EXPLORING DISPARITIES BETWEEN GLOBAL HIV/AIDS FUNDING AND RECENT
TSUNAMI RELIEF EFFORTS: AN ETHICAL ANALYSIS

TIMOTHY CHRISTIE, GETNET A. ASRAT, BASHIR JIWANI, THOMAS MADDIX,
JULIO S.G. MONTANER (2007) EXPLORING DISPARITIES BETWEEN GLOBAL
HIV/AIDS FUNDING AND RECENT TSUNAMI RELIEF EFFORTS: AN ETHICAL
ANALYSIS. Developing World Bioethics 7 (1), 1--7.
doi:10.1111/j.1471-8847.2006.00150.x

Objective: To contrast relief efforts for the 26 December 2004
tsunami with current global HIV/AIDS relief efforts and analyse
possible reasons for the disparity.

Methods: Literature review and ethical analysis.

Results: Just over 273,000 people died in the tsunami, resulting in
relief efforts of more than US$10 bn, which is sufficient to achieve
the United Nation's long-term recovery plan for South East Asia. In
contrast, 14 times more people died from HIV/AIDS in 2004, with
UNAIDS predicting a US$8 bn funding gap for HIV/AIDS in developing
nations between now and 2007. This disparity raises two important
ethical questions. First, what is it that motivates a more empathic
response to the victims of the tsunami than to those affected by
HIV/AIDS? Second, is there a morally relevant difference between the
two tragedies that justifies the difference in the international
response?

The principle of justice requires that two cases similarly situated
be treated similarly. For the difference in the international
response to the tsunami and HIV/AIDS to be justified, the tragedies
have to be shown to be dissimilar in some relevant respect. Are the
tragedies of the tsunami disaster and the HIV/AIDS pandemic
sufficiently different, in relevant respects, to justify the
difference in scope of the response by the international community?

Conclusion: We detected no morally relevant distinction between the
tsunami and the HIV/AIDS pandemic that justifies the disparity.
Therefore, we must conclude that the international response to
HIV/AIDS violates the fundamental principles of justice and fairness.

INTRODUCTION

The flow of humanitarian support for victims of the 26 December 2004
tsunami in South East Asia is appropriate and encouraging. It is
reported that, in the aftermath of this natural disaster,
international donors pledged over US$10 bn to tsunami relief
efforts.1 Of this US$10 bn, US$2.8 bn of funding was dispersed within
the first six months after the disaster, and there is a concerted
effort to ensure that donor countries live up to their funding
promises.2 The projection is that US$10 bn over the next five to ten
years will be sufficient funding to complete the United Nations' long-
term recovery plan for South East Asia.3 Public generosity for
tsunami relief has been so overwhelming that Me'decins Sans Frontie'res
has been compelled to decline further donations for this cause;4 in
addition, World Vision, Care USA, Oxfam America, and the American Red
Cross also have stopped actively collecting for this cause.5

The magnitude and immediacy of the international response to the
tsunami disaster compels us to ask why, paradoxically, other
problems, most notably the HIV/AIDS pandemic, have failed to strike
the same chord with the international community. In comparison to the
ample amount of US$10 bn pledged to tsunami relief efforts and the
US$2.8 bn actually dispersed so far, HIV funding pledged for 2005 is
less than half of the US$12 bn required, and it is estimated that by
2007 the pledged HIV funding will be only a quarter of the US$20 bn
that will be necessary at that time.6 Between now and 2007 the Joint
United Nations Programme on HIV/AIDS (UNAIDS) predicts a funding gap
of US$18 bn for HIV/AIDS.7

In referring to the `international community,' we realise that there
is no universally recognised group of stakeholders that make up this
association. However, in response to the tsunami, a coordinated
international effort developed that is so extraordinary it almost
defies description. For instance the United Nations have administered
billions of dollars of pledges from more than 60 donor nations. The
following is a quotation, which describes the extent of the
international response for one city of the 12 tsunami-affected
countries:

The international community response has been extraordinary,
involving 12 governments, 100 local governments, more than 150 NGOs
and partner organizations with 5,000 international staff in Banda
Aceh alone.8

The tsunami disaster demonstrates that stakeholders, such as
governments, non-governmental organisations, religious organisations,
individual members of the public, etc., have collaborated to
orchestrate the world's largest humanitarian relief operation in
history.9 Therefore, it is fair to ponder why such collaboration has
occurred in response to a natural disaster like the tsunami, but not
the much larger HIV/AIDS pandemic.

Although it makes many of us uncomfortable to compare disasters, the
fact remains that the tsunami death toll in 2004 of approximately
273,000 people is far less than the global death toll from HIV/AIDS
in 2004, which was approximately 3.1 million people. In fact, some
commentators have stated that the mortality rate from HIV/AIDS is
equivalent to one tsunami a month.10

The intention of this paper is to compare the international response
to the tsunami disaster with the international response to HIV/AIDS.
We will explain some specifics about the disparity and offer an
ethical analysis, which critically examines some of the fundamental
differences between the two events. We will conclude that although
there are differences between the tsunami and the HIV/AIDS pandemic,
these differences do not justify the colossal difference in the
response of the international community to these tragedies.

The Asian tsunami killed approximately 273,000 people in one
afternoon, it affected 12 countries, resulted in more than 150,000
casualties, 24,000 missing persons reports, and more than one million
displaced persons.11 In response to this disaster, the international
community pledged an incredible US$10 bn, of which US$2.8 bn has
already been dispersed. It is expected that this funding will be
sufficient to achieve the United Nations' long-term recovery plan for
South East Asia. On the other hand, the annual death toll from
tuberculosis is 2--3 times higher than the death toll from the
tsunami,12 and every month diarrhoea kills more than 140,000 people
worldwide, while malaria and AIDS each kill an additional 250,000
people per month.13 The tsunami orphaned approximately 100,000
children, whereas AIDS has orphaned more than 11 million children in
Africa alone.14

The latest HIV/AIDS statistics report that the global prevalence of
HIV is more than 39.4 million people and the incidence rate in 2004
was 4.9 million new infections. The death rate from HIV/AIDS related
causes in 2004 was 3.1 million people. Sub-Saharan Africa, by itself,
has over 60% (n = 25.4 million) of the world's population of people
living with HIV/AIDS.15 In 2002, the UNAIDS programme estimated that,
without proper prevention efforts, there would be approximately 45
million new cases of HIV in Africa by 2010. They further argued that
more than 64% (or 29 million) of these infections are avoidable via
proper prevention efforts.16 Regarding treatment of HIV, the `3 by 5
initiative' is a plan to provide three million people in low- and
middle-income countries, with antiretroviral treatment by the end of
2005. The cost will

be as little as US$17 per month/per patient, or
US$0.56 per day/per patient, but will reach less than 50% of the
people who need Highly Active Antiretroviral Therapy (HAART).17

A telling example of political inconsistency in response to these
disasters is Canada's response. Within the first two weeks after the
tsunami, Canada pledged over C$5 million without knowing exactly what
was needed or what the strategic direction for relief efforts would
be. On 10 January 2005, the Prime Minister announced that Canada
would contribute C$425 million over the next five years for a
comprehensive disaster relief package.18 In fact, Canada has been
applauded as one of the most generous countries in the world for its
tsunami relief efforts.19 In contrast, funding for the Canadian
Strategy on HIV/AIDS will gradually increase from C$42.2 million to
C$84.4 million over the next five years, which is still significantly
below the C$106 million currently necessary to get ahead of the
epidemic in Canada.20 Furthermore, Canada's pledge of C$70 million
for the Global Fund remains far below that deemed adequate by the
Equitable Contribution Framework.21

Unlike the international response to HIV/AIDS, the response to the
tsunami disaster has demonstrated that rapid and massive resource
mobilisation is possible if the international community is suitably
motivated. In fact, resources allocated for the tsunami exceed what
is required to deal with 100% of the demand; whereas the projected
resource allocation for HIV/AIDS is expected to be deficient by US$18
bn between now and 2007. This comparison raises two ethically germane
questions, which, furthermore, are importantly linked. First, what is
it that motivates a more empathic response to the tsunami than to
HIV/AIDS? Why is it that the international community has made such an
extraordinary effort to address this need so completely? Second, is
there a morally relevant difference between the two tragedies that
justifies the difference in the international response?

The first of these questions is a matter of moral psychology, on
which we will only speculate. The tsunami was a one-time event,
whereas HIV/AIDS is an ongoing crisis. It is probably true that a
sudden disaster generates a different visceral response than a slow
ongoing horror such as the HIV/AIDS pandemic. Furthermore, the shock
value of this event was definitely influenced by the media response
and, quite possibly, the resultant empathy for victims of the tsunami
was a `knee jerk' response.

It is also possible that tsunami relief efforts are, in a
sense, `easier' and more concrete than what is needed to fight
HIV/AIDS. Many health system constraints, in developing countries,
create bottlenecks that prevent aid from being used efficiently where
it is most needed.22 Tsunami relief efforts largely went to tasks for
which infrastructure and skills were readily available for use of
resources, for example, providing food, shelter, rebuilding and re-
equipping schools and clinics, rebuilding boats, desalinating rice
paddies, etc.; whereas what is needed to confront HIV/AIDS is:
education, changing attitudes, changing intimate behaviour, changing
unequal gender relations and attitudes toward women, etc. These are
much more involved projects that may be harder for people to
conceptualise and difficult to achieve without adequate
infrastructure support.

It is one thing to speculate whether the difference between a one-
time event and an on-going crisis, or whether the lack of
infrastructure supports, is actually the cause of the difference in
the international response to the two events. However, it is quite
another question to ask whether this difference is justified. In the
first question we are simply trying to understand the phenomenon of
the international community's reaction to the two events. But with
the second question we are exploring whether any difference in
response, whatever its actual cause, is justified. The principle of
justice suggests that any two cases that are situated similarly ought
to be treated in a similar fashion. For any difference in the
international response to the tsunami and HIV/AIDS to be justified,
the two tragedies have to be shown to be dissimilar in some relevant
respect -- in some way that is material to the purpose of the
comparison. The general question from this ethical principle is; are
the tragedies of the tsunami disaster and the HIV/AIDS pandemic
sufficiently different, in relevant respects, to justify the
difference in scope of the response by the international community?

One of the biggest differences between the tsunami and HIV/AIDS is
the apparent morally neutral nature of the tsunami disaster. The
tsunami was a natural disaster that did not involve human agency.
HIV/AIDS, on the other hand, is a disease that is spread via human
conduct, primarily through sex and/or injection drug use.23 This, at
a superficial level, may make it is easier to blame the victims, or
at least to be less empathic. The following quotation from Stephanie
Nolen's Globe and Mail piece describes the difference:

It's not [for] people fighting each other all the time -- and there is
a moral judgment that people still make about HIV and AIDS, but there
is no moral judgment about being hit by a wave. I feel a slight
undercurrent -- AIDS is connected with sex and sex is bad. But this is
just a wave.24

The general point is that a major difference between the two
tragedies is the role of human agency. That is, the victims of the
tsunami did nothing to precipitate the event (the underwater
earthquake) that led to the harms they ended up experiencing, but
those affected by HIV/AIDS have had a causal role to play in the
events that led to their being affected by the disease. This line of
argument reasons that human agency justifies the difference in the
way that the global community has responded to the two events.

The major problem with this argument is that it grossly overstates
the roles of a great many individuals, particularly in developing
countries, who end up with HIV/AIDS because they occupy relatively
weak positions in the power relationships that govern the social
order. For instance Dr Mark Wainberg explained the weakness in this
argument as follows:

It is incredible to hear some people still arguing that the victims
of HIV are largely deserving of their fate because of injection drug
use, promiscuity, prostitution or failure to use condoms -- as though
abject poverty, poor education and a too common sense of despair in
AIDS-endemic countries had nothing to do with it. Not to mention that
millions of women are the victims of sexual assault in any given year
and are often not empowered to insist on condom use under the best of
circumstances.25

Regardless of what one thinks about sex, injection drug use,
prostitution, promiscuity, and/or any other HIV risk behaviour,
evidence clearly indicates that the negative consequence of
contracting HIV/AIDS and/or having untreated HIV are largely
preventable and unnecessary. For example, the proper administration
of HAART can significantly reduce the morbidity and mortality
associated with HIV/AIDS and can extend, significantly, the lives of
those infected with the HIV virus.26 There is even evidence that
providing effective HAART can reduce the heterosexual transmission of
HIV by as much as 80%.27 The correct use of condoms can reduce the
risk of sexual transmission by more than 80%;28 harm reduction
strategies can significantly redu

ce the spread of HIV via injection
drug use by more than one third;29 and mother-to-infant transmission
can be virtually eliminated with proper interventions.30

One consequence of the disparity that results from the human agency
argument, is that if people behave in a way that precipitates holding
individuals or groups responsible for their disease, it is then
appropriate for that person (or group of people) to suffer the
consequent harms, no matter how severe or preventable. The principles
of respect for human life and human dignity, however, suggest that
the lives of those suffering preventable morbidity and/or mortality
(e.g. HIV/AIDS) are not any less deserving than those who suffer
morbidity and/or mortality from a natural disaster. Thus, we argue
that focusing on the human agency argument misses the point. The
question should not be whether or not we condone the risk behaviors
that could lead to HIV, but whether we should tolerate avoidable
negative consequences, simply because some may disapprove of certain
human behaviors.

Because the negative consequences of HIV/AIDS are largely
preventable, by employing the same type of supports and international
collaboration as were provided to the tsunami victims, it is
irrelevant whether or not we hold the victims of the HIV/AIDS
pandemic responsible for their tragic fates. Yet, the way we have
responded to the tsunami disaster, compared to the way we have
responded to the HIV/AIDS pandemic, implies precisely this. Blameless
victims have received unprecedented international support, whereas
victims who are blamed for their own situations have received much
less support. As Ian Culbert, Director of the Canadian HIV/AIDS
Information Centre with the Canadian Public Health Association
wrote: `the global HIV/AIDS crisis is really two epidemics that fuel
each other: an epidemic of disease ravaging countries and continents
and an epidemic of stigma and discrimination.'31

As for the argument that the infrastructure for supporting those
affected by the tsunami is in place, whereas it is missing in the
cases of HIV/AIDS victims and the victims of other conditions; while
the argument may have some explanatory merit, it lacks justificatory
force. A recent example of how investing properly in health system
infrastructure could help the more efficient use of resources is
South Africa's programme for the prevention of mother to child
transmission of HIV. This treatment regimen is relatively simple, a
single dose of Nevirapine given to the mother during delivery and to
the newborn. Prior to investing in infrastructure support, less than
10% of eligible women received this intervention, however, after
improving the service delivery infrastructure, coverage increased to
over 78% in South Africa.32 The lack of infrastructure support in
developing countries certainly is a barrier that would have to be
addressed. If the international community collaborated to fight HIV
in the way it came together in response to the tsunami, the lack of
infrastructure in developing countries would be rectified. For
instance, the tremendous efforts of the United Nations in
coordinating tsunami relief required developing new infrastructure
and this was done without delay.33 This is not an insurmountable
obstacle and, based on the above reasoning, there is an ethical
imperative that it must be addressed.

Critics may reject our argument for why there is a disparity between
tsunami relief efforts and HIV/AIDS relief efforts. Perhaps, stigma,
discrimination, and/or blaming the victims are not the only reasons
for the disparity. However, this does not mean that one is justified
in accepting this disparity uncritically. We argue that there is no
morally relevant difference between the two events that could lead to
an ethically just distinction in response by the international
community. Therefore, we must pose tough questions to the
international community, and to ourselves, about how such injustice
could occur and how it can be rectified.

What happened in South East Asia was basically unpreventable. Of
course, an early warning system could have saved many lives, but the
event itself could never have been prevented. Meanwhile, HIV/AIDS is
an appalling example of a largely preventable disease with proven
effective interventions. Responses to HIV/AIDS and the tsunami are
examples of our inconsistency in responding to large-scale human
tragedies. Regarding HIV/AIDS, we shrink behind rationalisations and
fallacious reasoning, whereas in the case of the tsunami we simply
did what needed to be done out of genuine empathy.

We can find no morally relevant distinction between the tsunami
disaster and the HIV/AIDS pandemic that withstand critical
examination. Therefore, we must conclude that the international
response to HIV/AIDS (not the response to the tsunami) violates the
fundamental principles of justice and fairness. Although it is very
difficult to pinpoint exactly what is meant by the `international
response', the disparity between tsunami relief efforts and HIV/AIDS
relief efforts is so grotesque that one cannot help but be morally
outraged. If the tsunami disaster has taught us anything, it is that
the public does have an enormous capacity for generosity in the face
of human tragedy, and for pressuring governments to respond. In
conclusion, our argument does not suggest that we should spend less
money on tsunami relief. Rather, we should abandon fallacious
rationalisations when it comes to dealing with the HIV/AIDS pandemic
and do what needs to be done.

Acknowledgments

The authors would like to acknowledge the contribution of Fred
Koning, Director of Ethics Services for Providence Health Care and
Anne Drummond, Medical Writer, BC Centre for Excellence in HIV/AIDS,
for their comments on the penultimate version of this paper. The
authors would also like to acknowledge the peer reviewers and editors
of Developing World Bioethics. By incorporating their comments and
critical questions this manuscript has been significantly improved.
Thank you very much.

Footnotes
1 Reuters Foundation. 2005. Tsunami Pledges/Donations Top $10
Billion. Reuters Foundation: Alert Net 27 July. Available at:
http://www.alertnet.org/thefacts/countryprofiles/218357.htm [Accessed
17 May 2006].

2 B.S. Klapper. 2005. U.N.: Tsunami Relief Pledges Surpass $10B.
Associated Press 22 June. Available at:
http://www.wtopnews.com/index.php?nid=412sid=393828 [Accessed 17 May
2006]; L. Cruz. 2005. Governments must Make Good on Tsunami Relief
Pledges. Boston, MA: Oxfam America. Press Release, 7 January.
Available at:
http://www.oxfamamerica.org/newsandpublications/press_releases/press_r
elease.2005-01-11.9987149063 [Accessed 17 May 2006].

3 Klapper, op. cit. note 2.

4 M. Thieren. Asian Tsunami: Death-toll Addiction and its Downside.
Bull World Health Organ 2005; 83: 82.Medline, ISI

5 WWW Virtual Library-Sri Lanka. 2005. Tsunami charities enough
already: U.S. Tsunami Donations Alone have Topped $1 Billion in
Relief. NewsMax.com 1 March. Available at:
http://www.lankalibrary.com/news/charities.htm [Accessed 17 May
2006].

6 H.M. Coovadia & J. Hadingham. HIV/AIDS: Global Trends, Global
Funds and Delivery Bottlenecks. Global Health 2005; 1: 13:
doi:10.1186/1744-8603-1-13. Available at:
http://www.globalizationandhealth.com/content/1/1/13 [Accessed 1 June
2006].

7 C. Akukwe. 2005. HIV/AIDS: Looming Funding Crisis. Worldpress.org
27 July. Available at: http://www.worldpress.org

/Africa/2123.cfm
[Accessed 1 June 2006].

8 E. Carll. United Nations Coordinated Tsunami Relief Efforts,
Including Billions in Pledges. International Society for Traumatic
Stress Studies Winter. Available at:
http://www.istss.org/publications/TS/Spring05/tsunami.htm [Accessed
17 May 2006].

9 B. Barber. 2005. Worldwide Tsunami Relief Pledges Top $6b. USAID
Frontlines May. Available at:
http://www.usaid.gov/press/frontlines/fl_may05/tsunamirelief.htm
[Accessed 17 May 2006].

10 M. Wainberg. 2005. A Tsunami a Month: Canadians are Turning their
Backs on the Global Fight against HIV/AIDS, Even though the Number of
Dead and Orphaned Keeps Rising. The Ottawa Citizen 24 February: A15.

11 Carll, op. cit. note 8.

12 I. Bastian. The Tsunami of Tuberculosis. Med J Aust 2005; 182:
263-- 264.Medline, ISI

13 R. Deonandan. 2005. Why not (Cough Cough) Diarrhea? The West as a
Whole seems to Prefer the Poor of Asia to the Poor of Africa. rabble
news 19 January. Available at:
http://rabble.ca/everyones_a_critic.shtml?x=36710 [Accessed 17 May
2006].

14 Klapper, op. cit. note 2.

15 Joint United Nations Programme on HIV/AIDS (UNAIDS). 2004. 2004
Global Summary of the HIV and AIDS Epidemic in 2004. Executive
Summary. Geneva: UNAIDS. Available at:
http://www.unaids.org/bangkok2004/GAR2004_html/ExecSummary_en/ExecSumm
_00_en.htm [Accessed 3 June 2006].

16 R. Parker & P. Angleton. 2002. HIV/AIDS-related Stigma and
Discrimination: A Conceptual Framework and an Agenda for Action.
Washington, DC: The Population Council Inc. Available at:
http://www.popcouncil.org/pdfs/horizons/sdcncptlfrmwrk.pdf. [Accessed
17 May 2006].

17 D. Bangsberg. 2005. HAART-felt or HAART-less: The Benefits and
Harms of providing HAART to HIV Positive Persons in Low and Middle
Income Countries. Seminar Paper. Presented to the Canadian
Association of HIV/AIDS Research, May.

18 Canada: Office of the Prime Minister. 2005. Canada Announces
Comprehensive Tsunami Disaster Relief, Rehabilitation and
Reconstruction Assistance. Office of the Prime Minister: Ottawa, ON.
New Release, 10 January. Available at: http://www.pco-
bcp.gc.ca/default.asp?
Language=EPage=archivemartinSub=newscommuniquesDoc=news_release_200501
10_381_e.htm [Accessed 3 June 2006].

19 Wainberg, op. cit. note 10.

20 J. Boothroyd. 2004. How Ottawa has run down the Canadian Strategy
on HIV/AIDS. LIVING+ July/August: 9--11. Available at:
http://www.bcpwa.org/articles/issue_31_9-11_critical_care.pdf
[Accessed 17 May 2006].

21 KAIROS: Canadian Ecumenical Justice Initiatives. Cultivating just
Peace: KAIROS Education and Action Campaign 2004--2005. Factsheet on
HIV/AIDS. Toronto, ON: KAIROS. Available at:
http://www.kairoscanada.org/e/action/CJPFactsheeHIV.pdf [Accessed 1
June 2006].

22 Coovadia & Hadingham, op cit. note 6.

23 WWW Virtual Library-Sri Lanka, op. cit. note 5.

24 S. Nolen. 2005. While we Mourn the Losses from the Tsunami . . .
Federal Tsunami Aid hits $425 million . . . as Cash Woes Hurt African
AIDS Fight. The Globe and Mail 11 January: A1. Available at:
http://www.actupny.org/reports/tsunami.html [Accessed 17 May 2006].

25 Wainberg, op. cit. note 10.

26 World Health Organization (WHO). 2003. Treating 3 Million by 2005:
Making it Happen. The WHO Strategy. Geneva: WHO. Available at:
http://www.who.int/3by5/publications/documents/en/3by5StrategyMakingIt
Happen.pdf [Accessed 17 May 2006]; E.L. Murphy et al. Highly Active
Antiretroviral Therapy Decreases Mortality and Morbidity in Patients
with Advanced HIV Disease. Ann Intern Med 2001; 135: 17-- 26; Medline,
ISI, CSA J.T. King. Long-term HIV/AIDS Survival Estimation in the
Highly Active Antiretroviral Therapy Era. Med Decis Making 2003; 23:
9-- 20; CrossRef, Medline, ISI C. Laurent et al. Long-term Benefits of
Highly Active Antiretroviral Therapy in Senegalese HIV-1 Infected
Adults. J Acquir Immune Defic Syndr 2005; 38: 14-- 17.CrossRef,
Medline, ISI

27 J. Castilla et al. Effectiveness of Highly Active Antiretroviral
Therapy in Reducing Heterosexual Transmission of HIV. J Acquir Immune
Defic Syndr 2005; 40: 96-- 101.CrossRef, Medline, ISI

28 S. Weller & K. Davis. Condom Effectiveness in Reducing
Heterosexual HIV Transmission. Cochrane Database Syst Rev 2002; 1:
CD003255.Medline

29 D. Vlahov & B. Junge. The Role of Needle Exchange Programs in HIV
Prevention. Public Health Rep 1998; 113(Suppl 1): 75-- 80.Medline

30 Kwazulu Natal: Department of Health. Implementing Prevention of
Mother to Child Transmission of HIV (PMTCT) in Kwazulu Natal.
Unpublished data. October 24. Found in Coovadia & Hadingham, op. cit.
note 6; M.L. Newell & C. Thorne. Antiretroviral Therapy and Mother-to-
Child Transmission of HIV-1. Expert Rev Anti Infect Ther 2004; 2: 717--
732.CrossRef

31 I. Culbert. 2003. The Fight Against HIV/AIDS Must Continue.
Toronto, ON. Canadian HIV/AIDS Legal Network. Press release, 28
November 2003. Available at: http://www.aidslaw.ca/Media/press-
releases/e-press-nov0703.htm. [Accessed 3 June 2006].

32 Vlahov & Junge, op. cit. note 29.

33 Carll, op. cit. note 8.