facilitated the subjection of the Hacienda Brasil Verde workers to trafficking, slavery and forced labor.” Accordingly, the representatives asked the Court to declare the violation of Article 6 of the American Convention, in relation, inter alia, to Article 1(1) of this instrument. Subsequently, in their final written arguments, they also asked the Court to declare the violation of Article 24 of the Convention. 227. The representatives concluded that Brazil was internationally responsible for failing to comply with its obligation to ensure the prohibition of slavery contained in Article 6 of the American Convention, in relation to the rights to juridical personality, personal integrity, personal liberty and safety, honor, dignity, privacy, and freedom of movement and residence (Articles 3, 5, 7, 11 and 22 of the Convention) with regard to all those who worked in Hacienda Brasil Verde following the date on which Brazil accepted the jurisdiction of the Court. This responsibility was aggravated owing to the discriminatory nature of the violations, and also the presence of victims who were under 18 years of age. 228. The State indicated that a clear distinction should be made between the concepts of slavery, servitude and forced labor. Although the concepts were related and were all prohibited by Article 6 of the American Convention, they retained their legal individuality and had varying degrees of gravity and, therefore, should have differentiated penalties in the case of international responsibility. In Brazil’s opinion, confusion should be avoided between the different types of human exploitation, because that would trivialize slavery and make it difficult to eliminate it. Likewise, the State argued that the Court should merely analyze slavery, servitude and forced labor in keeping with international law and not according to Brazil’s domestic law, which included a broader definition of those concepts without differentiating between them adequately. 229. The State also indicated that the prohibition of slave labor was an obligation erga omnes of jus cogens status. Nevertheless, those characteristics were insufficient to determine the content of the above-mentioned norms. 230. Regarding forced labor, the State indicated that, according to Convention No. 29 of the International Labour Organization (ILO), this included: (i) all work or service exacted under the menace of any penalty, and (ii) for which a person has not offered himself voluntarily. It also indicated that, in the case of the Ituango Massacres, the Court had added as an additional requirement that the violation could be attributed to the State. According to Brazil, a simple omission was not sufficient; rather, there had to be a State conduct indicating the intention to participate in the violation of the right, or at least facilitate it. 231. Furthermore, the State distinguished between servitude as such, and debt bondage. It argued that the elements of the former were that: (i) the obligatory work was performed on land belonging to another; (ii) the services were not provided voluntarily, and (iii) the obligation was based on law, custom or agreement. The threat of violence was also implicit. Meanwhile, the elements of debt bondage were that: (i) the work was demanded as guarantee for the payment of a debt; (ii) the work was assumed voluntarily; (iii) the value of the work was insufficient to pay off the debt; (iv) the duration of the work was indefinite, and (v) the nature of the services was indeterminate. 232. The State indicated that, according to the 1926 Convention, slavery referred to the “status or condition of a person over whom any or all of the powers attaching to the right of ownership are exercised.” Based on the fact that, legally, slavery had been abolished in almost all the world, the exercise of such powers would be a factual matter. Thus, the determination of the presence of slave labor would always depend on the specific case. Nevertheless, Brazil argued that the Court should focus on the domestic element of slavery; 59