Pact prohibits global employees, consultants, independent contractors, agents and volunteers (“workers”), subrecipient staff, visitors, or third parties working with Pact from engaging in any form of human trafficking or forced labor. Pact is committed to protecting workers and responding promptly and appropriately to any allegations of trafficking incidents. We recognize that Pact works in environments that can be high-risk for trafficking and worker exploitation. This plan establishes Pact’s procedures for preventing human trafficking through awareness, reporting, recruitment and wage plans, housing plans, subaward compliance, and investigations.
Pact’s resources related to combatting human trafficking and worker exploitation – our Policy, Compliance Plan, Compliance Checklist and related materials – are readily available on Mosaic (our intranet platform) for staff use and reference. All Pact employees are required to become aware of the Human Trafficking and Worker Exploitation Policy upon hire through Pact’s Code of Conduct, which is provided to all staff and accessible at any time on Pact’s intranet. Pact conducts compliance training for all staff. This training certifies that staff understand trafficking issues and agree to comply with the policies, procedures, and principles of Pact’s Human Trafficking and Worker Exploitation Policy, including their reporting obligations of any known violations.
All Pact Workers and subrecipients must report any suspicions or allegations of human trafficking or non-compliance with the Human Trafficking and Worker Exploitation Policy to Pact’s Ethics & Compliance Office, Global HR, or Pact’s reporting mechanism EthicsPoint.
Reports may also be made through the Global Human Trafficking Hotline via telephone (1-844-888-FREE) or e-mail (firstname.lastname@example.org). If Pact employees report incidents to these outside sources, they should also report internally at Pact so that appropriate action can be taken to address the incident for the organization.
Recruitment and Wage Plan
In all hiring practices…
- Pact abides by local labor laws.
- Pact workers are prohibited from charging recruitment fees to any candidate as a condition of their prospective employment at Pact.
- Pact workers should not solicit any candidate for purposes of employment using false or fraudulent pretenses, representations, or promises regarding that employment.
- Pact workers are prohibited from keeping, concealing, or destroying an employee’s identity or immigration documents.
To the extent that Pact uses recruitment companies, only recruitment companies with trained employees may be used, no recruitment fees may be charged to employees, and all wages must meet applicable cooperating country legal requirements.
Pact ensures that housing provided directly or through third-party entities for all staff or certified subrecipient staff meets host country housing and safety standards. No staff member should be provided housing in lieu of wages.
Pact workers must ensure that if transportation is offered to a staff member to work in an out-of-country work location, Pact or a subrecipient will provide transportation back to their home country at the end of the employment period. A staff member who refuses to return home because they want to seek survivor services or legal redress in the host country is exempt from this requirement.
Assessing Risks at the Project Level
Pact Country Directors (CDs) (or equivalent) are responsible for identifying, mitigating, and monitoring specific trafficking risks in their programs related to programming and country challenges. This includes, but is not limited to, conducting due diligence and certification requirements on subrecipients and vendors to ensure that Pact is not using organizations, vendors, suppliers or other third parties involved in human trafficking activities. If any subrecipient or vendor seems like a high-risk third party, the Country Office should work with the Ethics & Compliance Office (email@example.com) to determine any additional compliance measures that should be implemented.
Pact must include all applicable anti-trafficking requirements in our award documents to subawardees and subcontractors. Subrecipients who fail to comply with the requirements of Pact’s Human Trafficking and Worker Exploitation Policy or compliance plan risk could result in immediate termination of their subaward with Pact.
Specific Obligations for USG Projects
CDs must keep in mind that in U.S. Government-funded awards with an estimated value that exceeds $500,000, they are required to annually certify to USAID that they have implemented a compliance plan and are not engaged in any trafficking-related activities. Likewise, USAID subrecipients and subcontractors with a subaward or subcontract value that exceeds $500,000 are required to annually certify to Pact that they have implemented a compliance plan and are not engaged in any trafficking-related activities.
CDs may delegate responsibilities, as appropriate, to members of their team, a Chief of Party, or other responsible senior manager, but the CD holds final responsibility to ensure that human trafficking is regularly prevented in their programs.
Questions regarding Pact’s Human Trafficking and Worker Exploitation Policy and this compliance plan may be directed to your Country Director or Pact’s Ethics & Compliance Office.