Anti-Trafficking Policy and Compliance Plan

1. Purpose

This Global Communities Policy Prohibiting Trafficking in Persons (the “Policy”) establishes a zero-tolerance approach to human trafficking, ensuring ethical operations that protect human rights and dignity. It provides a model framework for organizations to prevent, detect, and respond to trafficking risks, supporting sustainable and inclusive community development worldwide.

2. Scope

This Policy applies to all employees, contractors, subcontractors, agents, partners, and third parties engaged with the organization, across all operational regions and activities.

3. Policy Statement

The organization prohibits all forms of trafficking in persons, including forced labour, sexual exploitation, and slavery-like practices. We comply with applicable national laws (e.g., Tanzania’s Anti-Trafficking in Persons Act, 2008) and international frameworks (e.g., UN Palermo Protocol, ILO Conventions). Violations will result in disciplinary action, contract termination, and legal reporting.

4. Legal Framework

• National Laws: Compliance with local anti-trafficking legislation (e.g., Tanzania’s 2008 Act).
• International Standards: Adherence to the UN Protocol to Prevent, Suppress and Punish Trafficking in Persons, ILO Forced Labour Convention (No. 29), and U.S. FAR 52.222-50 (if applicable).

5. Definitions

• Trafficking in Persons: Recruitment, transportation, or harboring of individuals through force, fraud, or coercion for exploitation.
• Exploitation: Includes forced labor, sexual servitude, or slavery.

6. Core Principles

• Zero Tolerance: No involvement in or facilitation of trafficking activities.
• Prohibited Practices:
  • Engaging in forced labor or exploitative recruitment.
  • Withholding wages, documents, or freedom of movement.
  • Charging recruitment fees leading to debt bondage.
• Victim Support: Commitment to identify and assist trafficking victims.
• Third-Party Compliance: Partners must align with this Policy.

7. Model Compliance Plan
   • Risk Assessment

• Conduct periodic trafficking risk assessments across operations and supply chains.
  • Due Diligence
• Screen all partners and contractors for anti-trafficking compliance before engagement.
• Include anti-trafficking clauses in contracts.
  • Training
• Mandate annual anti-trafficking training for all staff and key partners.
• Provide awareness programs for communities and stakeholders.
  • Monitoring
• Appoint an Anti-Trafficking Compliance Officer (ATCO) to oversee implementation.
• Perform regular audits of operations and third-party activities.
  • Reporting
• Establish a confidential reporting mechanism (e.g., hotline) for trafficking concerns.
• Protect whistleblowers from retaliation.
• Investigate reports promptly and document outcomes.
  • Remediation
• Terminate relationships with violators and report to authorities.
• Assist victims with access to support services (e.g., shelters, legal aid).

8. Responsibilities

• Leadership: Promote a trafficking-free culture and resource enforcement.
• Staff/Partners: Comply with the Policy and report violations.
• ATCO: Monitor compliance, train staff, and manage investigations.

9. Consequences

• Internal: Disciplinary action, up to termination, for staff violations.
• External: Termination of contracts with non-compliant partners.
• Legal: Cooperation with authorities for prosecution (e.g., penalties under Tanzanian law: up to 20 years imprisonment).

10. Community Commitment

• Educate communities on trafficking risks and rights.
• Collaborate with NGOs and governments to strengthen anti-trafficking efforts.

11. Review

Review the Policy and Compliance Plan annually to ensure relevance and effectiveness.

12. Global Vision

This model upholds trust with stakeholders, fostering thriving, empowered communities free from exploitation, in alignment with global human rights and development goals.