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Outgoing Letters and Public Statements

December 10, 2015

Hon. Jody Wilson-Raybould
Minister of Justice
House of Commons
Ottawa, Ontario K1A 0A6

Dear Minister Wilson-Raybould,

First, please accept my congratulations on your election and appointment as Minister of Justice and Attorney General of Canada. 

The Evangelical Fellowship of Canada (the EFC) is the national association of evangelical Christians in Canada, gathered together for influence, impact and identity in ministry and public witness. Since 1964, the EFC has provided a national forum for Evangelicals and a constructive voice for Biblical principles in life and society.

The EFC has a long history of engaging on behalf of those who are vulnerable and exploited. We intervened before the Supreme Court of Canada in the Bedford case, arguing that prostitution is a practice that arises from the historical subordination of women, and the historical assumed right of men to buy and exchange women as objects for sexual use. We argued that it is a disgraceful assault on human dignity, and that the limitations on freedom and security arising from the laws were reasonable in light of the significant human rights violations that flow from the decriminalization of prostitution and the direct correlation with sex trafficking.

We also appeared before both the House of Commons Standing Committee on Justice and Human Rights and the Senate Committee on Legal and Constitutional Affairs in support of Canada’s new prostitution laws, the Protection of Communities and Exploited Persons Act.

We are encouraged by the Government’s strong commitment to addressing gender-based violence, as expressed in the mandate letters to the Ministers and in many of the official statements made by the new government already.

It is our firm belief that Canada’s new prostitution laws are a critical component of any strategy to address gender-based violence. We disagree with arguments that suggest the laws are responsible for the violence that’s inherent in prostitution. Efforts to reduce the violence in prostitution shouldn’t be centred around the prostituted making better or safer choices, or choosing safer locations, because that places the responsibility for avoiding or reducing violence on the victims, and not the perpetrators. In our view, the only way to end the violence is to challenge the behaviours and attitudes of those who buy and abuse women. To normalize or condone prostitution would be deeply contrary to that objective. 

The Protection of Communities and Exploited Persons Act is critical because it challenges the assumption that buying sex is an inevitable in our society. It recognizes that prostitution is a form of exploitation and violence against women, and that the most effective means of curbing commercial sexual exploitation is to target the demand for paid sex. All women and girls are safer in a society that chooses to say no women or girl should be for sale.

Today, December 10, is International Human Rights Day, and marks the conclusion of the United Nations’ 16 Days of Activism Against Gender-Based Violence. On this day, I urge you to uphold the PCEPA, and to work within the gender equity framework it provides to increase the safety of, and the choices and opportunities available to, all women.

Part of that work will involve amendments to the Act, and a number of other legislative and policy measures. We would like, for example, to see the complete decriminalization of women in prostitution. The criminalization of those who are vulnerable serves only to further entrench the inequality and marginalization that they have experienced, and creates barriers to their exit from prostitution. We suggest the PCEPA be amended to remove section 213 (1.1), which allows for continued criminalization of those who are prostituted - notably, the most marginalized and desperate who are engaged in street level prostitution. 

We also ask that you consider making it simple and inexpensive for those who have been exploited to have prostitution-related charges expunged from their criminal records. Prostitution-related charges are often a significant barrier to obtaining employment or housing, a further injustice given that the vast majority of individuals in prostitution are there because of constrained choice, economic desperation, or no choice at all. 

Those who are prostituted must be provided with viable options and alternatives. We need to address the social conditions that drive individuals to prostitution or make them vulnerable to exploitation, and we need to help those who are in to exit safely.  In order to increase choice and opportunity, we need continued and enhanced government investment in exit supports and services. 

Further, as has been highlighted by this government, we need to address the inequalities and injustices faced by our indigenous peoples. We need to take action on poverty reduction and alleviation, and address the need for safe, secure, affordable housing for all Canadians. We look forward to working with you toward these ends.
Please be assured of my sincere prayers for you in your new mandate.

Kind Regards,

Julia Beazley
Policy Analyst
The Evangelical Fellowship of Canada

Outgoing Letters


EFC President Bruce J. Clemenger writes regular commentaries about public policy issues. The EFC magazine Faith Today often publishes articles and essays that examine such issues.

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