Trafficking in Persons Policy and Procedures

Policy Statement

It is the policy of the International Center for Journalists (ICFJ) to comply with USAID Standard Provision M20 for U.S. Nongovernmental Organizations, which concerns trafficking in persons.

Prohibited Activities

ICFJ prohibits its employees or other agents, contractors, and subrecipients from engaging in:

1. Trafficking in persons (as defined in the Protocol to Prevent, Suppress, and Punish Trafficking in Persons, especially Women and Children, supplementing the UN Convention against Transnational Organized Crime) during the period of this award;
2. Procurement of a commercial sex act during the period of this award;
3. Use of forced labor in the performance of this award; or

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

   • Destroying, concealing, confiscating, or otherwise denying an employee access to that employee's identity or immigration documents;
   • 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: 1. Exempted from the requirement to provide or pay for such return transportation by USAID under this award; or 2. The employee is a victim of human trafficking seeking victim services or legal redress in the country of employment or a witness in a human trafficking enforcement action;
   • 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;
   • Charging employees recruitment fees; or
   • Providing or arranging housing that fails to meet the host country housing and safety standards.

Reporting Procedures

ICFJ employees or other agents, contractors, and subrecipients are required to report to ICFJ without retaliation any suspected trafficking-related activity or violation of this policy. Reports may be made to ICFJ's Human Resources staff or any ICFJ supervisor. Any ICFJ supervisor who receives such a report is required to forward it immediately to ICFJ Human Resources. ICFJ Human Resources will promptly investigate all reported concerns.

ICFJ employees or other agents, contractors, and subrecipients may also report to the Global Human Trafficking Hotline any activity inconsistent with ICFJ's Trafficking in Persons Policy. The Global Human Trafficking Hotline accepts reports by phone (1-844-888-FREE) or email (help@befree.org). Complaints can also be reported here. 

If ICFJ receives any credible information regarding a violation of the prohibited trafficking-related activities as contained in ICFJ's Trafficking in Persons Policy and Procedures, ICFJ will immediately notify the cognizant Agreement Officer for any applicable USAID award and the USAID Office of the Inspector General. ICFJ will cooperate with any Federal agencies responsible for audits, investigations, or corrective actions relating to trafficking in persons.

Consequences of Violations

ICFJ employees or other agents who violate this policy by engaging in any of the prohibited activities as contained or otherwise violate this policy will be subject to disciplinary action up to and including termination of employment or affiliation with ICFJ.

ICFJ contractors or subrecipients who violate this policy by engaging in any of the prohibited activities as contained, violate this policy by failing to comply with any applicable agreement term or condition, or otherwise violate this policy will be subject to corrective action up to and including termination of any agreement with ICFJ.

Compliance Plans

If the estimated value of services required to be performed under a USAID award outside the United States exceeds $500,000, ICFJ will implement at a minimum its Standard Compliance Plan to comply with ICFJ's Trafficking in Persons Policy and Procedures. ICFJ will consider whether to augment the Standard Compliance Plan according to the size and complexity of the award and to the nature and scope of the activities, including the number of non-Untied States citizens expected to be employed. ICFJ will post the useful and relevant contents of the Standard Compliance Plan on its website and at its workplace.

Agreement Provision

ICFJ will include in all subrecipient and contractor agreements a provision barring the prohibited activities as contained by the subrecipient, contractor, or any of their employees or other agents. ICFJ will also include a provision authorizing ICFJ to terminate the agreement, without penalty, in the event of a violation of the provision barring the prohibited activities as contained.