Anti-Trafficking Compliance Plan

Sustainable Development Council (SDC) Anti-Trafficking Compliance Plan

1. Purpose and Introduction: This Anti-Trafficking Compliance Plan outlines the Sustainable Development Council’s (SDC) commitment to preventing and addressing human trafficking in all its forms. Human trafficking is a grave violation of human rights, and SDC is resolute in its stance against any involvement, direct or indirect, in trafficking-related activities. This plan supplements SDC’s existing policies, including the Code of Conduct, Child Protection and Safeguarding Policy, and Prevention of Sexual Exploitation and Abuse Policy, to comprehensively address the complexities associated with human trafficking.

2. Policy Scope: This plan applies to all SDC employees, interns, fellows, volunteers, and representatives (collectively referred to as “SDC Staff”), as well as SDC grantees/awardees, contractors, suppliers, consultants, and their employees, sub-grantees/awardees, and representatives (collectively referred to as “Delivery Partners”) engaged by SDC. It encompasses all SDC operations, programs, and projects globally.

3. Definitions:

• Human Trafficking: As defined by applicable international law, human trafficking includes the recruitment, transportation, transfer, harboring, or receipt of persons through force, fraud, or coercion for the purpose of exploitation.

4. Risk Assessment:

• SDC will conduct a periodic risk assessment to identify areas within its operations and supply chains where there is a risk of human trafficking.
• The risk assessment will consider geographical locations, types of projects, and characteristics of the workforce involved.

5. Prevention Measures:

• Due Diligence: SDC will implement due diligence measures during the selection of Delivery Partners and suppliers, emphasizing compliance with anti-trafficking laws and ethical business practices.
• Awareness Training: All SDC Staff and Delivery Partners will receive training on recognizing and preventing human trafficking. Training programs will be periodically updated to reflect emerging trends and legal developments.

6. Reporting Mechanism:

• SDC will establish a confidential reporting mechanism to allow SDC Staff and Delivery Partners to report any concerns or suspicions related to human trafficking. This mechanism will ensure whistleblower protection and anonymity.

7. Supplier and Contractor Compliance:

• SDC will include anti-trafficking clauses in all contracts, agreements, and grants, explicitly stating the prohibition of human trafficking and outlining the consequences of non-compliance.
• Suppliers and contractors will be required to certify compliance with anti-trafficking laws and adhere to the principles outlined in this plan.

8. Response and Remediation:

• SDC will take swift and appropriate action in response to any reports or suspicions of human trafficking. This includes initiating internal investigations, collaborating with law enforcement, and taking corrective actions.

9. Collaboration and Partnerships:

• SDC will collaborate with external organizations, government agencies, and NGOs to exchange best practices, participate in industry initiatives, and collectively combat human trafficking.

10. Review and Continuous Improvement:

• The Anti-Trafficking Compliance Plan will be subject to regular review and updates to ensure its effectiveness in addressing evolving risks and legal requirements.

11. Consequences of Non-Compliance:

• Non-compliance with this plan may result in disciplinary action, contract termination, or other legal consequences, depending on the severity of the violation.

SDC reaffirms its commitment to ethical and responsible conduct, condemning human trafficking in all its forms. By implementing this Anti-Trafficking Compliance Plan, we aim to contribute to the global effort to eliminate this heinous crime and uphold the dignity and rights of every individual.