Greater Sudbury Police Service

Greater Sudbury Police Service 1 1 9 0 B r a d y S t. S u d b u r y, O n t a r i o P 3 E 1 C 7

Table of Contents Acknowledgements... 3 Executive Summary... 4 Introduction... 6 Sex Work versus Human Trafficking... 9 Sexual Exploitation... 10 Why do victims not come forward?... 10 Canada's Criminal Law Responses... 11 Putting the Strategy Into Action... 12 Counter Sexual Exploitation Team Organization... 13 Counter Sexual Exploitation Team (CSET) Mandate... 14 The GSPS Counter Sexual Exploitation Strategy s 4 pillars are:... 14 Prevention, Protection, Enforcement and Partnerships... 15 Prevention... 15 Protection... 15 Enforcement... 15 Partnerships... 16 Our Shared Commitment Model to Community Safety and Well-Being and the Four Pillars... 17 1. Intervene Collaboratively to Reduce Elevated Risk Situations (Prevention)... 18 2. Champion Community Safety, Security and Wellness (Protection)... 18 3. Enforce Laws and Hold Offenders Accountable (Enforcement)... 18 4. Initiate and Partner to Achieve Positive Change in Community Outcomes (Partnerships)... 19 Business Plan... 19 Strategic Theme... Error! Bookmark not defined. Goals... Error! Bookmark not defined. Objectives... Error! Bookmark not defined. Performance Indicators... Error! Bookmark not defined. Ongoing Initiatives... Error! Bookmark not defined. Measurements/Outcomes... Error! Bookmark not defined. Conclusion The Way Ahead... 20 2

Acknowledgements The Greater Sudbury Police Service would like to acknowledge that our Counter Sexual Exploitation Strategy began with guidance from the Royal Canadian Mounted Police D Division Manitoba and the Winnipeg Police Service Counter Exploitation Unit. Since the initial inception many experienced and dedicated investigators from the Greater Sudbury Police Service have made contributions to the foundation of the Counter Sexual Exploitation Strategy. The Greater Sudbury Police Service engaged community partners such as Sudbury and Area Victim Services for victim focused expertise as we recognized the need to take a humanistic/respectful approach when interacting with vulnerable and/or marginalized persons within the City of Greater Sudbury. 3

Executive Summary The Greater Sudbury Police Service s (GSPS) Counter Sexual Exploitation Strategy (CSES) has been established to provide direction to members and Community Partners when supporting Sex Workers and Victims of Sexual Exploitation and Human Trafficking. The underlying goal of the CSES is to enhance Community Safety and Well-being for all citizens of Greater Sudbury by treating all vulnerable and/or marginalized persons with dignity and respect, while reducing or eliminating victimization. The CSES addresses three identified groups of at-risk persons; namely, Sex Workers, Sexually Exploited persons and persons who are victimized through Human Trafficking. The strategy seeks to coordinate actions to strengthen the reach and effectiveness of services provided to victims and potential victims of sexual exploitation including human trafficking. The aim of the Counter Sexual Exploitation Strategy is to support and empower at-risk, vulnerable and marginalized people (potential victims) and victims of sexual exploitation to minimize risk and reduce victimization thereby enhancing Community Safety and Wellbeing. To accomplish our aim the GSPS and Community Partners need to establish trust with our most marginalized, vulnerable and at-risk citizens. Through a trusting victim focused approach the Greater Sudbury Police Service will engage and mobilize the community creating partnerships in order to work collaboratively creating support networks, harm reduction programs, education/awareness campaigns and prevention models that are responsive to the needs of all persons engaged in sex work and victims or potential victims of sexual exploitation. Through strong sustainable partnerships and collaboration, the CSES will facilitate and promote open dialogue that will reduce vulnerability and build a safer and fully inclusive community for everyone. Vulnerability and victimization will be further reduced through collaborative Prevention Strategies, Education and Awareness Campaigns. The GSPS will be responsible for developing Enforcement Initiatives designed to rescue victims, disrupt predators and hold offenders accountable for sexually exploiting our at-risk individuals. To best support victims or potential victims, and reduce victimization, the Counter Sexual Exploitation Strategy is created around four integrated components of Prevention, Protection, Enforcement and Partnership with clearly established goals and objectives. 4

Prevention through Education and Awareness is the key to combatting sexual exploitation and domestic sex trafficking. It is sometimes difficult to identify victims of domestic sex trafficking and sexual exploitation. This challenge is not just for members of the public and law enforcement, but also for victims who may not understand that they are the victims of a crime. Police, citizens, community support groups, school boards and justice partners play a significant role in bringing awareness to the forefront. The Greater Sudbury Police Service has reframed our approach to Sex Work and has renewed internal organizational structures to best combat Sexual Exploitation and Domestic Sex Trafficking. The GSPS and Community Partners are committed to support victims as well as vulnerable and/or marginalized persons through outreach, supports and services (including exit strategies). Through information collection and intelligence led policing strategies GSPS officers will hold accountable those who seek to exploit the vulnerable in our community. 5

Introduction Sex work or prostitution had been criminalized legislatively until 2014 when a Charter challenge resulted in the passing of Bill C-36 making the selling of sexual services legal. Even though Canadian Law has changed, public perception towards sex work and the people who engage in it has not changed. The negative stigma attached to sex work has an impact on their human rights and they are forced to conduct their business underground putting them at greater risk. Besides the change in criminal law, police and community partners must also change their philosophy and approach towards sex workers. The CSES contains consistent guidelines that seek to remove traditional stigmas and re-establish dignity and human rights for Sex Workers. Safety, Protection and Support for all community members is the priority of the CSES; enforcement will not be the first option when responding to sex work complaints from the public unless the sex worker or community member has been victimized. Any interaction with a sex worker needs to be professional and respectful. Sex workers must be treated with dignity, sex workers need to trust the police and the community to enhance their personal safety. To best enhance community safety in neighborhoods in which sex work occurs, residents and business owners must take an inclusive approach and collaborate with sex workers to collectively determine viable solutions to achieve community safety and wellbeing. Legislation on Human Trafficking is relatively new, and these types of investigations can be extremely complex due to the fact the offenders will use force, threats, coercion, deception, isolation and fraud to violate their victims human rights. Many victims may not even know they are being sexually exploited and violations can involve single or multiple persons and can occur almost anywhere. Globally, it is estimated that human trafficking is amongst the most lucrative of criminal activities, rivaled only by drug and firearms trafficking and generating billions of dollars annually for sophisticated criminal organizations. At any given time, it is believed that worldwide over 2 million people are forced to perform degrading, dehumanizing work that places them at risk. At the same time, it is estimated that the numbers continue to increase. It is not known whether this increase is due to improved efforts to investigate, detect and report this crime or whether it is due to an actual increase in the incidence of the crime worldwide. Human Trafficking is taking place in Canada and in 6

Sudbury, with domestic sex trafficking for the purpose of sexual exploitation being the most common manifestation of this crime, where men, women and children are being victimized; however, women represent the majority of victims locally and across Canada. More generally, marginalized sectors of our community are at greater risk, this includes persons who are socially or economically disadvantaged, such as: some Indigenous women, LGBTQ2+, youth and children, migrants and new immigrants, teenaged runaways, children who are in care protection and girls and women who may be lured to large urban centers. The GSPS Counter Sexual Exploitation Strategy incorporates Prevention, Protection, Enforcement and Partnership as the key four pillars outlined in the Government of Canada s National Action Plan to Combat Human Trafficking in 2012. The Strategy utilizes the GSPS Our Shared Commitment Model as the framework to ensure the needs of our community are addressed. This Strategy highlights the importance of victim focused initiatives and supports to empower those who have been exploited or have the potential to be exploited. The Counter Sexual Exploitation Strategy will form the foundation of future operational plans as they relate to empowering and supporting victims while holding perpetrators accountable for their actions. 7

Sex Work versus Human Trafficking The tendency to blend sexual exploitation, human (domestic sex) trafficking and sex work as if they were the same thing is problematic. Legislation and social discussions have often blurred or denied any difference but that has always made things worse for those involved. Sex Work: Sex Workers include men and women who offer sexual services in exchange for money. Sex work must be consensual between the person offering the service and the person paying for the service, when consent changes or is absent a crime has been committed. Persons who participate in sex work do so by choice and the individual controls the experience and activities they engage in. The CSES recognizes that although sex work can be a high risk lifestyle choice, where sex work is consensual, the focus of the Greater Sudbury Police Service is harm reduction. Sex work that is not consensual is a crime and will be an enforcement priority. The Strategy will provide a consistent, professional and respectful approach to those who interact with Sex Workers whether they have been victimized or are the subject of public complaints. The CSES views sex work as a defined choice an individual makes for themselves. The priority of the CSES as it pertains specifically to Sex Workers is to ensure outreach is being conducted on a consistent basis by people who are in the best position to offer timely and needed supports and services. Sexual Exploitation and Human Trafficking: Human Trafficking and/or Domestic Sex Trafficking are criminal offences that involve recruiting, transporting, transferring, receiving, holding, concealing or harbouring a person, or exercising control, direction or influence over the movements of a person, for the purpose of exploiting them or facilitating their exploitation. Human Trafficking is a complex and often hidden crime that violates a person s human rights which results in serious and long-term trauma for survivors. Human traffickers prey on the most vulnerable in our society and use different tactics to control, abuse, exploit and profit from victims. Sexual Exploitation, Domestic Sex Trafficking and Sex Work disproportionally involve women and girls including those from already marginalized groups. Poverty, lack of education, child 8

abuse, mental health and addiction are all vulnerabilities that contribute to a person s decision to participate in the sex industry or become victimized through sexual exploitation. Sexual Exploitation is defined in the Criminal Code of Canada as the sexual abuse of children and youth through the exchange of sex or sexual acts for drugs, food, shelter, protection, other basics of life, and/or money. Sexual exploitation includes involving children and youth in creating pornography and sexually explicit websites. Sexual Exploitation for the purpose of the Counter Sexual Exploitation Strategy is the act of exploiting an individual or group for a sexual purpose. Human Trafficking or Domestic Sex Trafficking is another form of Sexual Exploitation and is defined as, the recruitment, transportation, harbouring and/or exercising control, direction or influence over the movements of a person in order to exploit that person, typically through sexual exploitation or forced labour. Victimization through any forms of Sexual Exploitation (including Human Trafficking) will be a service and enforcement priority with the GSPS and Community partners. Sex Work and some associated activities such as drug use/trafficking, solicitation, disturbances, unsanitary littering and increased road traffic can have a negative impact within our community. The Strategy seeks to bring Sex Workers and their advocates together with concerned community members to respectfully share safety concerns from both perspectives. After every voice is heard solutions will be created that respect all persons rights and freedoms while also enhancing Community Safety and Well-being. ACT - Recruitment - Transportation - Transfer - Harbouring BY MEANS OF MEANS - Threat or use of force - Coercion - Abduction - Fraud - Deception - Abuse of Power - Abuse of a position of vulnerability - Giving or receiving payments or benefits to acheive the consent of a person - Having control over another prerson FOR THE PURPOSE OF EXPLOITATION - Forced labour or services - Servitude - Removal of organs - Slavery or similar practices - Prostitution of others or other forms of sexual exploitation 9

Why do victims not come forward? Victims may: Not understand that they are victims of sexual exploitation or human trafficking Fear for their own lives Be taught to distrust outsiders, especially law enforcement and other government authorities Foreign victims may be afraid they will be detained and deported, or they may have limited language skills Be completely unaware of their rights or may have been intentionally misinformed about their rights in Canada Fear for their families and/or loved ones Feel threatened that traffickers will harm their families if they report their situation to, or cooperate with, law enforcement. A set of interrelated factors contribute to sexual exploitation victimization. Factors include different forms of vulnerability including poverty, living in unsafe situations, unemployment, and lack of education, inadequate social programs and gender-based inequality. Victims may be drawn into human trafficking through the promise of a better life having more money and a greater sense of self-worth, security and wellbeing. For traffickers, human trafficking is often characterized as a "low risk/high reward activity" because of the fact that the crime is clandestine, therefore difficult to detect and investigate, which contributes to the relatively low prosecution rates worldwide. Victims can be exploited over and over for the financial or material benefit of the traffickers making this crime lucrative. The United Nations (UN) has estimated that this illegal activity generates approximately $32 billion (US) annually for its perpetrators. 10

Canada's Criminal Law Responses Bill C-36, the Protection of Communities and Exploited Persons Act became in force as of December 6, 2014. The Bill brought about changes to Canadian criminal law where the overall objectives are to: protect those who sell their own sexual services; protect communities, and especially children, from the harms caused by prostitution; and reduce the demand for prostitution and its incidence. 1 Also in 2014 other modifications were made to the Criminal Code of Canada under the heading of Commodification of Sexual Activity, namely sections 286.1 (Obtaining sexual services for consideration), 286.2 (Material benefit from sexual services), 286.3 (Procuring), 286.4 (Advertising sexual services), and 286.5 (Immunity Material benefit and advertising). Section 286.5 provides immunity for sex workers who advertise and obtain material benefit from their own sexual services. The Criminal Code of Canada contains tools to hold human traffickers accountable and includes four specific indictable offences to address human trafficking, namely sections 279.01 (Trafficking in persons), 279.011 (Trafficking of a person under the age of eighteen years), 279.02 (Material benefit), and 279.03 (Withholding or destroying documents). Many other Criminal Code offences can also apply to human trafficking cases including kidnapping, forcible confinement, uttering threats, extortion, assault, sexual assault, prostitution-related offences and criminal organization offences. Section 118 of the Immigration and Refugee Protection Act (IRPA) contains a provision that prohibits the bringing into Canada of persons by means of abduction, fraud, deception or use of threat of force or coercion. It carries a maximum penalty of a fine of up to $1 million and/or up to life imprisonment. The Criminal Code also contains measures designed to make testifying less traumatic for victims and other vulnerable witnesses. Testimonial aids, such as a screen that prevents the witness from seeing the accused, the use of closed-circuit television that permits the witness to testify from outside the courtroom or the presence of support persons may be made available in appropriate circumstances. Other measures that may be available are publication bans on information that would identify a complainant or witness and, in some cases, orders excluding the public from the courtroom. 11

. Putting the Strategy into Action.. The Criminal Investigations Divisional Commander will maintain overall responsibility for the implementation of the CSES with every GSPS member having a critical role to play. Through efforts to have a greater impact on curtailing sexual exploitation in our community, the Greater Sudbury Police Service, through the Integrated Crime Team (Counter Sexual Exploitation Team-CSET), will work with the community in addressing all forms of sexual exploitation and sex industry related concerns. Members of the CSET will consult and support all community members, respecting individual human rights, with the common goal of reducing/eliminating victimization and enhancing Community Safety and Well-being. To measure both effectiveness and efficiency, the CSET will work in collaboration with the other operational and analytical branches of the Greater Sudbury Police Service. These roles include but are not limited to, (1) fostering community collaboration and partnerships to combat sexual exploitation; (2) better utilizing frontline investigators, providing a victim centered approach, encouraging the submission of intelligence reports, providing referral services to victims and engaging in focused directed patrols; (3) having the Community Response Unit (CRU) and the Rural CRU Unit undertake prevention strategies focused on enhancing awareness and education at Community Action Network meetings, along with assisting in conflict management with high complaint areas. In addition, both CRU and Rural CRU can provide oversight to community members specific to the concept of Crime Prevention Through Environmental Design Analysis ; (4) working with Criminal Investigations Division investigators involved in the collection and analysis of information obtained through investigations and having access to Power Case Software and the Major Case Management System. 12

Counter Sexual Exploitation Team Organization Criminal Investigations Division Inspector Integrated Crime Team Staff Sergeant Criminal Intelligence Analyst Community Response Unit Officers Patrol Operations Officers Intelligence Unit Sergeant Sex Exploitation Power Case Clerk Integrated Crime Team DRUG Unit Intelligence-Gang/Vice Investigator Integrated Crime Team BEAR Unit Sudbury Area Victims Support Criminal Investigations Division Missing Person Investigator The Counter Sexual Exploitation Team is responsible for the following core functions which falls in line with internationally accepted best practices, outlined in the Trafficking Protocol, Canada focuses on four core areas, known as the 4-Pillars (the 4-Ps): The prevention of human trafficking The protection of victims The enforcement of offenders Working in partnership with others both domestically and internationally 13

Counter Sexual Exploitation Team (CSET) Mandate The CSET is an integral part of the GSPS Criminal Investigations Division when combatting all forms of sexual exploitation. The underlying core operating principle of the CSET is the safety and wellbeing of those involved in sex work and the reduction/elimination of victimization among our most vulnerable and marginalized citizens. Where sex work is determined to be consensual, the focus will be safety, harm reduction strategies and support. In situations that involve human trafficking and/or sexual exploitation, the CSET will seek to protect the victims and hold offenders accountable. The complex and sensitive nature of these investigations will be victim first driven where the victims will be treated with respect and dignity. The focus will ensure a victim-centered approach is taken that includes steps to create a victim services network headed by Sudbury and Area Victim Service (SAVS) that is comprehensive and responsive to the needs of all victims to ensure that they are supported throughout their longterm journey as survivors. The Intelligence-Gang/Vice investigator officer is fully committed and dedicated to the guiding principles of the Counter Sexual Exploitation Strategy. Supported by the CSET, the Intelligence- Gang/Vice Investigator will ensure that victims of sexual exploitation are referred and connected to community resources as needed. The CSET, led by the Intelligence-Gang/Vice officer will receive and share any information, which might help identify offenders or other victims pertaining to sexual exploitation, with any and all police partners in Ontario and across Canada. The aim of the CSET is to minimize the risk of marginalized and vulnerable persons of being victimized or from potentially going missing or becoming a victim of foul play. Since community safety is a shared responsibility, the engagement and collaboration the CSET has with community partners is key. The CSET is part of a network of community based resources, social services, health professionals, NGOs, government and law enforcement agencies working together to help people get out of exploitive situations and into safe environments. 14

. The GSPS Counter Sexual Exploitation Strategy s 4 Pillars are: Prevention, Protection, Enforcement and Partnership Prevention Education Awareness is an essential prevention strategy to stop victimization before it occurs. Often, many victims do not know they are exploited or what their rights and options are, education and awareness may uncover and identify victims. Safety and Harm Reduction Strategies should be employed that include exit strategies and supports. Intelligence Gathering sharing information and coordinating efforts to encourage reporting of abuse and exploitation. Putting the pieces of the puzzle together to prevent and solve crime against vulnerable persons. Any amount of information is important. Education and awareness around Sexual Exploitation and Human Trafficking, directed towards high risk or at-risk missing youth and/or vulnerable persons. Protection: Identifying and building a rapport by working directly with individuals at risk of being exploited. Engagement and supporting outreach; providing links to support resources/victim services for the safety and welfare of exploited persons and/or those at risk of being exploited. Working to acquire any information on suspects/offenders. Providing assistance to the Missing Person Coordinator in locating high risk youth and missing persons. Providing culturally sensitive support to all victims Enhance referrals to appropriate services. Enforcement The Counter Sexual Exploitation Team will develop their enforcement goals exclusively directed at the identification and apprehension of exploiters and controllers, most 15

commonly referred to as traffickers and or pimps, the later more commonly associated to exploiting vulnerable persons involved in the sex industry. The GSPS officers is committed to addressing community concerns related to the visible sex industry, the CSET will facilitate open dialogue between sex workers and the concerned community to create sustainable solutions and a culture of safety for everyone. The GSPS is committed to the safety and protection of all community members and assigned officers will professionally and respectfully investigate all crimes committed against sex workers. Sex workers will be treated with dignity and respect will be provided culturally appropriate supports and services. Being a sex worker can be a high risk lifestyle for a variety of ways, such as physical health/wellness, emotional trauma, and a high propensity of being assaulted and or abused. The GSPS will support sex workers when they have been victimized and will work with community partners to provide wrap around services and exit strategies. Partnerships The Greater Sudbury Police Service will work in collaboration with members of the community, creating sustainable partnerships to provide assistance where and when required; for example, partnerships with vulnerable persons, community groups, government agencies, social service agencies and legal representatives will all contribute to Community Safety and Well-Being. With a collaborative approach the GSPS can focus on building a safer community with long term strategies while also balancing the needs of everyone involved. The Greater Sudbury Police Service recognizes the importance and value of multi-agency cooperation as a vital factor to the effectiveness and success of law enforcement efforts. GSPS continuously communicates and works together to meet mutual objectives from across Ontario and all jurisdictions it borders. Partnerships are extremely important; therefore, the GSPS will continue to collaborate with all stakeholders. Sudbury and Area Victim Services are established as Greater Sudbury and area s primary referral hub and are prepared to work with at risk and high risk individuals who have voluntarily removed themselves or as a result of police intervention been removed from a sexual exploitation situation and now find themselves requiring support and assistance. 16

Our Shared Commitment Model to Community Safety and Well-Being and the Four Pillars The Our Shared Commitment Model to Community Safety and Well-Being is made up of four separate and distinct performance dimensions; all are measured by new metrics and evidence-based practices which continue to evolve. The GSPS Counter Sexual Exploitation Strategy uses the GSPS Our Shared Commitment Model to Community Safety and Well-Being and the 2018-2020 GSPS Business Plan as the primary guiding document to operationalize these core principles. The GSPS Our Shared Commitment Model to Community Safety and Well-Being acknowledges that police cannot reduce levels of crime and victimization through traditional responses. The Strategy recognizes that Community Safety and Well-Being is not the sole responsibility of the police. It must be shared between various community partners to achieve the greatest result. The model acknowledges the unique ability the police possess to mobilize and engage community leaders, social service providers, municipal agencies, non-profits, community residents and the private sector in a multi-faceted approach to building a safer and healthier community. 17

1. Intervene Collaboratively to Reduce Elevated Risk Situations (Prevention) Collaboration is about new levels of inter-agency relationships, working together consistently with an ongoing open channel for information sharing within the bounds of privacy laws. Intervention speaks to enabling or mobilizing effective responses across agencies as needed to ensure early recognition and swift action upon the circumstances that place individuals, families and locations into elevated risk situations. Elevated Risk Situations occur when individuals, families or locations face situations which put them at predictable risk of offending. Examples of this are being victimized, breaching court imposed conditions or lapsing on a treatment plan for substance abuse. Building on enforcement and accountability, this Strategy also focuses a great deal on stopping crime and victimization before they happen. This is done through collaboration across agencies to recognize elevated risk situations faced by individuals, families or locations. Multiple partners are able to mobilize effective and quick actions in response. This represents the newest and most challenging aspect of this shared commitment as it requires agencies to work together in new ways. 2. Champion Community Safety, Security and Wellness (Protection) Our shared responsibility needs to work across the broader community and in our neighborhoods. It needs to build and maintain relationships among key agencies and community based partners. In addition, it must communicate the core concepts of Our Shared Commitment. GSPS members must be ambassadors to others for them to embrace this collective approach to Community Safety and Well-Being. 3. Enforce Laws and Hold Offenders Accountable (Enforcement) Police, Justice and Corrections officials will continue to have vital roles to play in enforcing the law, suppressing crime and disorder. They hold offenders accountable for their actions to keep our streets and neighbourhoods safe. Working together, the appropriate agencies will continue this focus through effective deterrents, targeted enforcement strategies, effective investigations, successful prosecutions and the rehabilitation of offenders. This is a key component to the Strategy s success. 18

4. Initiate and Partner to Achieve Positive Change in Community Outcomes (Partnerships) By addressing crime, victimization and their immediate risk factors, this shared commitment also focuses on the broader picture. A greater, more effective and economically sound integration of systems is needed in the community to build and sustain better lives and living conditions for more of our citizens. This is especially true for our youth and the most marginalized members of our population. The ongoing collaboration across agencies is necessary to define where services are needed most and to effect these changes. This is about planning for the future, not just addressing the present. 19

Conclusion The Way Ahead The GSPS Counter Sexual Exploitation Strategy outlines our commitment to the safety and security of all community members; this is best achieved through collaboration with other agencies and organizations (partners) from within the community to address the core issues of at-risk and/or vulnerable persons likely to being exploited. The Strategy s four pillars Prevention, Protection, Enforcement and Partnership asymmetrically envelop all aspects of the exploitation issue. Recognizing that Community Safety and Wellbeing cannot be the sole responsibility of the police; The Counter Sexual Exploitation Strategy will develop a Community Advisory Committee as the primary expert platform to develop ideas and critically review quarterly results in order to adapt to an ever changing environment. The Advisory Committee will consist of proven experts in the field with lived experience, academics and professionals in order to provide advice, guidance and a critical review on the progress of the Counter Sexual Exploitation Strategy. It is our collective responsibility to protect our most vulnerable from those predators who seek to do harm for their own personal and financial gain. We must make every effort to diminish opportunities for these predators that choose to steal the dignity and security from an innocent human being. This Strategy will guide police and community partners in a common direction, to provide culturally appropriate support to victims as well as tools and advice to frontline investigators to improve GSPS approach through innovation, collaboration and community engagement. 20

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