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An opinion piece by Jacqueline Bottner, Senior Coordinator, Corporate Engagement ICMEC Australia.
A blind spot in responsible travel
When people think about child sexual exploitation and abuse (CSEA) in the travel and tourism industry, their minds often turn to poverty-stricken countries - places with weak child protection laws, high levels of corruption, and perpetrators imagined as shady, dangerous individuals who lurk on the margins of society.
The unfortunate reality is that CSEA is a far-reaching issue that affects children everywhere, including here in Australia. Despite having some of the world’s strongest extraterritorial laws to prosecute Australians who offend overseas, the problem is also domestic. In fact, one in four Australians have experienced child sexual abuse right here at home (ACMS 2023). Many perpetrators blend in, looking like ordinary tourists, business travellers, or even families on holiday.
While sustainability and environmental, social and governance (ESG) initiatives are gaining momentum across the travel and tourism industry, child protection is still largely absent from the conversation. It’s encouraging to see growing commitments to environmental impact and community development, but when it comes to safeguarding children, there is often a lack of awareness. The risks and realities of CSEA fit squarely within the ‘social’ pillar of ESG, which focuses on human activity and civil society challenges, and should be considered a core part of every organisation’s human rights and modern slavery frameworks.
The good news is that hospitality workers are on the front lines of guest interaction, giving them a unique opportunity to recognise warning signs, intervene in unsafe situations, and even prevent children from being harmed.
The first step toward positive change is building awareness and recognising the role the industry can play in protecting children. By starting the conversation, we can begin to create travel environments that are not only sustainable and ethical, but also safe for children.
What is CSEA and how it intersects with travel
Child sexual abuse occurs when an adult takes advantage of a child for sexual purposes - whether that’s in person or online. When abuse involves money, gifts, or any kind of exchange, it becomes exploitation.
While some offenders travel with the deliberate intent to sexually abuse children, others are opportunistic. They may not set out to offend but end up doing so when the opportunity arises and protective measures are lacking. On the flip side, offenders don’t need to be on holiday to exploit travel infrastructure to facilitate these crimes.
The online / offline connection
In today’s digital world, offenders often make first contact with children through popular messaging platforms, social media apps, and online gaming, with the aim of eventually moving the relationship offline. In these situations, young people may be led to believe they’re communicating with someone their own age, when in fact they’re being groomed by an adult.
Once a connection is made, offenders may use travel to facilitate abuse - targeting children outside of their immediate area, where they feel more anonymous and less likely to be recognised. Offenders utilise travel services like rideshare apps, booking platforms, and hotels to arrange meetings and conceal their actions. In this way, ordinary tourism infrastructure can unintentionally become part of the abuse pathway.
Human trafficking and modern slavery
Modern Slavery is an umbrella term for the use of coercion, threats, violence, and deception to exploit people and deprive them of their freedom. One form of this is human trafficking, which involves transporting a child to sexually exploit them across city, state or international borders. It's important to note that children - by virtue of their age are considered inherently vulnerable and unable to consent - which means that their exploitation can still be considered modern slavery or human trafficking even if no one ever threatened or forced them explicitly. The UN estimates that one in three detected trafficking victims worldwide is a child, and in Australia, for every victim identified, another four go undetected.
Hotels, motels, and transit hubs are often misused in these crimes, making the travel and hospitality sector a critical line of defence. According to the Australian Criminal Intelligence Commission, serious and organised crime groups are often closely involved in the perpetration of these crimes, and this can jeopardise the safety of staff and other guests.
CSEA in hotels and holiday rentals
The privacy offered by hotel rooms and short-term holiday rentals can make them attractive settings for offenders looking to exploit children.
The rise of informal and less regulated accommodation options, such as peer-to-peer home rentals and smaller budget hotels with self-service check-in kiosks, has further complicated detection and oversight. However, this crime can happen in any type of accommodation, including luxury hotels.
In a recent Australian example reported on by ABC, the offender was a high-level bank executive staying in the Sofitel Brisbane while travelling for work. The offender tasked an 18-year-old sex worker with the procurement of two young girls for him to sexually abuse. The girls were brought to his hotel room, however, after changing his mind and refusing to open the door for them, the offender contacted the front desk and requested that the girls be removed from the five-star hotel. This phone call alerted the front desk to the suspicious situation, allowing hotel staff to intervene and contact the police. In the end, the offender was arrested and charged with using electronic communication to procure children under the age of 16.
More recently, in Cairns, a 25-year-old man was charged with multiple offences after allegedly arranging to meet a teenage girl at a city hotel via social media. Queensland Police allege he supplied the girl with drugs before sexually assaulting her. The case came to light when a family member raised the alarm, prompting a police investigation that led to his swift arrest. The matter is now before the courts, with police commending the victim’s bravery in coming forward.
These examples illustrate the diverse ways in which hotels, from luxury five-star properties to budget city motels, can be exploited by offenders. Hotels and motels are often a hot spot for human trafficking and sexual exploitation as they offer easy access, the ability to pay in cash, and a level of anonymity that makes it easier for offenders to avoid detection. In some cases, limited staff oversight or infrequent room checks create additional blind spots where abuse can occur unnoticed.
Hotels globally have faced lawsuits for being complicit in human trafficking, particularly where staff failed to identify or respond to red flags. In Australia, if a hotel is found to be knowingly involved in, aiding, or allowing human trafficking or slavery, it can be prosecuted under the Criminal Code Act 1995 (Cth). This legal risk adds another layer of urgency for the industry to invest in staff training, clear reporting procedures, and child protection policies.
Sexual assaults on aircraft
Commercial flights where personal space is limited and cabins are often dimly lit, can create conditions that leave unaccompanied minors or children seated away from their guardians vulnerable to in-flight sexual assault.
According to a 2024 report by the FBI, they investigated 104 cases of sexual assault on aircraft that year, with many of the reports coming from children. These incidents often go unreported due to feelings of fear, confusion, or embarrassment, which can make it harder to intervene or hold perpetrators accountable. The Journal of Australian Lawyers cites the seating of minors in close proximity to adult strangers as an identified issue in cases of sexual assault and harassment on airlines.
But it’s not only other passengers that pose a risk to children during air travel. In some recent cases, airline staff have also been accused of assaulting minors in their care. For example, in 2020, a father sued South American airlines LATAM over the sexual assault of his 6-year-old son by a member of airline staff when the boy was flying as an unaccompanied minor. In another recent case on American Airlines, a former flight attendant taped his phone to the toilet to record people using the bathroom, including a 9 and a 14-year-old girl.
In Australia, there have been several documented cases involving staff of major airlines charged with CSEA related offences. For example, a former flight attendant was recently jailed after admitting to sending thousands of files of child sexual abuse material to contacts worldwide. In another case, an international flight attendant who travelled to the Philippines in both private and professional capacities offended on 25 separate occasions over a seven-year period.
What makes this even more concerning is that there is currently no mandatory requirement for airlines to report incidents of sexual assault onboard to police. This lack of obligation can lead to serious incidents being handled informally or not at all - allowing offenders to walk away without consequence. In some of these cases, passengers have taken legal action against airlines, highlighting a growing area of legal and reputational vulnerability.
Why this matters in travel and tourism
Child protection is not a peripheral issue; it is closely linked to the travel industry’s existing priorities and responsibilities. As more businesses adopt sustainability and purpose-led strategies, there is a growing expectation from customers that human rights risks, including child exploitation, are addressed with seriousness and accountability.
Under Australia’s Modern Slavery Act, certain businesses in every industry must identify and address exploitation risks in their operations and supply chains, and that includes risks to children. By not addressing the risks of CSEA within your organisation head on, the business can face ongoing and significant safety, financial, reputational, and legal ramifications.
Customers are also paying closer attention. Families want to book with brands they can trust, and travellers increasingly expect companies to demonstrate clear ethical standards. Internally, protecting children also means equipping staff with the support they need to feel confident in identifying red flags and responding safely, so they know that their workplace takes this issue seriously. Given that employees can also be parents or caregivers, this training can help them recognise the signs of exploitation in a professional capacity, while also equipping them with the knowledge to keep their own families safe.
When companies take a proactive approach to child protection, it not only reduces risk but strengthens their values, brand, and long-term impact. Importantly, new data highlights that traveller perceptions of sustainability are broadening. Research from Booking.com in 2025, based on global consumer insights, found that for the first time more than half of travellers now consider the social impact of tourism on local communities, not just environmental factors. This shift underscores that responsible travel is no longer just about reducing environmental footprints, but it’s also about safeguarding people in the places we visit.
What the travel and tourism industry can do
Tourism and hospitality businesses can start by incorporating child protection into their ESG and risk management discussions, recognising it as an essential component of human rights due diligence.
While small businesses might feel that they don't have the capacity to implement child safeguarding initiatives, almost all disciplines touch on this topic in some way. Providing basic training for staff, such as how to recognise signs of grooming, exploitation, or suspicious behaviour, can go a long way in creating safer environments for children and guests alike. Partnering with organisations like ICMEC Australia can help businesses access the right resources, guidance, and support to build child-safe practices that align with existing sustainability and compliance goals.
Meaningful progress often begins with small, practical steps that can have a significant impact.
Take the first step
For those in the travel and tourism industry, consider initiating conversations within your organisation about where child protection fits into your ESG strategy. Explore available opportunities to strengthen your detection and prevention of this crime and engage with organisations already working in this space.
Child protection isn’t just an ethical issue; it’s a business responsibility. And it’s one the industry has the power to lead on.
If you’d like to learn more about how to get started, please get in touch with ICMEC Australia at corporate@icmec.org.au.
About ICMEC Australia
ICMEC Australia is a specialist not-for-profit organisation that strengthens Australia’s ability to prevent and respond to child sexual exploitation and abuse (CSEA). ICMEC Australia supports government, industry, and the community to strengthen safeguards, disrupt harm, and build systems that protect children. Our work is grounded in evidence, cross-sector collaboration, and a commitment to creating safer environments for children in Australia and beyond.
References:
What we are witnessing with Grok is not a technical failure. It is a platform governance failure.
In recent weeks, Grok (An AI chatbot embedded within the platform ‘X’) has been used to generate non-consensual sexualised imagery, including ‘nudified’ images of women and, in some reported cases, children. The response so far has largely been reactive: tweaks to safeguards, geoblocking in certain jurisdictions, and statements that shift responsibility back onto users once the damage is already done.
From an Australian perspective, our eSafety Commissioner made it clear this week that this is unacceptable. The Commissioner confirmed a rise in reports relating to Grok producing sexualised and exploitative imagery and has formally engaged X to explain what safeguards are in place – and why they were clearly insufficient. With new mandatory online safety codes commencing in March 2026, the message could not be clearer: generative AI systems must be expected to anticipate misuse, not merely respond after harm occurs.
Australia is not alone in this conclusion. Regulators across the EU and UK have also moved quickly, launching investigations, issuing data-retention orders, and, in some cases, referring matters to prosecutors under the Digital Services Act and national criminal law. Indonesia and Malaysia imposed temporary bans. Countries including France, Germany, Italy, Sweden, India, and the United Kingdom are all examining whether Grok’s design and deployment breach existing safety obligations.
What is striking is how familiar this pattern is. We have seen it before with social media platforms: rapid deployment, minimal guardrails, externalised harm, followed by accusations of ‘censorship’ when regulators step in. But generative AI raises the stakes significantly. When a system can automatically manipulate real images of real people at scale – particularly women and children – the harm is not hypothetical. It is immediate, personal, and enduring.
At ICMEC Australia, we see the real-world consequences of safeguarding and governance failures every day. Our work with law enforcement, regulators, and frontline organisations show us time and time again that harms created by unsafe technology design do not remain online – they follow children into their schools, homes, and communities, for life. Innovation does not have to come at this cost. Safety and technological progress are not mutually exclusive, but safety must be built in from the start.
AI companies cannot credibly claim neutrality when their products are designed in ways that invite abuse, fail to integrate guardrails, and simply deploy under a narrow interpretation of ‘innovation at speed’. Safety by design is not optional. Consent protections are not a ‘nice to have’. And blaming users is no longer a defensible position when predictable misuse was foreseeable from day one.
The Australian Government have signaled they understand what is at stake. Renewed attention towards legislating a digital duty of care, alongside emerging work on AI-related harms, reflects a broader shift towards placing responsibility where it belongs – on companies with the power to prevent harm before it occurs. As Australia moves into 2026, these reforms – and the need for further action – must remain a priority, particularly where children are concerned.
Grok is not under scrutiny because it is controversial. It is under scrutiny because it crossed a line. The question now is whether the AI sector learns from this moment – or whether regulators will be forced to draw much firmer boundaries on its behalf.
About the author
Colm Gannon is the CEO of the International Centre for Missing and exploited Children (ICMEC), Australia with over 20 years’ experience in law enforcement, digital safety, and child protection. He has led national and international investigations into online harms, child sexual exploitation and abuse (CSEA), and cybercrime. Combining this expertise with a technical background in AI and software development, Colm works at the intersection of technology and child safety, advancing ICMEC Australia’s mission to protect children.
References
An opinion piece by Rosie Campo, ICMEC Australia's Head of Corporate Engagement
In her latest op-ed, Rosie Campo, shares powerful insights from the ICMEC Australia Symposium 2025: Convergence, where leaders from government, financial services, technology, law enforcement and the non-profit sector came together with a clear message.
Businesses must take an active role in preventing child sexual exploitation to help combat this crime.
Rosie outlines how offenders are exploiting everyday business systems and why companies cannot wait for regulation to dictate their response. Prevention and disruption must sit at the centre of corporate responsibility, with safeguarding embedded into governance, risk and compliance.
Her reflections from the symposium highlight the enormous potential within business to identify risks earlier, protect children and strengthen the systems that offenders use to cause harm.
This is essential reading for anyone working across the corporate sector.
We are pleased to share the Impact Report FY2024–25.
A year of collaboration, innovation and measurable change. Together, we’re working towards creating a world where technology cannot be used to harm children.
“At the heart of our mission is a simple focus, to strengthen the professionals who detect, disrupt and prevent harm.”
— Colm Gannon, CEO, ICMEC Australia
We’re proud to share the ICMEC Australia Impact Report FY2024–25, highlighting another year of progress in strengthening our response to child sexual exploitation and abuse (CSEA).
ICMEC Australia is an independent not-for-profit organisation working to create a world where technology cannot be used to harm children, starting here in Australia.
We’re seeking Non-Executive Directors to join our Board and help guide the organisation’s strategy, risk, and performance in line with our mission: to strengthen the professionals working to detect, disrupt and prevent child sexual exploitation and abuse (CSEA).
As a Board Director, you will:
We’re looking for leaders who bring integrity, ethical governance, and a deep commitment to child safety and social impact.
To express your interest, please send a cover letter and CV to cosec@icmec.org.au.
On Tuesday, 2 September, leaders from across the political spectrum came together at Parliament House to drive urgent action and ensure child protection remains at the forefront of Australia’s approach to AI.
Convened by ICMEC Australia, the National Leaders' Conversation on AI and Child Safety brought together parliamentarians, senior law enforcement leaders, and child safety advocates to focus on three urgent priorities: embedding baseline AI training for police across the country, scoping a law-enforcement only facial recognition tool to assist investigations, and elevating awareness on AI-enabled harms nationally through a focus on prevention.
Following this roundtable, ICMEC Australia commends Kate Chaney MP for raising the issue directly in the House and drawing it to the attention of the Attorney-General. Her leadership highlights the momentum building across Parliament to address the growing risks of AI-enabled child sexual exploitation..
Listen to Kate Chaney speak in Parliament House below. Kate's speech begins at 6.02.00.
Launching our new series of Insights Papers
AI-driven “nudify apps” can take an innocent photo and turn it into a sexualised image within seconds. Once a niche tool, they are now mainstream, monetised and industrialised, fuelling sexual extortion, peer-on-peer exploitation and the large-scale creation of AI-generated child sexual abuse material (CSAM).
The first paper in ICMEC Australia’s new Insights Series examines how nudify apps exploit open-source AI, the severe harms they cause for children, and the urgent need for legal, community and cross-sector action.
The claim that “no real child is harmed” is false. Real children’s images are being scraped to train these tools, meaning exploitation begins the moment those images are reused.
Written by: Cherise Holley, Mikaela Jago, and Dr Janis Dalins
ICMEC Australia’s Insights Papers provide clear, accessible analysis of emerging risks at the intersection of child protection and technology. Produced with input from experts, the series offers timely insights for government, industry, and the community to inform action as new threats arise.
From concern to action.
How can Australia lead the world in protecting children in the age of AI?
ICMEC Australia's CEO Colm Gannon reflects on our recent national roundtable at Parliament House and highlights the urgent need for legal and technological safeguards as AI accelerates child sexual exploitation and abuse.
Read Colm’s opinion piece on why the time to act is now.
Stay informed and subscribe to our newsletter today below!
On Thursday 17 July, Australia’s first national roundtable on child safety in the age of AI took place at Parliament House. The event placed this urgent issue firmly on the national agenda.
Hosted by ICMEC Australia, the roundtable brought together senior leaders from government, law enforcement, technology, and child protection sectors. Participants addressed the alarming growth in AI-facilitated child sexual abuse, including deepfakes, synthetic child sexual abuse material (CSAM), automated grooming, and child-like AI personas.
The forum attracted widespread media coverage across television, radio, online, and print platforms, helping raise national awareness and public momentum for action.
“AI is being weaponised to harm children, and Australia must act,” said Colm Gannon, CEO of ICMEC Australia. “This roundtable represented a pivotal moment for child protection. We need urgent action to ensure these technologies do not outpace our systems of prevention and justice.”
New figures from the National Center for Missing and Exploited Children (NCMEC) revealed a 1,325 percent increase in reports of CSAM involving generative AI, rising from 4,700 in 2023 to more than 67,000 in 2024. In Australia, these threats compound a national crisis, with more than one in four Australians reporting they experienced sexual abuse in childhood (ACMS, 2023).
Key outcomes from the roundtable:
Participants included:
The national roundtable builds on ICMEC Australia’s SaferAI for Children's Coalition’s 2024 discussion paper and 2025 call to action. It is a key opportunity for Australia to lead globally on child protection and AI governance, whilst encouraging industry innovation through ‘Safety by Design’.
“If we act now, Australia can set a global benchmark for ethical AI and child protection,” said Gannon.
“Children’s safety must be at the centre of how we think about and regulate AI in Australia,” said Sonya Ryan, CEO of The Carly Ryan Foundation. “Technology is advancing rapidly. Without decisive, child-centred action, we risk failing to protect children from new and emerging threats.”
“We are seeing AI generate entirely new types of child abuse material. This is a turning point,” said Jon Rouse APM.
ICMEC Australia extends sincere thanks to all partners who joined the roundtable. Together, we can ensure that technology protects children rather than exploits them.
– Ends –
ICMEC Australia acknowledges Traditional Owners throughout Australia and their continuing connection to lands, waters and communities. We pay our respects to Aboriginal and Torres Strait Islanders, and Elders past and present.
