"People know [prostitution] is legal, but the subliminal message given all the time is: it's dirty, it's exploitation."

In 2003 New Zealand chose to decriminalise prostitution, but in Europe another model is increasingly favoured.

The secret diary of Bella, a call girl working in New Zealand, begins roughly a year ago, in London. She's in her early 20s, attractive, university-educated, working full-time in an ordinary day job. Her family is liberal, and sex isn't a taboo topic, but they are unaware sex work is on Bella's radar. Just as a sideline. The appeal is the money and the sexual thrill. She has absolutely no moral quandaries about prostitution.

Bella has friends who are sex workers, and through them hears stories of confrontations with police, brothel raids, workers too afraid of legal repercussions to report attacks. The UK's legal system is unkind to prostitutes. It's that fact, rather than the work itself, that makes the job off-limits.



"It had always crossed my mind, the industry, but I wouldn't do it," the 23-year-old says. "It was too dangerous, as far as I was concerned."

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Then, a twist: Bella's day job requires her to move to New Zealand, and suddenly sex work becomes a realistic prospect. Bella researches the laws here and is impressed: If a client attacks her, she can file a police report. If she doesn't want to have sex with a client, she can say no, regardless of whether he's paid. "It just seemed like New Zealand had got it right," says Bella.

She is unsettled by the first agency she approaches: "The first thing he showed me when I walked in was a baseball bat behind the counter and was like, 'Don't worry, you'll always be safe here, ha ha.' I was like, what the f*** have I just walked into? The only questions he asked me were, 'How flexible are you?' and 'When can you start?' They didn't even ask me if I liked sex, if I had a drug habit, why I was there."

So she contacts another agency, one she saw on a documentary back home some years ago. Named Bon Ton, the brothel is run by women who charge higher rates than most outfits and screen every client. Bella starts working for them a short time later.

On a recent sunny Saturday afternoon, Bella lounges on a couch in the tiled office of Bon Ton founder Jennifer Souness. The two sip rosé. A large mood board with pinned images and buzzwords takes up one wall. Souness sits on a chair beside Bella, holding a book in her lap: Feminism Unfinished.

Bella knows sex work is risky. When she goes on call-outs to hotels, she gets a bit scared – "What if I meet the guy downstairs, go up and there's six guys there?" But Bella knows her rights, trusts her madam, and enjoys her work.

Smart, empowered, a feminist – Bella is the kind of worker that is thought to make up most of New Zealand's 3500 prostitute workforce. "I earn good money in my daytime job. I don't need to do this; I choose to do this," she says with confidence. "I think that's what scares people. They're like – 'You want to have sex with old men? Why would you possibly want to do that? You must be being forced.' No! I willingly want to f*** these men."

If you're to believe Bella, New Zealand is the best place in the world to be a prostitute. Many share her opinion – there are activists, researchers and workers who think our system, which gives prostitutes the same legal rights as any other worker, is the most effective at protecting women and regulating the industry.

They include Catherine Healy, national coordinator of the New Zealand Prostitutes Collective, who lobbied for decriminalisation. "I know that our system has been rigorously researched, not only domestic research but international research, too," she says. "Sex workers tell us that things are working really well."

No one's saying there aren't problems – there are stories of dodgy brothel owners, of underage workers, of drug and alcohol dependence among prostitutes. All these issues warrant serious attention, but by and large, says Healy, the system works.

Yet, around the world, a rather different system is gaining traction. Alternately called the 'Swedish model' or the 'Nordic model', it was first adopted in Sweden in 1999, and shifts the criminality from sex workers to their patrons, making it legal to work as a prostitute, but illegal to pay for sex with one.

"Sweden believes that prostitution is fundamentally degrading and dehumanising to women," says Michelle Goldberg, an American journalist who received a grant in 2014 to research the Nordic system. "Sweden is very upfront that gender equality is a goal of Swedish society, and that prostitution is incompatible with gender equality, and it's something they don't want to condone – even if it means curbing certain people's individual freedoms." The law is Sweden's way of saying prostitution is bad, but it won't criminalise sex workers.

The Nordic system is supported by the European Women's Lobby, an umbrella group of feminist organisations, and in February 2014, the European Parliament passed a resolution urging member countries to consider Swedish-style laws. The model has been adopted by Norway, Iceland, Canada and, last year, Northern Ireland, with other countries looking at it to inform their own laws.

The ultimate effect is the opposite to what we have created in New Zealand. While the Nordic system's goal is to stamp out prostitution, ours is to decriminalise and destigmatise it, to bring it out of sleazy, dangerous corners and into the regulated light of society. But if our system is as world-leading as its advocates would suggest, why is the rest of the world moving in the opposite direction?

***

Joep Rottier is a researcher from the Netherlands' Utrecht University, and knows quite a bit about prostitution legislation. Rottier has studied the laws of his home country (where sex work is legal), Sweden, and now he's in New Zealand, researching our system. He's afraid the approach Europe is taking to the sex industry is horribly wrong.

"I think the Nordic model isn't a realistic model," says Rottier. "The Swedish government tries to show that the number of clients has decreased." Indeed, since the law change, Sweden boasts that demand has dropped, the number of prostitutes is down, and those still working are paid more.

"What they don't mention is that it has decreased the visible sex industry. It isn't visible on the street, but underground it continues. It's a very negative feature of criminalisation of the clients – workers, escorts, go underground, and it makes them very vulnerable for exploitation. Comparing this with New Zealand, the illegal circuit isn't so big. It isn't necessary to go underground because it isn't criminalised," says Rottier.

Then why is their system so popular? Part of the reason is that supporters of the Nordic model conflate prostitution with human trafficking, says Dr Ivana Radacic, a senior research associate from Croatia's Institut Ivo Pilar. Like Rottier, she is in New Zealand at present, studying our legislation. Her home country is currently considering adopting a system similar to Sweden.

Human trafficking is a huge problem in Europe, and a concern about legalising prostitution is that it will increase trafficking. A 2012 study on the subject, published in World Development, concluded: "We find that countries with legalized prostitution have a statistically significantly larger reported incidence of human trafficking inflows." But Rottier question the validity of the figures often touted.

And anyway, says Rottier, the issues are not one and the same – trafficking happens in all sorts of industries, not just prostitution. By lumping the two together, you perpetuate an idea that every prostitute is working against their will.

"You have to maintain a difference between voluntary sex work and trafficking," says Radacic. "There are ways to address exploitative work conditions without criminalising the industry. And even if you take the position 'Prostitution is bad', women need to be protected – how are you protecting them by criminalising what they do?"

***

It's been suggested that New Zealand's geographic isolation is the reason our model works – human trafficking isn't so prevalent here, because it's hard to sneak people across our borders. (Although there have been several reported cases since the law change.) Further, New Zealand law makes it illegal for migrant workers to work as prostitutes – a condition some say is discriminatory, but others believe prevents an influx of foreign women who could be exploited.

With all the fear and panic whipped up in Europe's discussion of prostitution laws, the voice of the prostitute has been lost in the hubbub, says Radacic. "There has been no effort to try to engage sex workers in the discussion on policy models," she says. Among the foremost critics of the Nordic model are sex workers themselves, who complain the law treats them as victims when they don't identify as such.

Bella wouldn't work under the Nordic system because it plays into the narrative that prostitution is immoral, which only stigmatises workers further. "You're still giving people the idea that what these girls are doing is bad. Prostitutes get attacked by men because they're seen as just property – 'The whole thing's dangerous and illegal and you're worth nothing.'"

Bella and Souness are still sipping rosé. The two contemplate whether our law changes have decreased the stigma attached to prostitution here, if sex work will ever be considered a normal job.

"People know it's legal but the subliminal message given all the time is: it's dirty, it's exploitation," says Souness.

Bella thinks attitudes are far better here than in the UK. Her friends in the sex industry back home can't fathom working in the system she does. "They're mesmerised. Every day they wake up scared to do their job. Whereas, I finish my other job, come to Bon Ton and I'm not scared. I'm happy, excited to go to work."

THE UK VIEW

Sex worker Bella believes the UK's prostitution laws are not fair to workers, and she's not alone.

In the documentary Prostitution: What's the harm?, British journalist and it-girl Billie JD Porter delves into the UK's sex industry, interviewing workers, clients, activists and policemen. Porter says she finds the laws around prostitution surprisingly complex. "New Zealanders will probably watch it and realise how lucky they are."

The take-home message is that legalising and regulating brothels would make the UK industry safer for all involved – though Porter doesn't think that will happen any time soon. "I don't think our current prime minister would make any changes to support the underdogs," she says.

Prostitution: What's the Harm? screens on BBC Knowledge tonight at 8.30pm.