Strategy)192 recognises the critical importance of building and supporting regional and global partnerships to end all forms of modern slavery. Continued participation in regional forum such as the Bali Process on People Smuggling, Trafficking in Persons and Related Transnational Crime,193 investment in regional programs such as the ASEAN-Australia Counter Trafficking (ASEAN-ACT) program,194 and strengthening of operational cooperation between law enforcement and border agencies should be encouraged. The 40 commitments identified in the International Engagement Strategy need to be fully resourced and implemented. In particular, the Commission notes that the commitment to ratify the International Labour Organization Protocol of 2014 to the Forced Labour Convention 1930 (No. 29) was met with the ratification of the Protocol by Australia on 31 March 2022. 195 Recommendation 32: The Australian Government amend the Modern Slavery Act to establish an independent Anti-Slavery Commissioner, introduce financial penalties for non-compliant entities, and establish a national compensation scheme for victims. Recommendation 33: The Australian Government resource and implement both the National Action Plan and International Engagement Strategy. Recommendation 34: The Australian Government facilitate the provision of alternative supports and pathways to remedies for victims and survivors which are not contingent on participation in criminal prosecutions. 8 Counter-terrorism legislation Relevant provisions of the CAT: Article 2, 11. 135. The Australian Government has enacted 92 counter-terrorism laws in the two-decades since 11 September 2001. 196 The Commission is concerned that many of Australia’s counter-terrorism laws restrict human rights through legislation that has not been shown to be legitimate, reasonable or proportionate responses to potential harms. In particular, the Commission draws the Committee’s attention to the following laws: • Preventative detention orders enabling a person to be held in secret without arrest or charge for up to 48 hours, and control orders which can place significant prohibitions and restrictions on a person’s freedom of movement, expression, association and right to privacy.197 32