Combatting Trafficking In Persons

 

Defined as recruitment, transportation, transfer, harboring or receipt of persons by means of the threat, use of force, coercion, abduction, fraud, deception, abuse or exploitation, Trafficking in Persons is the third largest and fastest growing criminal activity in the world. A grave violation of human rights, it is a world-wide criminal threat to security, civil rights, and stability – and a direct threat to our national foreign policy goals. Trafficking in Persons undermines and degrades our readiness and will not be tolerated at EdjAnalytics.

This zero-tolerance policy applies to all employees, contractors and subcontractor employees.  EdjAnalytics will not:

  • Engage in forms of trafficking in persons;
  • Procure commercial sex acts;
  • Use forced labor;
  • Destroy, conceal, confiscate, or otherwise deny access by an employee to the employee’s identity or immigration documents, such as passports or drivers’ licenses, regardless of issuing authority; or
  • Use misleading or fraudulent practices during the recruitment of employees or offering of employment, such as failing to disclose, in a format and language accessible to the worker, basic information or making material misrepresentations during the recruitment of employees regarding the key terms and conditions of employment, including wages and fringe benefits, the location of work, the living conditions, housing and associated costs (if employer or agent provided or arranged), any significant cost to be charged to the employee, and, if applicable, the hazardous nature of the work;
  • Use recruiters that do not comply with local labor laws of the country in which the recruiting takes place;
  • Charge employees recruitment fees;
  • Fail to provide return transportation or pay for the cost of return transportation upon the end of employment – (A) For an employee who is not a national of the country in which the work is taking place and who was brought into that country for the purpose of working on a U.S. Government contract or subcontract (for portions of contracts performed outside the United States); or (B) For an employee who is not a United States national and who was brought into the United States for the purpose of working on a U.S. Government contract or subcontract, if the payment of such costs is required under existing temporary worker programs or pursuant to a written agreement with the employee (for portions of contracts performed inside the United States); except that – (ii) Some requirements shall not apply to an employee who is – (A) Legally permitted to remain in the country of employment and who chooses to do so; or (B) Exempted by an authorized official of the contracting agency from the requirement to provide return transportation or pay for the cost of return transportation; (iii) Some requirements may modified for a victim of trafficking in persons who is seeking victim services or legal redress in the country of employment, or for a witness in an enforcement action related to trafficking in persons. EdjAnalytics shall provide the return transportation or pay the cost of return transportation in a way that does not obstruct the victim services, legal redress, or witness activity.
  • Provide or arrange housing that fails to meet the host country housing and safety standards; or
  • If required by law or contract, fail to provide an employment contract, recruitment agreement, or other required work document in writing. Such written work document shall be in a language the employee understands. If an employee must relocate to perform the work, the work document shall be provided to the employee at least five days prior to the employee relocating. The employee’s work document shall include, but is not limited to, details about work description, wages, prohibition on charging recruitment fees, work location(s), living accommodations and associated costs, time off, roundtrip transportation arrangements, grievance process, and the content of applicable laws and regulations that prohibit trafficking in persons.

 

All employees must understand the dynamics and indicators of trafficking and be vigilant in correcting or reporting suspected violations or activities.  All violations or suspected violations should be reported to the Chief Executive Officer and Human Resource Department immediately. Failure to comply with this Combatting Trafficking in Persons compliance plan will result in the termination of employment.   No employee will turn a blind eye to this issue.