287. Under the European human rights system, even though there is no explicit mention of the phenomenon in the European Convention on Human Rights,433 the European Court has concluded that the definition of trafficking in persons in the Protocol of Palermo included the prohibition of slavery, servitude and forced labor and fell within the scope of Article 4 of the European Convention.434 In the case of Rantsev v. Cyprus and Russia, the European Court established that trafficking in persons “by its very nature and aim of exploitation, is based on the exercise of powers attaching to the right of ownership. It treats human beings as commodities to be bought and sold and put to forced labour, often for little or no payment, usually in the sex industry but also elsewhere. It implies close surveillance of the activities of victims, whose movements are often circumscribed. It involves the use of violence and threats against victims, who live and work under poor conditions.”435 288. The definitions included in the previously mentioned international treaties and the interpretation by the European Court of Human Rights in the Rantsev case leave no doubt that the concepts of the slave trade and traffic in women have transcended their literal meaning in order, at the current stage of evolution of international human rights law, to protect the “persons” trafficked for the purpose of subjecting them to different forms of unwilling exploitation. One and the same factor connects the prohibitions of the slave trade and traffic in women, and that is the control exercised by the perpetrators over the victims during their transportation and transfer for exploitation purposes. The European Court also identified the following factors that were common to both forms of trafficking: (i) control of a person’s movement or physical environment; (ii) psychological control. (iii) adoption of measures to prevent escape, and (iv) forced or compulsory labor. 436 289. Based on the foregoing, the Inter-American Court considers that, in light of the evolution of international law in recent decades, the phrase “slave trade and traffic in women” of Article 6(1) of the American Convention should be interpreted broadly to refer to “trafficking in persons.” In the same way that the purpose of the slave trade and traffic in women is the exploitation of the human person, based on the interpretation that is most favorable to the individual and the pro persona principle, the Court cannot limit the protection granted by this article only to women or to the said “slaves.”437 This is important to give practical effects to the prohibition established in the American Convention pursuant to the evolution of the phenomenon of human trafficking in our societies. 290. Therefore, the prohibition of “the slave trade and traffic in women” contained in Article 6(1) of the American Convention refers to: i) The recruitment, transportation, transfer, harboring or receipt of persons; ii) Resorting to threat or use of force or other forms of coercion, of abduction, of fraud, of deception, of the abuse of power or of a position of vulnerability or of the giving or receiving of payments or benefits to achieve consent by a person having control over another person. In the case of European Convention on Human Rights, Article 4: Prohibition of slavery and forced labour 1. No one shall be held in slavery or servitude. 2. No one shall be required to perform forced or compulsory labour […]. 433 434 ECHR, Case of Rantsev v. Cyprus and Russia, para. 282. 435 ECHR, Case of Rantsev v. Cyprus and Russia, para. 281. 436 ECHR, Case of Rantsev v. Cyprus and Russia, para. 280. Cf. Case of Boyce et al. v. Barbados, Preliminary objection, merits, reparations and costs. Judgment of November 20, 2007. Series C No. 169, para. 52, and Case of Wong Ho Wing v. Peru. Preliminary objections, merits, reparations and costs. Judgment of June 30, 2015. Series C No. 297, para. 126. 437 75