will make it a crime to pay for sex with someone "forced into prostitution" or "controlled for another's gain".
2003 NZ PROSTITUTION REFORM
Brothels allowed to operate
Up to four prostitutes can set up collective as equal partners
Advertising sale of sex legalised
Brothels require certificate and registration by court
Sex work subject to normal employment and health and safety standards
Supporters of the legislation argue that trafficking and other forms of coercion are rife in the sex industry.
"Something like 80% of women in prostitution are controlled by their drug dealer, their pimp, or their trafficker," MP Fiona Mactaggart told the BBC in November.
Another Labour politician, Denis MacShane, estimated in 2007 that there were as many as 25,000 sex slaves in Britain.
However those speaking for sex workers dispute the figures, and believe that their rights and safety would be better protected through liberalisation rather than further repression.
"We think the New Zealand law should serve as a model for the rest of the world," Cari Mitchell of the English Collective of Prostitutes told the BBC News website.
She calls the proposed legislation for England and Wales a "moral crusade", and says the popular picture of an industry dominated by criminals holding girls in virtual bondage is "a big lie".
The numbers surrounding trafficking have long been a matter of controversy. This is partly due to the lack of a clear, agreed definition.
An estimated 80% of sex workers in London are foreign
Most people think of "trafficked women" as girls lured abroad under false pretences and forced by violent men to work off some fictitious debt.
However police reports often use the term to refer to illegal migrants.
The Poppy Project, a British group that has carried out research into prostitution, has estimated that 80% of women working in brothels in London are foreign.
The report does not use the word "trafficking", but according to Julia O'Connell Davidson of the University of Nottingham, advocates quoting the report have used the term, contributing to public confusion.
"People understand it as meaning that 80% of sex workers have been brought in at the barrel of a gun and locked into buildings, which is not the case," she told the BBC news website.
No one knows how many prostitutes in Britain work under duress, but police raids carried out in more than 1,300 brothels nationwide in 2006 and 2007 suggest the numbers are not as high as many fear.
About 250 of the women rescued were said to have been victims of trafficking, police said.
The total number of people picked up is not known, but assuming an average of four prostitutes per establishment - a figure commonly used by support groups - this suggests that less than 5% meet the police definition of "trafficked".
NO SEX PLEASE
Sweden: Paying for sex made outlawed in 1999
Norway: Buying sex outlawed in January 2009
England and Wales: MPs considering ban on purchase of sex from "controlled women"
Netherlands: Ban on buying sex from trafficked people proposed by Cabinet
The number is no doubt disturbing, but a far cry from the most alarming figures.
That proportion, incidentally, is not much more than the 4% share of New Zealand prostitutes which a 2008 parliamentary report estimated were being kept by force.
The prostitution industries of both Europe and the South Pacific may not be poles apart after all.
Both the New Zealand Prostitutes Collective and European organisations representing sex workers argue that the overwhelming majority of women in the industry have made a conscious choice, and that Swedish-type laws are addressing a largely non-existent problem.
Liv Jessen of Pro Sentret, a Norwegian support group for prostitutes, contends that the rationale for Norway's new law is spurious, because trafficking is already punishable by 10 years in jail.
She says the most notable effect of the legislation is that it has made sex workers feel more vulnerable, as they view police as hostile.
Ms Jessen says it would have been "fairer and more honest" to ban prostitution outright. "The women would have a better status as criminals than as victims harassed by police for their own good."
Neither did sex workers in neighbouring Sweden support the 1999 ban on buying sex. Sans, a network of Swedish prostitutes' groups, was opposed to it and is calling for New Zealand-style decriminalisation.
Why is there such a discrepancy between what so many people across Europe assume about the sex trade and testimony from within the industry?
According to Julia O'Connell Davidson, public perception is heavily influenced by organisations that support those prostitutes who have had abusive experiences.
The cases are real and these groups play an important role, but they deal with extreme situations. The sex industry as a whole should not be judged on the basis of their advocacy, Ms O'Connell Davidson argues.
"It's a bit like judging the state of heterosexual relationships in Britain today by talking just to people who work in domestic violence units."
Effective lobbying by anti-prostitution groups and the revulsion caused by human traffickers mean that calls for New Zealand-style liberalisation are falling on deaf ears in Europe.
Nordic-style prohibition is gaining recruits even in the liberal Netherlands, which legalised brothels in 2000.
Many Dutch politicians point to evidence that the reform has failed to sever links between prostitution and crime. As a result parliament is considering a government plan to ban the purchase of sex from trafficked women.
Sietske Altink of De Rode Draad (Red Thread), an advocacy group for Dutch prostitutes, says such a clampdown is unwarranted. Trafficking may be rife, she concedes, but it does not mean coercion is.
"Lots of trafficked women knew they were going to work as sex workers," she says.
In the Netherlands, Ms Altink notes, prostitutes are also strongly opposed to criminalising punters but few politicians are interested in their views.
"It's very curious they don't want to listen to the people they make the laws for," she says.