Policy Against Trafficking in Persons and Slavery

1. Purpose

IT for Change (ITfC) is committed to a work environment that is free from human trafficking and slavery, which for the purposes of this Policy, includes forced labor and unlawful child labor. ITfC will not tolerate or condone human trafficking or slavery in any part of the organization. This Policy is consistent with ITfC’s core values to protect and advance human dignity and human rights in its work.

ITfC employees, contractors, subcontractors, vendors, suppliers, partners and others through whom ITfC conducts business must avoid complicity in any practice that constitutes trafficking in persons or slavery.

2. Scope

This Policy applies to all employees of ITfC as outlined in the Code of Conduct.

3. Policy

ITfC employees, contractors, subcontractors, vendors, suppliers, partners and others through whom ITfC conducts business must not engage in any practice that constitutes trafficking in persons or slavery. This includes, but is not limited to, the following activities:

    (a) Engaging in any form of trafficking in persons;
    (b) Procuring commercial sex acts in an official capacity in any jurisdiction where it is deemed illegal;
    (c) Using forced labor in the performance of any work;
    (d) Destroying, concealing, confiscating, or otherwise denying access by an individual to the individual’s identity or immigration documents, such as passports or drivers’ licenses, regardless of issuing authority;
    (e) Using misleading or fraudulent practices during the recruitment of candidates 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 ITfC), any significant cost to be charged to the candidate, and, if applicable, the hazardous nature of the work;
    (f) Using recruiters that do not comply with local labor laws of the country in which the recruiting takes place;
    (g) Charging applicants/candidates recruitment fees;
    (h) 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;
    (i) 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 document in writing.

ITfC requires its partners to observe all applicable laws and conduct business in an ethical and responsible manner.

3. Reporting

Employees should report any conduct they believe to be a violation of this Policy, either directly to the integrity officer or to an immediate manager or Director. Any member who reports suspected violations of this policy in good faith will be protected by IT for Change’s Whistleblower Policy and Procedure.

4. Investigation

In lieu of any suspected violation of this Policy, all ITfC employees and partners will be required to fully and promptly cooperate with ITfC’s internal and external auditors and investigators, and must respond fully and truthfully to their questions, requests for information, and documents. Any failure by an employee to completely cooperate, or any action to hinder an investigation or audit, including for example, hiding or destroying any information or documentation, providing false answers or false information, or deleting email or other documents, may be grounds for disciplinary action, up to and including termination, subject to applicable law.

5. Consequences of Violation

Any violation of this Policy by an employee/s of the organization, if found to be substantiated upon investigation and due-process, may be grounds for disciplinary action, up to and including termination, subject to applicable law. Violation of applicable laws may also result in criminal prosecution of responsible individuals.