Anti-Trafficking in Persons

Purpose and introduction

This Policy describes Conservation International's guiding principles with respect to combatting human trafficking.

Conservation International (CI) supports a zero-tolerance policy to combat human trafficking and forced labor. We are committed to high standards of ethics and integrity and compliance with all applicable local laws across our global operations, including the prohibition of actions that facilitate trafficking in persons. CI's work with vulnerable populations potentially exposes CI Staff and Delivery Partners to issues of human trafficking and forced labor. CI Staff and CI Delivery Partners should be particularly vigilant when contracting with local businesses that may use forced labor tactics to grow their workforce.

This policy expands on CI's Code of Conduct, which outlines ethical standards and acceptable behavior applicable to CI operations and complements CI's Child Protection and Safeguarding Policy and Prevention of Sexual Exploitation and Abuse Policy (PSEAH). This policy should be read and applied with CI's Safeguards System (CISS) to avoid or minimize adverse environmental and social impacts, and to enhance positive impacts to the maximum extent possible in our projects.


This Policy applies to all CI employees, interns, fellows, volunteers, and representatives (jointly, "CI Staff"), as well as CI grantees/awardees, contractors, suppliers, consultants, and their employees, sub-grantees/awardees, and representatives (jointly, "Delivery Partners") engaged by CI, including for the performance of U.S. federal government contracts, awards or cooperative agreements and other applicable agreements.

Prohibited activities

CI prohibits all CI Staff and Delivery Partners to engage in the following:

  • Trafficking in persons.
  • Procuring commercial sex acts that may be directly associated with CI, including but not limited to during work hours, while attending work-related off-site functions, and at any time while in work travel status.
  • Using forced labor.
  • Destroying, concealing, confiscating, or otherwise denying any employee access to their identity or immigration documents, such as a passport or driver's license.
  • Using misleading or fraudulent recruiting practices during the recruitment of employees or offering of employment to employees, such as failing to disclose (in a format and language accessible to the employee) or making material misrepresentations about the key terms and conditions of employment, including wage and benefits, work location, living conditions, housing and associated costs (if provided for by Conservation International), significant costs to be charged to the employee and hazardous nature of the work (if applicable).
  • Using recruiting or staffing agencies that do not comply with the labor laws of the country where the recruitment of the employee takes place.
  • Charging recruitment or placement fees to prospective employees.
  • Failing to provide or pay the cost of return transportation at the end of employment for an employee who is not a national of the country where the work took place and who was sent to that country for purposes of CI business.
  • Providing or arranging housing that fails to meet the host country's housing and safety standards.
  • If required by law or contract, failing to provide an employment contract, recruitment agreement, or other required work documents, written in a language the employee understands, that includes details of the work description, wages, work location, living accommodations (if applicable) and the content of applicable laws and regulations that prohibit trafficking in person.

Applicable agreements with CI Delivery Partners will include a provision proscribing the above Prohibited Activities.

Reporting requirements and procedures

All CI Staff and Delivery Partners are required to report any trafficking in persons-related concerns, activities, or violations to CI. Individuals may report concerns on a confidential basis via CI's online Ethics Hotline or by calling +1 (866) 294-8674. All CI Staff who receive a report or hear a concern from another individual must immediately share all pertinent information with CI's General Counsel and Chief Compliance Officer. Project-level grievance mechanisms will be designed to be community friendly and any related reports immediately elevated to CI's Global Grievance Committee. In addition, any CI Staff or CI Delivery Partner staff who believe that they or others have been subjected to Prohibited Activities may submit a report as outlined above or may contact the Global Human Trafficking Hotline at 1-844-888-FREE or via its email address at CI will promptly and thoroughly investigate all complaints in accordance with established investigation procedures. Every effort will be made to protect the privacy of all complainants, reporters, and subjects of a complaint. Delivery Partners shall cooperate and ensure the cooperation of persons and entities (under their control) with CI and CI-designated parties in any child abuse-related investigation. Retaliation against any individual who submits a report in good faith is strictly prohibited in accordance with CI's Conflict Resolution and Formal Complaints Policy.

CI's General Counsel and Chief Compliance Officer will make all required disclosures as outlined in its Compliance Plan. As required under applicable donor policies and regulations, CI will report allegations or suspicions of child abuse to donors and cooperate with donor investigations. As appropriate and with the expressed desire of the victim, CI will make reports to state agencies with authority over the criminal prosecution of child abuse offenses.

Consequences of policy violations

If an investigation confirms that a policy violation by CI Staff has occurred, CI will take disciplinary action, up to and including termination as appropriate in accordance with its policies and applicable law. Violation of this Policy, failure to comply with the applicable contractual language in the CI sub-contract or CI sub-award, or applicable Compliance Plan by a CI Delivery Partner will result in remedial action, including termination of the sub-contract or sub-award for cause with immediate effect and disqualification from future contracts or grants with CI.

Compliance plan

Conservation International maintains a written anti-trafficking compliance plan​ for U.S. Government (sub-)contracts and (sub-)awards with an estimated value in excess of $500,000 that are for supplies to be acquired or services to be performed outside of the United States (jointly "Covered Agreements"). Sub-contractors and sub-awardees of Covered Agreements will be required to implement and submit a copy of their compliance plan to prevent the Prohibited Activities.


  • Commercial Sex Act: Any sex act on account of which anything of value is given to or received by any person
  • CISS - CI Safeguard System: System of policies, standards, and procedures for the screening, due diligence, mitigation, monitoring, and reporting of environmental and social risks and impacts. The purpose is to provide CI staff and Project Teams with procedures to avoid (or minimize) adverse environmental and social impacts and to enhance positive impacts to the maximum extent possible throughout the project cycle.
  • Forced Labor: Knowingly providing or obtaining the labor or services of a person by express or implied threats of serious harm to, or physical restraint against, that person, their family member, or another person
  • Recruitment/Placement Fee: Fees of any type that are associated with the recruiting process, regardless of the time, manner, or location of imposition of the fee. Examples of prohibited recruitment/placement fees include fees that are associated with the recruiting process for interviewing, referrals, skills testing, or placing employees or potential employees; obtaining labor certifications or visas; required medical examinations and immunizations; background checks; an employer's recruiters' or attorneys' fees.
  • Trafficking in Persons: Recruitment, transportation, transfer, harboring, or receipt of persons, by means of the threat or use of force or other forms of coercion, of abduction, of fraud, of deception, of the abuse of power or of a position of vulnerability or of the giving or receiving of payments or benefits to achieve the consent of a person having control over another person, for the purpose of exploitation. Exploitation shall include, at a minimum, the exploitation of the prostitution of others or other forms of sexual exploitation, forced labor or services, slavery or practices similar to slavery, servitude, or the removal of organs.

Roles and responsibilities

General Counsel and Compliance
  • Advise on legal issues related to trafficking in persons
  • Handle any referrals to competent local authorities or third parties
  • Advise on investigation and/or disciplinary process for any suspected or confirmed breaches of this policy
  • Advise on the best ways to protect people who report concerns
  • Manage related investigations in coordination with CI People Operations
  • Ensure accessible and confidential helpline is available
  • Ensure CI Staff and Delivery Partners are held accountable for violations of the policy
CI People Operations
  • Ensure all prospective staff are aware of this policy and document and collect policy acknowledgment forms
  • Ensure all staff are trained on the policy
  • Advise on the best ways to protect people who report concerns
  • Manage related investigations in coordination with General Counsel
Project Delivery and Monitoring
  • Ensure all projects that undergo CISS screening identify possible trafficking in persons risks during the proposal stage and design appropriate actions to mitigate risks.
  • Provide technical guidance and counsel in the development of projects aligned with this policy
  • Ensure that the implementation and monitoring of identified mitigation actions are in compliance and budgeted for through safeguard monitoring.
Project Managers
  • Promote awareness and understanding of the policy and all Prohibited Activities among CI Staff and Delivery Partners
  • Ensure that the project has been screened for risk via the CISS screening form
  • Incorporate risk mitigation measures in planning, monitoring, budgeting, and resource allocation as needed and commensurate to risk level/scope.
  • Support monitoring and compliance with the policy as needed
  • Support continual training and awareness-building efforts during the project life cycle
All CI Staff and Delivery Partners
  • Understand, advocate, and apply the policy to their work
  • Report any suspected breaches of this policy
  • Cooperate with any investigations into suspected breaches of this policy