Anti-Trafficking Policy

CALL FOR DUTY Anti-Trafficking Policy

1. Purpose
Consistent with its mission to alleviate poverty, suffering, and oppression, CALL FOR DUTY is committed to a work environment and operations that are free from human trafficking and exploitation. Human trafficking and exploitation are wholly contrary to CALL FOR DUTY mission. CALL FOR DUTY will not allow human trafficking or slavery in any part of our global organization or with any of our partners. This policy sets forth the expectations we have of our team members to avoid engagement of, complicity in, or benefiting from human trafficking.

2. Scope of Policy
This policy applies to: CALL FOR DUTY UK and CALL FOR DUTY world, their subsidiaries and affiliated organizations (collectively “Call For Duty”); Members of Call For Duty’ Boards of Directors, officers, management, Team Members, seconded employees, interns, and volunteers (collectively “Team Members”); and Subrecipients, partner organizations, contractors, outside experts (including attorneys), consultants, agents, representatives, and any other organization or individual that acts on Call For Duty’ behalf, at Call For Duty’s direction or with CALL FOR DUTY funding (collectively “Partners”).

3. Policy Statements
3.1. It is the policy of CALL FOR DUTY to comply with laws and regulations prohibiting trafficking in persons. CALL FOR DUTY Team Members and Partners must avoid and are prohibited from active engagement, complicity in or benefiting from any practice that constitutes trafficking in persons. The consent of a victim of trafficking is irrelevant.

3.2. “Trafficking in persons” means the recruitment, transportation (including failure to provide return 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” includes, 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. The recruitment, transportation, transfer, harboring or receipt of someone under the age of 18 for the purpose of exploitation is considered “trafficking in persons”.

3.3. Examples of Team Member or Partner conduct that would violate this policy because it contributes to trafficking in persons include (but are not limited to):

• Procuring commercial sex acts;

• Using forced labor in the performance of any contract, cooperative agreement or award;

• Destroying, concealing, confiscating, or otherwise denying any employee access to his or her identity or immigration documents, such as passports or drivers’ licenses;

• Using misleading or fraudulent recruiting practices during the recruitment of employees or offering of employment/contract positions; such as failing to disclose, in a format and language accessible to the potential candidate, basic information or making material misrepresentations during the recruitment of candidates regarding the key terms and conditions, including wages and fringe benefits, the location of work, the living conditions, housing and associated costs (if provided by Call For Duty), any significant cost to be charged to the candidate, and, if applicable, the hazardous nature of the work;

• Using recruiters that do not comply with local labor laws of the country in which the recruiting takes place;

• Charging applicants/candidates/employees recruitment fees;

• If required by law or contract, failing to provide a return
transportation or failing to pay for the cost of return transportation upon the end of employment;

• If required by law or contract, failing to provide or arrange housing that meets the host country housing and safety standards; or

• If required by law or contract, failing to provide an employment contract, recruitment agreement, or other required work documents in writing.

3.4. Employees who violate this policy will be subject to discipline, up to termination, and may be subject to criminal prosecution. Partners may have their agreements terminated, be prohibited from working with CALL FOR DUTY in the future and/or be subject to criminal prosecution.

3.5. Team Members and Partners must immediately report violations or suspected violations to CALL FOR DUTY Integrity Hotline in accordance with CALL FOR DUTY Ethics Complaint and Whistleblower Policy. CALL FOR DUTY will not tolerate any form of retaliation against Team Members and Partners who report suspected violations of this policy in good faith.

3.6. CALL FOR DUTY will report Trafficking in Persons to the appropriate authorities and to the donor as required by its donors or by law, or, if not required, as CALL FOR DUTY determines 3.3. Examples of Team Member or Partner conduct that would violate this policy because it contributes to trafficking in persons include (but are not limited to):
• Procuring commercial sex acts;
• Using forced labor in the performance of any contract, cooperative agreement or award;
• Destroying, concealing, confiscating, or otherwise denying any employee access to his or her identity or immigration documents, such as passports or drivers’ licenses;
• Using misleading or fraudulent recruiting practices during the recruitment of employees or offering of employment/contract positions; such as failing to disclose, in a format and language accessible to the potential candidate, basic information or making material misrepresentations during the recruitment of candidates regarding the key terms and conditions, including wages and fringe benefits, the location of work, the living conditions, housing and associated costs (if provided by Call For Duty), any significant cost to be charged to the candidate, and, if applicable, the hazardous nature of the work;
• Using recruiters that do not comply with local labor laws of the country in which the recruiting takes place;
• Charging applicants/candidates/employees recruitment fees;
• If required by law or contract, failing to provide return transportation or failing to pay for the cost of return transportation upon the end of employment;
• If required by law or contract, failing to provide or arrange housing that meets the host country housing and safety standards; or
• If required by law or contract, failing to provide an employment contract, recruitment agreement, or affiliated in writing.
3.4. Employees who violate this policy will be subject to discipline, up to termination, and may be subject to criminal prosecution. Partners may have their agreements terminated, be prohibited from working with CALL FOR DUTY in the future and/or be subject to criminal prosecution.
3.5. Team Members and Partners must immediately report violations or suspected violations to CALL FOR DUTY Integrity Hotline in accordance with CALL FOR DUTY Ethics Complaint and Whistleblower Policy. CALL FOR DUTY will not tolerate any form of retaliation against Team Members and Partners who report suspected violations of this policy in good faith.
3.6. CALL FOR DUTY will report Trafficking in Persons to the appropriate authorities and to the donor as required by its donors or by law, or, if not required, as CALL FOR DUTY determines

4. Processes and Procedures Required to Ensure Compliance

4.1. All Team Members will be trained on the contents of this policy via Call For Duty’s mandatory Code of Conduct training.

4.2. All CALL FOR DUTY offices will display the CALL FOR DUTY Anti-Trafficking Policy posters, translated into the primary language of the office, in conspicuous locations where all staff will see them.

4.3. All CALL FOR DUTY agreements with Partners will include a clause that requires the Partner to adhere to the substance of this policy and to communicate this policy to their staff.

4.4. Country Directors or other responsible Senior Leadership are required to report all suspected violations of this policy to the Ethics Team in the Legal Department, which will follow up and respond in accordance with Call For Duty’s Ethics Complaint and Whistleblower Policy. Anyone at any time can report suspected violations of this policy directly to the Ethics Team:

5. Policy Administration
Responsibility for ensuring this policy is monitored, enforced, and remains up-to-date and compliant rests with Call For Duty’s Legal Department and General Counsel.

6. Approved Policy
This policy was approved by the CALL FOR DUTY Board of Directors on March 7, 2018, and CALL FOR DUTY Europe Board of Directors on July 31, 2018. This policy may only be amended or changed with the approval of the Board(s).

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