Compliance

Roots of Peace Compliance Plan

Policies and Procedures Concerning Avoidance of Human Trafficking

Purpose

The Roots of Peace Anti-Human Trafficking Compliance Plan will ensure Roots of Peace remains in adherence to the policies outlined in the CHAMP Cooperative Agreement, the Federal Acquisition Regulations, and to our principles of respect for all people worldwide.

In accordance with the CHAMP Cooperative Agreement, which was written in accordance with United States federal regulations against the participation in human trafficking by award recipients, Roots of Peace is dedicated to removing itself from any form of illegal human trafficking, and will follow this Compliance Plan in pursuit of this goal.

Definitions

  • Trafficking in Persons: As defined in the United Nations’ Protocol to Prevent, Suppress, and Punish Trafficking in Persons, Article 3, subsection a, “‘Trafficking in persons’ shall mean the recruitment, transportation, transfer, harboring or receipt of persons, by means of the threat or use of force or other forms of coercion, of abduction, of fraud, of deception, of the abuse of power or of a position of vulnerability or of the giving or receiving of payments or benefits to achieve the consent of a person having control over another person, for the purpose of exploitation. Exploitation shall include, at a minimum, the exploitation of the prostitution of others or other forms of sexual exploitation, forced labor or services, slavery or practices similar to slavery, servitude or the removal of organs”
  • Employee: an individual engaged in the performance of this award as a direct employee, consultant, or volunteer of the recipient or any sub-recipient.
  • Other Workers: any of the following
    1. Contractor: an employee, hired to perform work for Roots of Peace limited by specific job or program, as defined by their contract.
    2. Subcontractor: an employee or contractor hired by a Roots of Peace contractor to help with the performance of this award.
    3. Agent: person who is authorized to act or work on behalf of Roots of Peace or a Roots of Peace employee, contractor, or subcontractor.
  • Commercial Sex Acts: a sexual act obtained through trade of anything of value.
  • Forced Labor: Labor that has been coerced under threat, fraudulent misrepresentations or promises, or otherwise unlawful pressure or means.

Awareness Program

Every new employee or other worker will be educated at the time of orientation on the prohibited activities and policies of Roots of Peace as outlined in this document. This education, as well as an explanation of their duties to report and the mechanisms through which to do so, will be provided to them in writing at the time of their orientation. A copy of this Compliance Plan will be provided to them as well. All Roots of Peace personnel will be notified through e-mail of any changes or updates in the policies and procedures regarding human trafficking.

Prohibited Activities

Roots of Peace, including its management, employees, and other workers, will not engage in the following activities during the period of this award:

  • Trafficking in Persons
  • Procurement of commercial sex acts in conjunction with, during the performance of, and/or during the period of this award
  • Use of forced labor in conjunction with, during the performance of, and/or during the period of this award
  • Any act directly or indirectly in support of human trafficking, including but not limited to
    1. Destroying, confiscating, concealing, or otherwise denying an employee access to said employee’s identity or immigration documents
    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:
      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
    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. Charging employees or potential employees recruitment fees; or
    5. Providing or arranging housing that fails to meet the host country housing and safety standards.
  • Use of any recruitment company that does not prohibit charging a recruitment fee to the employees, that does not have trained employees.

Reporting Procedures

Every employee or other worker of Roots of Peace is required to report any and all violations of the prohibited activities listed above, as well as any reasonable suspicions that violations of these prohibited activities have taken place. Employees are strongly encouraged to first make a report to their supervisor, or if necessary, their supervisor’s supervisor. If the employee is not satisfied with the response of the supervisor, the employee can make a report to the Chief Executive Officer or President. Lastly, employees can make a report by emailing conduct@rootsofpeace.org which will be read by a Roots of Peace board member.

Employees, contractors, and subcontractors also have the option of reporting these violations to the Global Human Trafficking Hotline at 1-844-888-FREE or its email address at help@befree.org.

Any resources reasonably spent on reporting violations to Roots of Peace or to the Global Human Trafficking Hotline, will be reimbursed to the reporting employee or contractor.

Further, any reporting employee or other worker will not face any retaliation, personal or professional, from the Roots of Peace organization or its employees, contractors, subcontractors or agents for reporting any violations or reasonably suspected violations.

Once notified of any employee or other worker participating in any prohibited activities, Roots of Peace will conduct an investigation, and immediately notify the Agreement Officer and the USAID Office of the Inspector General, and will fully cooperate with any federal agencies responsible for audits, investigations, or corrective actions related to trafficking in persons.

Wage Plan

Roots of Peace is committed to protecting its employees’ right to fair wages. Roots of Peace pays employees in accordance with applicable host-country requirements. Any variance will be explained on a case-by-case basis.

Housing Plan

In the instances that housing is provided to an employee or other worker, such housing will adhere to the housing and safety standards of the host country. 

Procedures for Prevention and Monitoring

No Roots of Peace employee or other worker is permitted to take part in human trafficking or the related prohibited activities outlined above.

Each employee is responsible for reporting, through the mechanisms described above, any participation in the prohibited activities, so that Roots of Peace may prevent such participation, and terminate any employee, contractor, subcontractor or agent that is engaged in such participation.

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