The Ferienjob program offers short-term employment opportunities for Indonesian students in Germany during academic breaks. However, its implementation has triggered serious issues related to manipulative recruitment, irregular placement procedures, debt bondage, and exploitative working conditions. However, legal studies examining in-depth whether the Ferienjob practice meets the elements of human trafficking (TPPO) as stipulated in Law Number 21 of 2007 are still very limited. This study aims to analyze the fulfillment of the legal elements of TPPO in the program and evaluate institutional governance during its implementation. By combining a normative juridical approach and case studies, this research utilizes primary and secondary legal materials, as well as public documents related to the Ferienjob case. The analysis focuses on three main elements of TPPO under Indonesian law: process, method, and exploitation. The study results indicate that the implementation of Ferienjob for Indonesian students has met all three elements. The process element is evident in the structured recruitment of 1,047 students from 33 universities and their placement in Germany. The method element is evident through fraud, debt bondage, and exploitation of victims' vulnerabilities. Meanwhile, elements of exploitation are reflected in harsh working conditions, wage cuts, and facts on the ground that are far from the initial promises. This research also found weak oversight and coordination between institutions in monitoring student recruitment. Based on the available evidence and the framework of Law No. 21/2007, this study concludes that the practice of Ferienjob can be legally qualified as human trafficking (TPPO). These findings expand the legal literature on human trafficking hidden within official mechanisms and emphasize the importance of tightening regulations on recruitment agencies, conducting due diligence by universities, and strengthening cross-border protection.
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