Anti-Trafficking in Persons

Purpose

  • To describe Conservation International's ("CI") guiding principles with respect to combatting human trafficking
  • To comply with applicable U.S. Government and other applicable laws, regulations and policies prohibiting trafficking in persons by government contractors and award recipients

Policy statement and scope

CI supports the zero tolerance policy adopted by the United States government 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 prohibition of actions that facilitate trafficking in persons.  CI's work with vulnerable populations potentially exposes CI staff and partners to issues of human trafficking and forced labor. CI Staff and CI Suppliers should be particularly vigilant when contracting with local businesses who may use forced labor tactics to grow their work force.

This policy applies to all CI employees, volunteers, and agents (jointly "CI Staff") as well as CI awardees, contractors, suppliers, consultants, at any tier, as well as their employees, labor recruiters, brokers, and agents (jointly "CI Suppliers") engaged by CI for the performance of U.S. federal government contracts, awards or cooperative agreements and other applicable agreements ("Government Contract(s)").

In addition, this policy establishes a program compliant with U.S. Federal Government regulations and USAID standard provision M20, which prohibits CI, its subawardees, contractors, at any tier, or their employees, labor recruiters, brokers or other agents from the following Prohibited Activities:

  • ​Trafficking in Persons during the period of a Government Contract.
  • Procuring Commercial Sex Acts during the period of a Government Contract.
  • Using Forced Labor in the performance of a Government Contract.
  • Destroying, concealing, confiscating or otherwise denying any employee access to his or her 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 recruiters that do not comply with the labor laws of the country where recruiting takes place.
  • Charging recruitment fees to individual 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 working on a Government Contract.
  • Providing or arranging housing that fails to meet the host country housing and safety standards.
  • If required by law or contract, failing to provide an employment contract, recruitment agreement or other required work document, written in a language the employee understands, that includes details of work description, wages, work location, living accommodations (where applicable) and the content of applicable laws and regulations that prohibit trafficking in person.

​All agreements with CI Suppliers under Government Contracts will include a provision proscribing the above Prohibited Activities.

Reporting requirements and procedures

All CI Staff and CI Suppliers are required to report any trafficking-in-persons related activities or violations of this Policy to CI. Reports may be made on a confidential basis via CI's Ethics Hotline (web submission) or by calling +1 (866) 294-8674. Any CI Staff who receive such a report must immediately share all pertinent information with CI's General Counsel and Chief Compliance Officer. In addition, any CI Staff or CI Suppliers 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 help@befree.org. CI will investigate all reports of Prohibited Activities and other violations of this Policy and take appropriate action. In addition, CI's General Counsel and Chief Compliance Officer will make all required disclosures as set forth in its Compliance Plan. CI strictly prohibits retaliation against any CI staff who report Prohibited Activities or other violations of this Policy.

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.

Consequences of policy violations

Violation of this Policy or failure to comply with the Compliance Plan by CI Staff will result in disciplinary or other action, including termination, reduction in benefits or removal from U.S. Government award, contract or cooperative agreement.

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 Supplier will result in remedial action, including termination of the sub-contract or sub-award for cause with immediate effect.

Definitions

TermDefinition
AgentAny individual, including a director, an officer, an employee, authorized to act on behalf of CI or CI Suppliers
Commercial Sex ActAny sex act on account of which anything of value is given to or received by any person
EmployeeAny individual directly engaged in the performance of work under a Government Contract and who has other than a minimal impact or involvement in performance of the work
Forced LaborKnowingly 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 p​erson
Trafficking in PersonsRecruitment, 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.