Trends, Precipitating Factors and Control of Human Trafficking in South Africa and Zimbabwe

This paper explores the scourge of human trafficking in South Africa and Zimbabwe- two neighboring Southern African nations. Data for this study were obtained from research articles, documents and online articles on trafficking in persons. The paper highlights the trends, push/pull factors, the control, as well as the obstacles to effective control of human trafficking within the two countries. The paper reveals that South Africa is characterized by pull factors, largely due to its position as the economic powerhouse of Southern Africa. Conversely, human trafficking in Zimbabwe is mainly spurred by push factors emanating from acute socio-economic problems. Despite significant efforts in the control of trafficking in persons through legislation and enforcement, loopholes in the trafficking in persons legislation within the two nations, as well as persistent economic challenges in Zimbabwe, are impeding the effective control of human trafficking.


Introduction
With its end seemingly not in sight, human trafficking continues to be a perennial problem affecting the human security in both the developing and the developed world. Human trafficking is a transnational organized crime, whose consequences on individuals, socio-political and economic fronts are compelling. Victims of human trafficking suffer from physical abuse, psychological and emotional trauma, whilst societies, economies and the political climate within nations are seriously impacted by the scourge. The characteristic gruesome nature of human trafficking and its serious ramifications, not only on global security, "but also on human lives, have consistently elicited outcries from various global stakeholders" (Bello & Olutola, 2018: 270). Although human trafficking is global phenomenon that knows no borders, its far-reaching implications are however felt within individual countries. Whilst trafficking in persons is a common phenomenon almost in all continents around the globe, it is endemic in Africa (Bello & Olutola, 2020;Bird & Reitano, 2019). Just like in other continents and other African regions, human trafficking is also a serious human security concern within the Southern African region (Southern African Development Community (SADC) Secretariat, 2016). Within the SADC region, the impacts of human trafficking are far-reaching, with the scourge affecting individuals, communities and the wider region, thereby reducing the socio-economic status of the region's citizens to mere commodities, as well as negatively impacting on the region's peace and security agenda (SADC Secretariat, 2016).
Against this background, this paper focuses on human trafficking within two Southern African nations -South Africa and Zimbabwe, the later being a developed nation and the former being a developing nation that has been characterized by acute socio-economic challenges. The choice of the two countries was largely influenced by the close proximity of the two countries, given that they share perhaps the busiest border post on the African continent-Beitbridge border post. Moreover, as shall be seen in this paper, the economic problems bedeviling Zimbabwe have ramifications on human trafficking within the two nations. The paper specifically focuses on three aspects, namely: the trends in human trafficking; the precipitating factors; and the control of human trafficking. Given the longstanding concern over absence of comprehensive data on human trafficking (Bello & Olutola, 2018;Dempsey, 2017;Roper et al., 2020;Van der Watt, 2018) this article was based on a documentary survey of research articles, policy documents, online news platforms and statutory instruments on human trafficking. In order to reveal the current trends, articles and documents that were published between 2016 and 2020 were reviewed. The paper gives current context-specific information pertaining to the human trafficking problem in two Southern African nations. Whilst several studies on trafficking in persons have been conducted in South Africa, very limited research has been conducted in Zimbabwe. Other than adding to the existing body of knowledge on this perennial problem, the paper gives the current trends on the problem of human trafficking, which will help law makers and other policy makers in crafting comprehensive human trafficking control policies from an informed position.

Conceptualizing human trafficking
Perhaps one area which has made it difficult to deal with the human trafficking scourge is the absence of clarity in the definition. The term "human trafficking" or "trafficking in persons" has been a relatively challenging concept to define (Roper et al., 2020) and the argument as to what constitutes human trafficking has often been a central issue of debate (Bello & Olutola, 2018). Notwithstanding the definitional problems, the starting point for defining human trafficking was the United Nations (UN)'s 2003 Protocol to Prevent, Suppress and Punish Trafficking in Person (known as the Palermo Protocol), in which Article 3 defines human trafficking as follows: "The recruitment, transportation, transfer, harbouring or receipt of persons, by means of the threat or use of force or other forms of coercion, of abduction, of fraud, of deception, of the abuse of power or of a position of vulnerability or of the giving or receiving of payments or benefits to achieve the consent of a person having control over another person, for the purpose of exploitation." Despite its seemingly comprehensive nature, the UN definition has proven to be imprecise, leading to much confusion amongst lay persons, policy-makers and academics (Roper et al., 2020). One critical loophole in the above definition is the absence of clarity on what the term "exploitation" means. Included in the definition was a non-exhaustive list of practices, which include slavery, forced labor, and organ removal (Bird & Reitano, 2019). Consequently, an everexpanding list of practices is now deemed as exploitation, leading to a dilemma on how to precisely deal with the scourge. Some of the practices that are deemed to constitute exploitation include: "unethical adoptions, prostitution, pornography, webcam sexual exploitation of children, forced begging, and kidnapping for the purpose of terrorism" (Bird & Reitano, 2019: 3). However, it can be argued that the Palermo Protocol set the foundation upon which various nations were supposed to build up, hence individual nations were supposed to come up with precise definitions.
There is however consensus among academics that human trafficking comes in many forms. Labour trafficking is perhaps the most dominant form of human trafficking is labour trafficking, and it entails "the use of violence, threats, lies, debt bondage, or other forms of coercion to force people to work against their will" (Movsisyan, 2019: 545). The victims, most of whom will not be having proper documentation, will be subjected to inhuman working conditions characterized by long working hours and very low earnings (Movsisyan, 2019). A global survey that was conducted by the International Labor Organization on human trafficking established that over 40 million people across the globe were in modern slavery (Walk Free Foundation, 2017). Sex trafficking is also another dominant form of human trafficking. There are several offences which are linked to human trafficking for sexual exploitation and these include: forced marriage, child sex tourism, child pornography, as well as other bad cultural practices (Van der Watt, 2018). There is also a growing phenomenon of human trafficking for the purpose of organ removal. Given the absence of a legal market for organs, the illegal trade in human organs is estimated to be generating "about 1.5 billion dollars from around 12,000 illegal transplants per year" (Gonzalez, Garijo & Sanchez, 2020: 2). Another similar classification of the forms of exploitation is proffered by May (2017: 3) as follows: "sexual exploitation, forced labor, and slavery or slavery-like practices". Trafficking in persons cases are on numerous occasions also subsumed under a range of other criminal activities that include rape, kidnapping, abduction, domestic violence, civil and labor disputes (Dempsey, 2017;Roper et al., 2020).
An important aspect regarding the contemporary forms of human trafficking is the central role that technology is playing. Research has shown that perpetrators are using technology during the three phases of the human trafficking crime -recruitment, control and exploitation (EUROPOL, 2018). In order to hide their identities and to maintain anonymity, perpetrators are using fake social media accounts to recruit their victims [Inter-agency Coordination Group Against Trafficking in Persons (ICAT), 2019]. The 2018 United Nations Office on Drugs and Crime (UNODC) human trafficking report reveals that traffickers identify potential victims on various social media platforms, establish relationships of trust with the victims before entrapping the victims in exploitative situations (UNODC, 2018). Moreover, crypto currency makes it possible for traffickers to anonymously transact and move criminal proceeds (ICAT, 2019). With the expansion of the Internet and advances in digital technology, a new crop of players involved in trafficking in persons is also emerging. Movsisyan (2019) notes that Internet Service Providers (ISPs) are also profiteering from trafficking in persons through facilitating the crime. For example, the Internet Watch Foundation (IWF) received "57,335 reports of websites containing child sexual imagery in 2016, with 5,452 of these websites being used for commercial sexual abuse" (IWF, 2016: 3). Contrary to the common trend of sex trafficking occurring on the streets, at casinos, truck shops and other physical locations, the exploitation is now being predominantly done online (Movsisyan, 2019).

Human trafficking trends in South Africa
Official statistics on human trafficking in South Africa are hard to come by, largely due to the absence of "a centralized database and aggregated data on the scope, nature and extent of human trafficking" (Van der Watt, 2018: 8). This absence of reliable statistics on human trafficking prevalence in South Africa has been of urgent and persistent concern to the South African government, non-governmental organizations, academics and policy makers (Roper et al., 2020). However, research has been conducted and policy documents have been authored on human trafficking in South Africa and this paper builds on these researches and policy documents. Overall, South Africa is predominantly a destination country for trafficking in persons, with most of the victims being trafficked from the Southern African region, as well as other African nations (Bello & Olutola, 2020; Southern African Development Community (SADC) Secretariat, 2016). Other victims are also trafficked from countries such as Bangladesh, Cambodia, China, Eastern Europe, Pakistan and Thailand for exploitation in South Africa (SADC Secretariat, 2016). Due to South Africa's air transport links to international destinations, this also makes the country a transit point for intercontinental human trafficking between Africa and other continents (SADC Secretariat, 2016). Whilst South Africa mainly serves as a destination country for human trafficking, there are also incidents where South African nationals are trafficked to other countries where they are forced to engage in various forms of criminal activities (Van der Watt, 2018). Nations like Brazil, China, Switzerland, USA and the Middle East are the destination countries for victims who are trafficked from South Africa (SADC Secretariat, 2016). As will be seen in the proceeding paragraphs, there is also internal trafficking in persons, which entails trafficking of victims from rural areas to urban centers for exploitation.
Research has shown that labor trafficking is perhaps the most dominant form of trafficking in persons for South Africa. As the economic powerhouse for both the Southern African region and the African continent at large, the nation has also served "as a major hub for trade in human commodity" (Bello & Olutola, 2020: 3). South Africa is a destination for both poor and low-skilled people, as well as highly skilled workers from neighboring countries such as Zimbabwe (Roper et al., 2020;Van der Watt, 2018). Large numbers of undocumented migrants easily cross into South Africa through the country's expansive maritime and land borders (Van der Watt, 2018). Most unskilled migrants are forced to work in mines, farms and for domestic servitude with very low remuneration (Frankel, 2016;Roper et al., 2020;SADC Secretariat, 2016; US Department of State, 2020). Given the illegal migrants' status, the victims may not be able to seek for help from law enforcement officials and other organizations which can assist them, as this will further expose them to deportation if their illegal migrant status is found out. The influx of undocumented migrants into South Africa has been witnessed during the COVID-19 lockdown era, when illegal migrants, predominantly Zimbabweans, risked their lives by crossing into South Africa through the crocodile-infested Limpopo river.
Labor trafficking in South Africa is two pronged-inter-state and intra-state. In one of the researches, Van der Watt (2018:7) notes a scenario in which men and boys are lured into South Africa's Free State province "from rural villages in Mozambique for illicit mining operations". Bello & Olutola (2020) also note the trafficking of Mozambican nationals from Maputo to Durban and Johannesburg, where women are forced to provide sexual services to minors, whilst men are exploited for labor related tasks at mines. Perpetrators also recruit street children from Lesotho, mainly victims of abuse at home and children orphaned by AIDS, and they are taken to the Maseru -Lesotho's capital, from where they are then trafficked to work as farm laborers in the Eastern Cape by mostly white Afrikaans (Bello & Olutola, 2018). Notwithstanding the predominance of inter-state human trafficking, intra-state human trafficking is also common. Victims are trafficked from rural areas to cities such as Pretoria, Johannesburg, Cape Town, Durban and Bloemfontein, with women exploited as domestic servants, whilst men serve as street vendors, street beggars, farm laborers and for other criminal activities (Bello & Olutola, 2020; US Department of State, 2020).
Trafficking for sexual exploitation is also a growing trend in South Africa. Perpetrators recruit their victims from other poor SADC countries and poor rural areas within South Africa to main urban areas, where the victims are forced into sex trafficking (Bello & Olutola, 2020;Sambo & Spies, 2020; US Department of State, 2020). The United States' 2020 Trafficking in Persons Report notes that organized crime syndicates that are dominated by Nigerian nationals predominantly facilitate commercial sex industry trafficking (US Department of State, 2020). The sex trafficking business thrives due to "harsh living conditions mostly characterized by high unemployment levels", acute poverty and "lack of prospects" in their areas or countries of origin (Sambo & Spies, 2020: 78). Closely related to sex trafficking is forced marriage-a cultural practice known as "ukuthwala" in South Africa's the Eastern Cape Province. "Ukuthwala" involves "kidnapping, rape and forced marriage of minor girls, some as young as twelve years, by men who are at times old enough to be their grandfathers" (SADC Secretariat, 2016: 43). However, as noted by Bello and Olutola (2018), such cultural and traditional practices impede the anti-human trafficking efforts in South Africa. Similarly, traffickers reportedly force male victims to marry South African women in order to regularize their citizenship status in South Africa (SADC Secretariat, 2016), with the main objective of continued exploitation of the trafficking victims.
Whilst there is no much documented research pertaining to the phenomenon, organ trafficking is also a challenge in South Africa. Unlike in other countries where organ trafficking is only done in the context of organ transplant (Gonzalez et al., 2020), organ trafficking in South Africa is mainly used for two purposes: making traditional medicine or "muthi", and medical transplant of organs (Roper et al., 2020). On the former, traditional healers request their clients to bring human body parts, which will be mixed with other traditional medicines, and this is mainly done to make wealth or lucky charms.

Push/pull factors
Whilst some of the push/pull factors have been highlighted in the preceding discussion, this section further elaborates on the push/pull factors for human trafficking. It is necessary to point out that the human trafficking factors in South Africa are predominantly pull factors emanating from circumstances which force victims to migrate from other countries to South Africa or from rural areas to urban centers, rendering them vulnerable to exploitation. The problem has been compounded by harsh economic conditions, "characterized by poverty, unemployment and a lack of prospects in the countries of or areas of origin" (SADC Secretariat, 2016: 43;Sambo & Spies, 2020). Because of this economic desperation, victims will be willing to accept dehumanizing offers in South Africa. Given South Africa's status as the economic hub for the Southern African region, victims from other African countries are lured by the perceived job and other economic opportunities in the nation, resulting in them falling prey to human traffickers. Thus, South Africa "provides an enabling environment and market for the services of persons trafficked from other countries" (Bello & Olutola, 2020: 7), who are then exploited in the construction, mining, agriculture and fisheries industries. Also emanating from these push/pull factors is the ability of traffickers and other criminal networks to freely move between South Africa and its neighboring countries (Roper et al., 2020). Porous borders between South Africa and its neighbors such as Zimbabwe, Mozambique and Lesotho, coupled with high corruption levels at border posts, provide entry points for human trafficking victims to enter or leave South Africa (SADC Secretariat, 2016). The demand for organs and body parts, which are not ordinarily available on the official market, is another pull factor (Bello & Olutola, 2020). HIV and/ AIDS has also been identified as a push factor which increases the vulnerability, especially in child-headed households (SADC Secretariat, 2016). Lastly poverty in some of the rural areas in South Africa pushes the victims to urban areas, where they are exploited into sex trafficking and forced labor (US Department of State, 2020).

Human trafficking trends in Zimbabwe
Like South Africa, and perhaps in a worse scenario, Zimbabwe does not have a centralized database for official statistics on human trafficking. Whilst substantial research has been conducted in South Africa, very limited studies on human trafficking have been conducted in Zimbabwe. To this end, this section mainly focuses on this limited research, other policy documents and online media articles on human trafficking in Zimbabwe. Despite the absence of official human trafficking data in Zimbabwe, published literature and documentary evidence has shown that Zimbabwe is largely a source of human trafficking victims (SADC Secretariat, 2016;Zengenene, 2020). Prior research and media reports indicate that Zimbabweans are mainly trafficked to neighboring countries such as South Africa and Botswana; as well as to the Middle East, particularly Kuwait; and Asian countries, particularly China and India (Parliament of Zimbabwe, 2018; SADC Secretariat, 2016). Despite its status as the source "hot spot" (Zengenene, 2020), Zimbabwe is also a transit country for trafficking victims from African countries such as Ethiopia and Somalia to South Africa (SADC Secretariat, 2016; US Department of State, 2020). Zimbabwe also acts as the corridor of human traffickers from countries such as "India, Pakistan, Democratic Republic of Congo, Mozambique and Zambia to South Africa" (Parliament of Zimbabwe, 2018: 5). Though at a lower scale, victims are also trafficked from countries such as China, Ethiopia, Pakistan, Rwanda and Somalia to Zimbabwe, and in most cases the victims are trafficked by their fellow nationals (SADC Secretariat, 2016). As is the case with South Africa, there is also a growing trend of internal trafficking, whereby young unemployed women are trafficked from poor rural communities to urban centers, where they would be exploited (Parliament of Zimbabwe, 2018).
Research and documentary evidence reveal that Zimbabwean women and girls are "mainly trafficked for domestic servitude and sexual exploitation" (Parliament of Zimbabwe, 2018: 5; SADC Secretariat, 2016; US Department of State, 2020; Zengenene, 2020). In the first official report of human trafficking in Zimbabwe, a female Zimbabwean cross-border trader was arrested after recruiting two victims to Angola, where they were exploited for sex work (SADC Secretariat, 2016). The United States' 2020 Trafficking in Persons Report notes that perpetrators "exploit women and girls from Zimbabwean towns bordering South Africa, Mozambique and Zambia into sex trafficking in brothels", with some of the victims forced to provide sex services "to long-distance truck drivers on both sides of the border" (US Department of State, 2020: 538). In one incident that points to the vulnerability of Zimbabwean women and girls who are trafficked to foreign land, South African police reportedly identified "30 Zimbabwean women in brothels in Mpumalanga province as potential victims of sex trafficking" (US Department of State, 2020: 438). The emergence of sex tourism has also led to continued exploitation of women and girls, as young unemployed girls are reportedly recruited from rural areas to resort towns such as Victoria Falls, where they are forced to engage in prostitution (Parliament of Zimbabwe, 2018). Similarly, Somali and DRC refugees who are camped at Zimbabwe's Tongogara Refugee Camp "reportedly travel to Harare, where traffickers exploit them, and in some cases, coerce them into prostitution" (US Department of State, 2020: 537).
Labor trafficking is also another dominant form of trafficking for Zimbabweans who are exploited outside Zimbabwe (Parliament of Zimbabwe, 2018; SADC Secretariat, 2016; US Department of State, 2020; Zengenene, 2020), though in most of the cases, the phenomenon is linked with sexual exploitation. In the second officially recognized case of human trafficking in Zimbabwe, a female Zimbabwean recruitment agent was charged with human trafficking after attempting to recruit 22 women to work as domestic workers in Saudi Arabia (SADC Secretariat, 2016). Perhaps the most prominent case relating to both labor enslavement and sexual exploitation relates to a case involving the smuggling of would-be house maids to Kuwait. In 2016, state and independent media in Zimbabwe was awash with news pertaining to repatriation of human trafficking victims from Kuwait, where they were exploited through domestic servitude and sexual exploitation (Machakaire, 2016;Razembe, 2016). In a related incident, an accused person who was working in cahoots with a Kuwait Embassy official allegedly recruited 32 desperate female job seekers, who were later turned into slaves and prostitutes when they arrived in Kuwait (Machivenyika, 2017: 1). By the year 2017, over 200 victims had been trafficked from Zimbabwe to Kuwait and Saudi Arabia, "where they were forced to engage in prostitution and labor enslavement" (Machivenyika, 2017: 1). In 2020, the government of Zimbabwe exposed a human trafficking ring of individuals domiciled in Canada and were working with locals, "who were luring Zimbabweans to apply for non-existent jobs in North America and other parts of the world", and the victims were lured through various social media platforms (Madzimure, 2020: 1). Whilst women and girls are the most vulnerable in Zimbabwe, man and boys are also vulnerable, with some of the victims forced to engage in activities such as stealing, begging, or used as domestic slaves (Parliament of Zimbabwe, 2018). Both male and female victims are also forced into "exploitative labor situations in agriculture, construction and hospitality" industries in neighboring countries (US Department of State, 2020: 538), predominantly South Africa and Botswana. There have also been reports that traffickers lure prospective students from Zimbabwe to Cyprus and other countries "with false promises for education" through scholarships, "where they are exploited in forced labor and sex trafficking" (SADC Secretariat, 2016: 53; US Department of State, 2020).
As is the case with South Africa, there are cultural practices in Zimbabwe which abet human trafficking. For example, the cultural practice of "kuripa ngozi" (A native Shona term meaning to appease avenging spirits), which entails "giving a family member to another family to avenge the spirits of a murdered relative, creates a vulnerability to trafficking" (US Department of State, 2020: 538). In this case, young girls are pledged by the family of the person who would have committed the murder and they are married off to a member of the family of the murdered person. Such a cultural practice can be equated to "ukuthwala" in South Africa, as in both cases, young girls are forced into marriage, albeit in different circumstances.

Push/pull factors for human trafficking
The predominant push factors for human trafficking in Zimbabwe are poverty and unemployment (Parliament of Zimbabwe, 2018;SADC Secretariat, 2016). A study by Zengenene (2020) on trafficking of women and girls also revealed that socio-economic and political ills such as high unemployment levels, shortage of essential goods, high corruption levels and gender inequality have escalated the susceptibility of women to traffickers in Zimbabwe. The political and economic challenges experienced by Zimbabwe at the turn of the millennium have been largely credited as push factors, as Zimbabwean migrate to other countries in search of greener pastures, where they are vulnerable to exploitation by the traffickers (SADC Secretariat, 2016). Situations of vulnerability eventually arise when the Zimbabweans are enroute or are in host countries, where they are exposed to abuse and exploitation by opportunists. Secondary schools, as well as tertiary institutions, are also churning out thousands of graduands on a yearly basis, but in the absence of employment opportunities in Zimbabwe, they become susceptible to traffickers in foreign lands (Parliament of Zimbabwe, 2018). Consequently, they easily fall prey to false promises for employment and education by the traffickers. HIV and AIDS is also a push factor for trafficking of Zimbabweans in and outside Zimbabwe, as it has left multitudes of children orphaned and vulnerable.

Control of human trafficking
The starting point for the control of trafficking in persons within the two nations is the ratification of the Palermo Protocol by the two nations, which paved the way for the enactment of relevant legislation by the two countries. In 2009, SADC member states emphasized their commitment towards combating human trafficking by adopting the SADC Strategic Plan of Action on Combating Trafficking in Persons (2000)(2001)(2002)(2003)(2004)(2005)(2006)(2007)(2008)(2009)(2010)(2011)(2012)(2013)(2014)(2015)(2016)(2017)(2018)(2019) in Kinshasa, Democratic Republic of Congo. Being SADC member states, South Africa and Zimbabwe were bound by this strategic plan, which aimed for coordinated efforts towards fighting human trafficking. Notwithstanding the lapse of the strategic plan in 2019, human trafficking seems to be on an upward trend, especially due to the push factors that have been highlighted. The proceeding sections look at the regulatory framework and the manner in which the two nations are dealing with the scourge. Loopholes within the regulatory frameworks, as well as the obstacles to the fight against human trafficking, are also highlighted.

Human trafficking control in South Africa
In South Africa, the main statute governing the control of human trafficking is the "Prevention and Combating of Trafficking in Persons Act (7 of 2013)" (PACOTIP Act) and the Act criminalizes "all forms of trafficking, including labor trafficking" (Roper et al., 2020: 3). The PACOTIP Act "criminalizes sex trafficking and labor trafficking, prescribing penalties of up to life imprisonment, a fine up to R100 million or both" (US Department of State, 2020: 453). To provide policy direction, South Africa's National Policy Framework (NPF) on the management of Trafficking in Persons Offences was launched in 2019. The policy framework offers a multifaceted and coordinated "response on trafficking in persons, prosecution, protection and prevention" in South Africa, and aims to rationalize resource use and effective response to trafficking in persons (Roper et al., 2020: 3). Despite its seemingly sound legislative framework, the legal definition of human trafficking, particularly the definition of the term "exploitation" has proven to be imprecise (Roper et al., 2020). To this end, key players in the fight against the scourge lack a robust understanding of the concept (Bello & Olutola, 2018). There is absence of clarity on what human trafficking is and human trafficking cases are usually subsumed under a range of other crimes that include rape, kidnapping, abduction and labor disputes (Dempsey, 2017;Van der Watt, 2020;Roper et al., 2020). The 2019 United States human trafficking report notes that a poor understanding of human trafficking continues to hinder South Africa's counter-human trafficking efforts (US Department of State, 2019). Therefore, there is need for clarity on the legal definition of human trafficking, which can be achieved by making necessary amendments to the PACOTIP Act.
On the operational front, South Africa seems to be on the right track in the fight against human trafficking, a fact which is also acknowledged in the United States 2020 human trafficking report. South Africa has "a vibrant civic society and non-governmental community that is engaged in counter-human trafficking work" (Roper et al., 2020: 3). During the year 2020, there were increased efforts by the South African authorities in the investigations, prosecutions and convictions of human trafficking perpetrators, with an increase in the training of human trafficking frontline responders (US Department of State, 2020). There were 2,132 human trafficking cases that were registered on the South African Police Service's Crime Administration System between 9 August 2015 and 12 December 2017, though only 47 of the cases were successful human trafficking prosecutions (Roper et al., 2020). The Directorate of Priority Crime Investigation -an elite crime fighting department popularly known as "The Hawks" -reportedly investigated 24 potential trafficking cases in 2020 (US Department of State, 2020).
Despite making significant efforts in dealing with human trafficking, the United States Trafficking in Persons Report notes that "South Africa does not fully meet the minimum standards for the elimination of human trafficking" (US Department of State, 2020: 453). This may be attributed to a number of factors, chief among them being the already discussed loopholes in the legal framework. The absence of reliable statistics on human trafficking prevalence is also a challenge (Bello & Olutola, 2018;Roper et al., 2020;Van der Watt, 2018), as for any intervention measures to be successful, they should be premised on full and accurate statistics. The lack of clarity on the definition has also resulted in countless cases not being identified or documented, with some of the cases "being subsumed under cases such as kidnapping, domestic violence, abduction and labor disputes" (Van der Watt, 2018: 8). Moreover, cultural practices such as "ukuthwala" impede the efforts to deal with human trafficking, as what amounts to trafficking may be considered by some communities as normal traditional practices.

Human trafficking control in Zimbabwe
The Trafficking in Persons Act [Chapter 9: 25] of 2014 (TIP Act) is the main act that deals with human trafficking in Zimbabwe. Before the TIP Act was promulgated, temporary measures -the Presidential Powers (Temporary Measures) (Trafficking in Persons Act) of 2014, had been promulgated for the purpose of prosecuting human trafficking cases and they were operational for six months (SADC Secretariat, 2016). Among the key provisions of the TIP Act are: establishment of the crime of trafficking in persons; powers of law enforcement officials; protection and compensation of victims; establishment of anti-trafficking inter-ministerial committee; and forfeiture of trafficking proceeds and property. In 2019, the government of Zimbabwe adopted a national action plan for combating human trafficking, with nationwide awareness campaigns being conducted. Whilst the promulgation of the TIP Act may be viewed as a positive milestone, the Act does not adequately define the crime of human trafficking, a challenge that is also present in South Africa's PACOTIP Act. Specifically, the TIP Act does not adequately define "exploitation" (US Department of State, 2020), leaving the term to numerous interpretations, at worst excluding some of the activities that are associated with human trafficking. Another loophole that is noted by the United States Trafficking in Person Report is the TIP Act's definition of human trafficking as a movement-based crime, thus focusing on the transportation of victims (US Department of State, 2020), yet victims can travel on their own, only to be exploited upon reaching their destinations.
During 2019 and 2020, Zimbabwe demonstrated increasing efforts in investigating and prosecuting human trafficking offenders, coupled with heightened training of judicial officers and law enforcement officers (US Department of State, 2020). Whilst statistics on human trafficking in Zimbabwe are difficult to get or they could be non-existent, there are some positive developments as reported in online media platforms and other documents. In a positive development, one of the kingpins in the Kuwait human trafficking saga was convicted on five counts for human trafficking, and was sentenced to 50 years imprisonment (Chingarande, 2019), a sentence which can be considered as deterrent enough. In 2018, a human trafficker from Harare received a 20-year jail term "for facilitating the trafficking of five Zimbabwean women to Kuwait, where they were turned into slaves or sex work" (All Africa, 2020: 1). During 2019 and 2020, Zimbabwean authorities identified 52 human trafficking victims who needed assistance and the victims were referred to international organizations for reintegration and support (US Department of State, 2020). The Thematic Committee on Human Rights in the Parliament of Zimbabwe has also set up a subcommittee on human trafficking and modern day slavery, which oftentimes conducts inquiries on human trafficking in Zimbabwe and beyond (Parliament of Zimbabwe, 2018).
Other than the definitional deficit and the absence of statistics on human trafficking, Zimbabwe also faces other hurdles in its anti-human trafficking efforts. A Report by the Parliament of Zimbabwe's Thematic Committee on Human Rights on human trafficking and modern day slavery noted the shortage of resources in the form of personnel and equipment as a key factor hindering the implementation of the anti-human trafficking laws (Parliament of Zimbabwe, 2018). Protection of victims and their re-integration are resource-intensive activities which may be difficult to implement given Zimbabwe's socio-economic challenges. Importantly, the persistent socio-economic and political challenges that have characterized Zimbabwe for more than two decades persistently add to the push factors to human trafficking, creating a vicious cycle of perpetuation of human trafficking and fighting human trafficking. Lastly, despite making significant progress, "Zimbabwe does not fully meet the minimum standards for the elimination of human trafficking" (US Department of State, 2020).

Conclusion
This paper reveals that the problem of human trafficking is persistent in South Africa and Zimbabwe. Human trafficking in South Africa is largely as a result of pull factors, largely attributable to perceived presence of job opportunities, market for cheap labor in the agricultural, mining and fisheries industries. Victims mainly migrate from other Southern African countries, predominantly Zimbabwe, to South Africa, where they are susceptible to labor and sex exploitation. Zimbabwe is largely characterized by push factors, with the harsh economic environment pushing Zimbabweans to countries like South Africa, Botswana, Kuwait and Saudi Arabia, where they fall victims to traffickers. In both countries, internal trafficking of victims from poor rural areas to urban centers is also rife, with the trend attributed to factors such as poverty and HIV and AIDS. The paper also reveals that women and girls are more susceptible to human trafficking and they are prone to sexual exploitation and domestic servitude. Cultural practices, specifically "ukuthwala" in South Africa and "kuripa ngozi" in Zimbabwe, are also perpetuating human trafficking in the two countries and such practices are also impeding the efforts to curb human trafficking.
The two nations have made significant efforts fighting human trafficking, as evidenced by increased prosecution and conviction of perpetrators of human trafficking, although South Africa seems to be leading in this regard. These efforts are underpinned by anti-human trafficking legislation within the two countries -PACOTIP Act in South Africa and TIP Act in Zimbabwe. Notwithstanding these positive developments, lack of clarity in the definition of the terms "human trafficking" and "exploitation" within the two statutes militate against the efforts to deal with the scourge. This calls for the urgent need to amend the existing anti-human trafficking laws within the two nations, with the objective for clear definitions which meet international standards. The current macro-economic challenges in Zimbabwe have made the enforcement of anti-human trafficking laws difficult, especially in terms of resources for the protection and re-integration of victims. There is also need to invest more in the training of law enforcement officials and frontline workers who deal with human trafficking, which, however, may be easier for South Africa given its economic status, but difficult for Zimbabwe under the current macro-economic challenges. The absence of accurate statistics on the prevalence of human trafficking in both countries also impedes the efforts to curb the crime. There is need for centralized databases on human trafficking and related offences so that all prescriptive measures are taken from an informed position.