In sentencing for child exploitation offences committed by facilitators rather than perpetrators, a notional starting point close to the maximum penalty may be justified where there is a gross breach of trust by a family member who assumed an obligation of care, and where the facilitation objectively placed the child at risk of more serious harm. General deterrence and child protection are the paramount considerations in such cases, outweighing the offender's personal disadvantages, vulnerability, and manipulation by the co-offender. The absence of sexual motivation on the part of the facilitator is of limited relevance where the facilitator contemplated that the offending would enable the co-accused's sexual gratification.
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