Effective Date: June 2022
This policy supersedes all previous policies related to combating trafficking in persons.
- Human trafficking: The act of trapping people using violence, deception, or coercion and exploiting them for personal and/or financial gain. Human trafficking is a form of modern-day slavery.
- Forced labor: Work that is performed involuntarily and with threat of penalty. Examples of penalties are threats of violence, intimidation, manipulation, debt, removal of identification papers, or threat of exposure to immigration authorities.
- Modern-day slavery: Severe exploitation of other people for personal or financial gain.
- Worker exploitation: The abuse of people in the workplace for profit. Can include wage deductions, wages and personal paperwork controlled by another person, being forced to work long hours without breaks, being subjected to poor or unsafe working conditions.
- Debt bondage: When a person is forced to work to pay off a debt. The person is tricked into working for little or no pay, with little or no control over their debt amount. Money earned is used to pay for their loan, which means that the value of their work becomes greater than the original sum of money borrowed.
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. The purpose of this policy is to ensure that (1) all participants in Pact’s programs and Pact workers are safe and not exposed to any threat or acts of human trafficking, and that (2) Pact does not work with other organizations, vendors or suppliers who may be involved in human trafficking.
This policy applies to all global employees, consultants, independent contractors, agents, and volunteers (“Workers”) and subrecipient staff.
“Human trafficking,” “worker exploitation,” and “modern-day slavery” are terms used to describe situations where one person is exploited by another person for profit. The person or child may be compelled to perform labor or engage in a commercial sex act. These are broad terms that cover many types of exploitation that use force, fraud, coercion, deception, or abuse of power.
Human trafficking involves three elements: 1) the perpetrator’s actions to obtain or maintain labor; 2) using force, fraud, or coercion over the victim; and 3) for purpose of taking advantage of the victim.
The use of force, fraud, or coercion over a victim may include preventing a victim from controlling their own freedom, safety, personal documents, working and living conditions, and wages. If a worker does not have control over any of these areas, it is a potential sign of trafficking or exploitation.
Examples of forced labor can include situations where a worker is paid less than promised, does not receive pay, does not have access to their identification documents, or has no control over their money.
In addition to human trafficking as defined above, actions that directly support or advance trafficking are prohibited. Such actions include, but are not limited to:
- Procuring a commercial sex act
- Destroying, hiding, taking, or denying an employee access to their identity or immigration documents
- Offering employment under false pretenses
- Charging employees recruitment fees
- Providing wages and benefits that do not meet local legally required minimum standards
- Providing housing that does not meet local housing and safety standards
- Failing to provide transportation to an employee working outside of the country from which they were recruited upon the end of employment.
All Pact Workers and subrecipients must report any suspicions or allegations of human trafficking or non-compliance with this Policy to Pact’s Chief Ethics and Compliance Officer, 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.
Training and Awareness
All Pact employees are required to become aware of this policy upon hire through Pact’s Code of Conduct, which is provided to all staff and accessible at any time on Pact’s intranet. The Code of Conduct Manual and associated training include an overview of this policy and are required for all staff. In addition, training specific to this policy is conducted on a regular cadence and is mandatory for all employees.
Subaward and Contractor Obligations
Pact must include the applicable prevention of human trafficking terms in all subawards and contracts. A subawardee’s or contractor’s failure to comply with the requirements may result in the termination of the subaward or contract (including subcontracts).
Pact Human Resources
Pact has a Global Anti-Trafficking Compliance Plan that outlines how Pact operationalizes the requirements in this policy, providing specific instructions on the appropriate implementation of recruitment and wage plans and non-salary benefits so that Pact does not engage in any acts that could be perceived as human trafficking.
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.
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 trafficking and exploitation is regularly prevented in their programs.
Violation of this policy constitutes an act of serious misconduct and is grounds for disciplinary action, including termination of employment and referral to law enforcement.
Pact prohibits retaliation against any employee who reports any violation of this policy or who cooperates with any investigation of such reports. Employees who engage in any retaliation or other violation will be subject to corrective action up to and including termination of employment and reporting to local authorities as appropriate. For more information, see the Non-Retaliation Policy.
Any vendor/subrecipient or vendor/subrecipient personnel who engages in any prohibited activities, fails to report suspicious activities, or engages in retaliatory actions will be subject to action including termination of the business relationship, and reporting as appropriate.