Page last updated at 13:37 GMT, Friday, 16 July 2004 14:37 UK

Prostitution: International answers

By Dominic Casciani
BBC News

The UK government launched a major consultation on what to do about prostitution in July 2004. But how do other nations deal with prostitution? Do their schemes work or make things worse?

Country: Sweden
Concept: Shifting the focus onto the kerb crawlers

How it works

When Sweden set about reforming its laws on prostitution, it decided to make it clear that the purchaser of sex was the villain and the prostitute the victim.

Kerb crawling: Target in Sweden
Under Swedish law there are no offences of loitering or soliciting, but paying for sex on or off the street is a crime. The country has also introduced a comprehensive "out-reach" programme to help women.

What works with the scheme?

The number of women involved in street prostitution has declined. The Swedes say a key element of their success has been funding schemes to get women off the streets completely.

They also believe they have had some success in reducing the social stigma of prostitution.

But what are its drawbacks?

The British government was circumspect about whether it would work in the UK but has adopted parts of this model, making it illegal to pay for sex where the prostitute is being controlled by someone else.

Sweden's circumstances are however quite different. It has proportionally far fewer street prostitutes than the UK. Secondly, Swedish prostitutes do not have the same overwhelming rates of drug addiction as seen elsewhere. Experts also say that this strategy appears to consume a lot of police time and effort.

Country: The Netherlands
Concept: Managed "tolerance zones"

How it works

The Dutch created "working areas" - official red light districts where prostitutes are concentrated together.

Brothels: Licensed around the world
Local authorities targeted their drugs and welfare support at these zones, hoping to get more of the women out of the business. Managed areas are patrolled by the police and drug dealing is officially prohibited. Two British cities, Doncaster and Liverpool, said they were previously wanted to try this model.

What works with the scheme?

In theory, the concentration of sex workers makes it easier for the police to target the criminals and kerb crawlers while social services target the women.

Supporters say it reduces crime in residential areas and reduces the stigma of prostitution. Health services progressively improve their contact with the prostitutes because their whereabouts are more controlled.

But what are its drawbacks?

Some of the Dutch schemes have failed. When police stopped drug dealing within a zone, the prostitutes left to work in other areas.

But if police turn a blind eye, it defeats the purpose of trying to tackle drug abuse in the first place. If the zones were limited to those who are drug-free, those most in need of help would miss out.

Nominating areas is fraught with difficulty because of the balance between creating somewhere safe and minimising the risk to residents.

Finally, creating managed zones means accepting the permanence of prostitution - something many members of the public would not accept.

Countries: Australia, New Zealand and the Netherlands
Concept: Various forms of brothel licensing

How it works

Three of Australia's six states run licence schemes for brothels.

A prostitute walking on a city street
Prostitution: Local councils are pushing for reforms
The idea is that they provide a safe workplace - but also protect the clients too. Brothel owners must be licensed, have local permission for their location and ensure their premises are limited to six rooms. Prostitutes must also have regular health checks.

New Zealand also legalised brothels, giving women the power to be "owner-operators".

What works with the scheme?

Supporters say legalised brothels are safer than working on the streets because the prostitutes are able to protect each other and screen clients.

It also provides an easy way for health services to target the prostitutes and for police to keep tabs on what is going on. Supporters say only licensed brothels stand any chance of significantly reducing criminality.

But what are the drawbacks?

Many brothels in Australia appear to be in the hands of the same criminals who would otherwise control street prostitutes.

In the Netherlands, a commission found organised crime's control of prostitution increased following licensing.

There is little evidence that illegal street prostitution has decreased in these countries.

The UK also fears brothels would not help tackle the serious problem of the trafficking of women into the sex trade from abroad.

Other research suggests there have been few health benefits - The Australian state of New South Wales said the prevalence of some sexually transmitted diseases worsened after the law was changed.

Countries: Austria, Germany and Greece
Concept: Licensing the prostitutes themselves

How it works

In Austria, registered prostitutes must be at least 19-years-old and are obliged to attend regular health checks.

They can be limited to working in certain areas, or even banned entirely from the streets. Similar rules are in place in Germany and Greece.

What works with the scheme?

Supporters say it ensures that those involved are regularly screened for sexually or drug transmitted diseases. Police and social services have good opportunities of targeting the women, say supporters.

But what are the drawbacks?

Some research suggests voluntary testing works better than trying to force people to attend check-ups.

A major fear is that mandatory testing creates "two-tiers" of prostitutes: Those who are being assisted and those who are not.

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