91ÉçÇø Combating Trafficking in Persons Policy
As recipients of US government funding, the US government policy prohibits 91ÉçÇø, its employees, consultants, subrecipients, and subcontractors from:
- Engaging in severe forms of trafficking in persons while working on a program or project sponsored by the US government. This means:
- Sex trafficking in which a commercial sex act is induced by force, fraud, or coercion, or in which the person induced to perform the act is under 18 years of age; or
- Recruiting, transporting, or harboring a person for labor or services through the use of force, fraud, or coercion for the purposes of involuntary servitude, peonage, debt bondage, or slavery.
- Procuring commercial sex acts during the contract period
- Using forced labor in performing the contract
- Destroying, concealing, confiscating, or otherwise denying access by an employee to the employee’s identity papers or immigration documents, such as passports, identification cards, or drivers’ licenses
- Use of deceptive or unlawful employment strategies, including:
- Failing to disclose to the employee in a format and language that he or she understands:
- Terms and conditions of employment, including wages and fringe benefits
- The location of work
- The living conditions, housing, and associated costs
- Any significant costs to be charged
- If applicable, the hazardous nature of the work
- Using recruiters who do not comply with local labor laws of the country in which the recruiting takes place
- Failing to disclose to the employee in a format and language that he or she understands:
- Charging employees recruitment fees
All 91ÉçÇø personnel, suppliers, and supplier personnel are required to report any suspected trafficking-related activity or violation of this policy to 91ÉçÇø.
91ÉçÇø employees are strongly encouraged to report any violation of this policy directly to the 91ÉçÇø chief financial officer/vice president (CFO/VP) and/or chief human resources and administrative officer (CHRAO) as both an effective and expeditious means of addressing the required reporting of potential violations. In addition and in the case of suppliers/contractors and their personnel, as well as 91ÉçÇø employees, reports may be made to any 91ÉçÇø supervisor, senior country office management (which includes country directors or project chief of party), or headquarters human resources representative. Any 91ÉçÇø supervisor, member of senior country office management, or headquarters human resources representative who receives such a report is required to immediately forward the report to the 91ÉçÇø CFO/VP and CHRAO. Supplier personnel who believe they or others have been subjected to prohibited trafficking-related activities may report the activity as outlined above. Reports may be also be made via 91ÉçÇø’s anonymous compliance hotline online at , by email to jhpiego@integritycounts.ca, or by phone:
US: (1-866) 921-6714
Philippines: 00-800-2002-0033
India: 0008001007980
Indonesia PT Indosat: 0018030208158
Indonesia PT Telkom: 0078030208158
For all other countries, contact the international operator, ask to place a collect call to 001-604-922-5953, then ask for a whistleblower agent.
Human resources will investigate all reports of prohibited trafficking-related activity or violations of this policy and take appropriate action. The Office of the CFO/VP will make all required notifications to government agencies, as more fully set out in this compliance plan.
91ÉçÇø strictly prohibits retaliation against any 91ÉçÇø employee who reports prohibited trafficking-related activity or other violations of this policy, or who cooperates with any internal or government investigations of such reports. Employees may do so without fear of reprisal. 91ÉçÇø personnel who engage in any form of retaliation against those who report prohibited trafficking-related activities or other violations of this policy are subject to disciplinary action, up to and including termination of employment with 91ÉçÇø.
91ÉçÇø Antitrafficking Compliance Plan
91ÉçÇø has developed an Antitrafficking Compliance Plan in accordance with the US government’s zero-tolerance policy regarding trafficking in persons by government contractors and award recipients. Download the complete plan here. Additional information on trafficking may be found at the Department of State’s Office to Monitor and Combat Trafficking in Persons at .