Anti Human Trafficking Policy
Tropical Health – Combatting Human Trafficking Policy
This policy supersedes all previous policies related to combating trafficking in persons.
This policy describes Tropical Health’s guiding principles with respect to combating trafficking in persons.
Tropical Health is opposed to all forms of trafficking in persons and is committed to ensuring that all operations and programmes are delivered with a strong zero tolerance policy to enable staff and partners to combat human trafficking. Tropical Health is committed to being fully compliant to donor regulations as they relate to combatting human trafficking. Tropical Health understands the importance of anti-trafficking and has devoted resources to promote compliance.
This policy applies to:
- All staff, consultants, directors and partners of Tropical Health
- Tropical Health’s suppliers:
Overview of Policy
Tropical Health prohibits the following:
- Engaging in any form of human trafficking
- Engaging in any act that could be deemed to be contributing to sexual tourism which includes commercial sex acts at any time during work travel.
- Using any kind of forced labour.
- Failing to provide proof of employment or full documentation in writing prior to commencing employment with the organisation
- Provision of housing that fails to meet the host country’s housing and safety standards
- Denying access to an employee’s immigration documentation
- Using misleading, unprofessional or fraudulent recruiting practices
- Charging employee candidates recruitment fees
- Failing to pay contractually agreed return transportation costs
Tropical Health implements this policy through:
- Employee acknowledgement of receipt of the policy
- Staff training on policy content and full adherence to the policy
- Compliance plan
- Reporting any incidents through defined channels
As required by a funder or local law, country offices may edit the related resources listed at the end of this policy to ensure they are sensitive to the local context. In addition, country offices may translate the policy and any of the related resources in local languages as required.
Receipt of the Policy and Training
All Tropical Health’s staff will acknowledge receipt and understanding of this policy upon commencement of employment and annually thereafter. All employees are responsible for complying with this policy as well as completing any associated training mandated as a condition of continued employment. When engaging outside parties Tropical Health’s staff will ensure that the requirements of this policy are communicated to partners, sub-contractors, independent consultants, and service providers.
Tropical Health will make available an anti-trafficking in persons compliance plan template for written anti-trafficking compliance plans. All U.S. Government-funded sub-awards with an estimated value of US$500,000 are required to complete an anti-trafficking compliance plan. The compliance plans may be adjusted based on risk factors for trafficking due to the location, beneficiary population, complexity, size of the program, or other variable deemed appropriate and relevant.
All Tropical Health staff are required to report any suspected trafficking activity to the Head of Programmes and Operations at Tropical Health; or the Global Human Trafficking Hotline at 1-844-888-FREE or firstname.lastname@example.org.
Strict adherence to this policy is expected and any violations will result in disciplinary action that may include but is not limited to termination of employment for employees and termination of the relationship with Tropical Health non-employees.
Tropical Health prohibits any retaliation against an employee who reports any violation or who cooperates with any investigation relating to reporting a violation. There will be serious consequences for any employee who engages in any form of retaliation which could include termination of employment and reporting to local authorities as appropriate. Any supplier or supplier personnel who engage in any prohibited activities or fails to report suspicious activities will be subject to action including termination of the business relationship and reporting as appropriate.
Anti-Human Trafficking Compliance Plan – Tropical Health
In accordance with FAR 52.222-50(h), Tropical Health has developed this Anti-Human Trafficking Compliance Plan to be implemented on United States Government contracts or subcontracts, other than commercially available off-the-shelf items, acquired outside the United States or services to be performed outside the United States and has an estimated value that exceeds $500,000. The purpose of this Plan is to ensure employees, partners and sub-contractors are aware of the legal requirements to conduct under anti-trafficking regulations and laws, as well as actions that may result from violations.
This Compliance Plan may be appropriately tailored with respect to the size and complexity of the contract and to the nature and scope of the activities to be performed under its USG funding, including the number of non-U.S. citizens expected to be employed and the risk that the contract or sub-contract will involve services or supplies susceptible to trafficking in persons
3. Plan Requirements
a. Awareness Program – Tropical Health has adopted an internal policy to ensure we are combatting human trafficking, to comply with the anti-human trafficking laws and regulations of both the United Kingdom and the United States of America, and those territories in which the Company operates. This policy is also summarised in Tropical Health’s Ethics Policies. Tropical Health’s policies describe prohibited trafficking related activities and the actions that will be taken against employees for violations.
Tropical Health also includes an overview of combatting trafficking in persons in its procurement decisions in its procurement procedures and provides training to all employees with supplier delegation of authority, provides employees with general information, reporting requirements and examples of trafficking in the supply chain.
Tropical Health also periodically conducts specialised training on the procedures for ensuring we are never involved in human trafficking.
b. Process to Report – Any Tropical Health employee or consultant or third-party doing work on behalf of the Company are required to report information or knowledge of the actual or potential human trafficking violations to the Head of Programmes and Operations. The employee may also report violations privately by contacting the Global Human Trafficking Hotline at 1-844- 888-FREE or email@example.com.
Retaliation against an individual who reports a violation is strictly prohibited.
c. Recruitment and Wage Plan – Tropical Health permits only the use of recruitment companies who have trained employees, they prohibit charging recruitment fees directly to the employee and ensure that wages meet applicable host country legal framework for labour practices and provide a fair wage within minimum wage requirements. All legitimate employment practices are followed, and taxes and insurances related to their employment are covered. For all purposes, all employees will be legitimately employed.
d. Housing Plan – Tropical Health does not currently provide housing to any employee in any country but if the need arises, they confirm that they will ensure housing meets host country housing, legal and safety standards.
e. Procedures for Agents & Subcontractors – All Tropical Health partners and sub-contractors must agree to comply with Tropical Health’s Anti Human Trafficking Compliance Plan and all applicable anti-trafficking laws and regulations. Tropical Health will include FAR 52.222-50 and FAR 52.222-56 in supplier agreements where applicable.
Tropical Health’s partners and subcontractors must have procedures to prevent trafficking in persons and to monitor, detect and terminate any partnership agreements, subcontracts or subcontractor employees that have engaged in such activities.
Tropical Health will share this plan with staff and will place a copy in any company offices, and on its external website, www.trophealth.com. This Plan is also available upon request from the Head of Programmes and Operations.
After receiving an award (and annually if required), Tropical Health will certify to the Government (through its lead partners) that;
1) it has implemented a compliance plan to prevent any prohibited human trafficking activities and to monitor, detect and terminate any partner, subcontractor or consultant engaging in prohibited activities and,
2) After having conducted due diligence, to the best of Tropical Health’s knowledge and belief, neither it nor any of its partners, subcontractors or their partners, are engaged in trafficking activities; or if abuses related to any of the prohibited trafficking activities have been found, Tropical Health or its subcontractor has taken the appropriate remedial and referral actions.
- K. Modern Slavery Act 2015: http://www.legislation.gov.uk/ukpga/2015/30/contents/enacted
- USAID ADS 303:https://www.usaid.gov/sites/default/files/documents/1868/303maa.pdf
- USAID Counter Trafficking in Persons Field Guide: https://www.usaid.gov/sites/default/files/documents/2496/C-TIP_Field_Guide_Final_April%205%202013.pdf