Singapore - economically developed and wealthy like Hong Kong - has almost no legislation for its 201,000 domestic helpers. Rest days, salaries, and daily work hours are all left up to negotiations with the employer. Public holidays do not have to be granted. Consequently, some helpers take only one or two days off a month, according to the Coalition for Migrant Workers. Singapore also does not allow helpers to get the right of abode after a set number of years.

At the other extreme is Canada. Its 35,000 live-in caregivers get paid the same minimum wage as Canadian citizens and can apply for permanent residency after two years. Even before that, they're covered by the same labour laws as Canadians, ensuring paid public holidays, annual leave and even overtime.

Italy is another attractive location for helpers, as most employers pay up to double the minimum wage, said Rhacel Parrenas, a labour and migration expert and professor at the University of Southern California. Most helpers get two days off a week and a 13th month of pay each year. And they can get residence after five years. However, residency is not guaranteed; helpers have to establish a savings account and show educational development, among other requirements.

In some respects, Hong Kong is at the progressive end of foreign workers' rights. Around the world, some 23.6 million domestic workers, 45 per cent of the globe's total, have no entitlement to a weekly rest day, according to an International Labour Organisation policy brief published this year. On the other hand, 52 per cent of helpers worldwide earn the same minimum wage as other workers in their countries, the ILO says. They don't in Hong Kong.

Still, no country will have a truly fair system until an ILO treaty on domestic helpers' rights, passed in June by 396 votes to 16, is ratified by all its member states, said Aaron Ceradoy, of the Asia Pacific Mission for Migrants. China has signed the convention and has the power to extend its reach to Hong Kong.

'We cannot really say that any country is better than another country right now,' Ceradoy said. 'The fact that no country has ratified it yet is already proof that ... the labour standards that are being followed for domestic workers are not really on par with the international standard for all workers.'

It's an opinion echoed by Amy Sim, an assistant professor in sociology at the University of Hong Kong. 'We basically don't have a model system,' she said.

In most of the world, domestic helpers' rights were perceived differently, Sim said. 'We still have this class system that means that some people are still less human than the rest of us in terms of their rights - to job mobility, to security, to livelihood,' she said.

Certain Middle Eastern countries have a particularly poor reputation on helpers' rights. Kuwait was the second largest importer of Filipino domestic labour after Hong Kong last year, the Philippine government said. But Human Rights Watch says that employers keep their helpers under their thumb by easily reporting them as 'absconding' - thus getting them deported - if they run away from physical or sexual abuse.

And Saudi Arabia stopped receiving domestic helpers from Indonesia and the Philippines in July after furores over the beheading of an Indonesian helper for stabbing to death her employer and a refusal to guarantee better pay for Filipinos.

$10.25

The hourly rate, in Canadian dollars (HK$78) , that domestic helpers are paid in Ontario, the same minimum wage as the country's citizens