I can answer the question with respect to the New Zealand model.
The Prostitution Law Review Committee recognized, when it reviewed the success of the plan, that exploitative working conditions were long-standing in the industry and that decriminalization made no significant difference to the working conditions for women in prostitution. Nonetheless, the committee decided not to interfere, leaving the matter to be one of negotiation between the women and the brothel itself.
The committee decided not to recommend that women in prostitution be granted employment rights. The committee recognized that most women in prostitution were independent contractors. Under their system, as I understand it—and this is something that's beyond your jurisdiction, obviously—they have an employment relations authority that is roughly equivalent to the employment standards plus an industrial tribunal. The remedies there are not available to independent contractors.
In fact, the only provision that those authorities have is that they can provide a dispute resolution. It's a voluntary process, so a woman in prostitution would have to go to the authority to say she is actually an employee and convince them that she's an employee; then she'll get benefits. Otherwise, she's an independent contractor with no rights.