Trafficking in Persons Compliance Policy

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As an organization committed to empowering individuals and increasing respect for human dignity, IRI supports initiatives to end human trafficking. Trafficking in persons (TIP) is the crime of using force, fraud, or coercion to exploit another person, which can be in the form of domestic servitude, forced or bonded labor, sexual servitude, and the use of child soldiers. 

In affirmation of this commitment, IRI requires its Employees and partners to engage in conduct, including the implementation of all projects, consistent with the laws and international agreements countering trafficking. Noncompliance with this policy, as with other IRI corporate policies as outlined in IRI’s Employee Handbook and Code of Ethics, respectively, or with the specific policies and procedures of IRI’s funders, may result in disciplinary action, including and up to termination of employment from IRI.

The obligation to adhere to the Trafficking in Persons provisions applies to all IRI employees, contractors, and volunteers, as well as to all project partners, subawardees and stakeholders. IRI informs subawardees, contractors and volunteers of Trafficking in Persons provisions and incorporates those provisions in to all subawards and contracts. In certain circumstances, IRI may require a prospective subawardee or contractor to certify compliance with TIP requirements prior to the issuance of a contract or subaward and to so certify annually thereafter as long as any contractual relationship exists between IRI and a subawardees/contractor.

Any violation of the laws against trafficking in persons and/or IRI policy will result in disciplinary action. In the case of Employees, this action can include immediate termination of IRI employment. For contractors and subawardees, failure to comply with TIP restrictions is a basis for IRI to terminate any agreement(s) with that contractor or subawardee immediately and to recover any funds expended by that contractor or subawardee.

During the period of any award or contract, IRI and its subawardees and contractors at any level and their employees, labor recruiters, brokers or other agents, shall not engage in:

1.

Any behavior deemed trafficking in persons, as defined in U.S. law, the Protocol to Prevent, Suppress, and Punish Trafficking in Persons, especially Women and Children, supplementing the UN Convention against Transnational Organized Crime;

2.

The procurement of a commercial sex act;

3.

The use of forced labor in the performance of this award;

4.

Acts that directly support or advance trafficking in persons, including the following acts:

4.1

Destroying, concealing, confiscating, or otherwise denying an employee access to that employee’s identity or immigration documents;

4.2

Failing to provide return transportation or pay for return transportation costs to an employee from a country outside the United States to the country from which the employee was recruited upon the end of employment if requested by the employee, unless:

4.2.1

exempted from the requirement to provide or pay for such return transportation by USAID under this award; or

4.2.2

4.3

Soliciting a person for the purpose of employment, or offering employment, by means of materially false or fraudulent pretenses, representations, or promises regarding that employment;

4.4

Charging employees recruitment fees; or

4.5

Providing or arranging housing that fails to meet the host country housing and safety standards.

IRI vets contractors and subawardees that conduct regular business with the Institute. This includes all parties with whom IRI conducts regular commercial business or with whom it establishes contractual relationships. IRI conducts this vetting through World Check One, a commercial system that conducts verification against more than 100 international terrorist and sanctions lists, including OFAC, UN and SAM. This database contains information on parties sanctioned or debarred by the U.S. Government as well as those with publicly known criminal background information. World Check One allows for verification on an on-going basis from the date of initial data entry.

Any knowledge of violations of this policy must be reported to IRI immediately. IRI maintains a hotline service for the reporting of any known or suspected violations of this policy or violations of policies regarding financial matters (e.g., fraud), other unethical or illegal conduct, or inappropriate professional conduct related to business activities. Reported violations of this policy can be reported in the following ways: 

Toll-Free Telephone: 

Direct Dial 

AT&T USA Direct 

All other countries: 800-603-2869 (must dial country access code first click here for access codes and dialing instructions) 

IRI follows all legal requirements regarding the reporting of suspected trafficking or other violations of the law, including, where applicable, disclosures to agreement officers, the Office of Inspector General, or law enforcement.

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