I don't know what I think
Consent gained under deception makes it rape but it wasn't the men she gave BJs to who deceived her.
I wouldn't assume the men were significantly less drunk.
I've seen a few seconds of the video on my FB feed. She is pulling dicks out of mens pants and sucking on them. Maybe if I'd watched the whole thing then I would have seen men putting their dicks in her mouth but I didn't. If a drunk person stuck his head up my skirt and gave me oral then I would think I was the victim, not them.
Surely it's illegal to perform a sex act in public (which would lead to her and the men being prosecuted)
Is it illegal to 'goad' people into doing things like this, especially when they are drunk? If it's criminal then does it fall under a conspiracy law or maybe prostitution/pimping.
I would think a 'prize switch' would be illegal in general but there was unlikely to be any written T&Cs and I imagine the rep would get off with an "I was only kidding" defence.
I think it would be worth investigating the holiday company to see if it is a company policy or a rouge rep. (I suspect the former)