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Preventing Trafficking Compliance Plan

This plan details Vital Strategies’ prohibitions on activity that is or facilitates human trafficking and provides support and clarity to Vital Strategies employees, board members, consultants, anyone representing Vital Strategies, and others working with Vital Strategies to help them proactively engage in preventing human trafficking in any Vital Strategies program or activity. This plan is intended to comply with donor requirements requiring such a plan and applicable U.S. laws and regulations and is applicable to all employees, board members, consultants, anyone representing Vital Strategies, and others engaging in work for or under awards from Vital Strategies. As necessary, subaward or sub agreements and other agreements will contain language requiring subawardees, subrecipients, subgrantees, and other contract partners to refrain from facilitating or engaging in human trafficking and to enact similar plans.

Prohibition on trafficking and related activities

Vital Strategies prohibits engaging in trafficking in persons[1] and human trafficking-related activities. These activities include engaging in sex trafficking, procuring commercial sex acts (even if this practice is legal in the jurisdiction where it transpires), using force, fraud, or coercion to subject a person to involuntary servitude, or obtaining labor from a person by threats of serious harm to that person or another person, among others.

Other related activities which are likewise prohibited include:

  • Destroying or otherwise denying access to an employee’s identity or immigration documents;
  • Using misleading or fraudulent practices to recruit employees, such as failing to disclose key terms and conditions of employment;
  • Using recruiters that do not comply with local labor laws;
  • Charging employees recruitment fees;
  • Failing to provide return transportation to certain employees who are brought to a country for the purpose of working on a U.S. Government contract;
  • Providing housing that fails to meet host country standards; and
  • Failing to provide an employment contract or work document where required by law.

Reporting and Investigation

Anyone to whom this plan is applicable having knowledge of credible information concerning actual or potential violations of this policy must report them immediately in accordance with the Vital Strategies Whistleblower Policy. Timeliness of reporting any suspected violation is critical as the U.S. Government has imposed an especially stringent reporting obligation when there is credible information of violations. Failure to report actual or potential illegal behavior or actual or potential violations of this policy may also subject employees to disciplinary action, up to and including termination of employment and may subject consultants and third parties to termination of their agreements.

Employees may use any avenue listed in the Whistleblower Policy or this plan to make a report. When making a report, employees are encouraged to share as much information as possible so that appropriate action can be taken. All reports will be investigated following the procedures outlined in the Whistleblower Policy with minimal delay. To the extent possible, if requested by the whistleblower, the investigation shall be kept confidential.

Vital Strategies does not tolerate retaliation or threats of retaliation against anyone who raises a concern under this plan or who assists with an internal or governmental audit or investigation. Any employee, consultant, or third party who engages in retaliation or threats of retaliation will face disciplinary action, which could include termination of employment for employees and termination of agreements for consultants and third parties.

Tips for identifying trafficking

Vital Strategies seeks to help those impacted by this plan with identifying potential trafficking in persons. The below list is not exhaustive and not everything on this list will always be an indication of trafficking. However, Vital Strategies encourages those impacted by this plan to be familiar with this list and to report any activity which they believe may be indicators of trafficking in persons.

Common Work and Living Conditions: The individual(s) in question

  • Is not free to leave or come and go at will
  • Is under 18 and is providing commercial sex acts
  • Is in the commercial sex industry and has a pimp / manager
  • Is unpaid, paid very little, or paid only through tips
  • Works unreasonably long and/or unusual hours for the situation
  • Is not allowed breaks or suffers under unusual restrictions at work
  • Owes a large debt and is unable to pay it off
  • Was recruited through false promises concerning the nature and conditions of his/her work
  • High security measures exist in the work and/or living locations (e.g. opaque windows, boarded up windows, bars on windows, barbed wire, security cameras, etc.)
  • Is living and working on site
  • Experiences verbal or physical abuse by their supervisor
  • Is not given proper safety equipment
  • Is not paid directly
  • Is forced to meet daily quotas

Poor Mental Health or Abnormal Behavior

  • Is fearful, anxious, depressed, submissive, tense, or nervous/paranoid
  • Exhibits unusually fearful or anxious behavior after bringing up law enforcement or immigration officials
  • Shows signs of substance use or addiction

Poor Physical Health

  • Shows signs of poor hygiene, malnourishment, and/or fatigue
  • Shows signs of physical and/or sexual abuse, physical restraint, confinement, or torture

Lack of Control

  • Has few or no personal possessions
  • Is frequently monitored
  • Is not in control of their own money, financial records, or bank account
  • Is not in control of their own identification documents (ID or passport)
  • Is not allowed or able to speak for themselves (a third party may insist on being present and/or translating)


  • Claims of just visiting and inability to clarify where they are residing/address
  • Lack of knowledge of whereabouts and/or do not know what city he/she is currently in
  • Appear to have lost sense of time
  • Shares scripted, confusing, or inconsistent stories
  • Protects the person who may be hurting them or minimizes abuse

Again, this list is not exhaustive and represents only a selection of possible indicators. The red flags in this list may not be present in all trafficking cases. Each individual indicator should be taken in context, not be considered in isolation, nor should be taken as “proof” that human trafficking is occurring. Additionally, cultural differences should also be considered[2].

Violations of this Plan

Vital Strategies employees, board members, or others representing Vital Strategies, or those working with Vital Strategies as consultants, subcontractors, subawardees, or in any other contractual relationship that engage in activities prohibited in this plan, that are substantiated upon investigation, shall have their relationship with Vital Strategies immediately terminated. If Vital Strategies substantiates that any of the above individuals or entities engaged in prohibited activities prior to their relationship with Vital Strategies, those individuals or entities may have their relationship with Vital Strategies terminated or restricted based on applicable laws and donor requirements.

U.S. Government Reporting Line

In addition to the above reporting procedures, reports may also be made to through the Global Human Trafficking Hotline at 1-844-888-FREE and its e-mail address at Making a report through these channels does not alleviate an individual’s responsibility to make a similar report to Vital Strategies.

Additional Donor Requirements

This plan is intended to comply with U.S. government donor requirements and to satisfy requirements of additional Vital Strategies’ donors. However, additional requirements may be imposed depending on the nature of the programmatic activity and any specific donor requirements.

Awareness Program

Vital Strategies will ensure that employees, consultants and other third parties are appropriately informed, including through posting on the Vital Strategies website, about the trafficking related prohibitions contained in this plan, the measures they can take to identify and prevent trafficking, and the sanctions that may be imposed for failing to comply.

[1] As defined in the Protocol to Prevent, Suppress and Punish Trafficking in Persons Especially Women and Children, supplementing the United Nations Convention against Transnational Organized Crime (excerpted below):

(a) “Trafficking in persons” shall mean the recruitment, transportation, transfer, harbouring 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 labour or services, slavery or practices similar to slavery, servitude or the removal of organs;

(b) The consent of a victim of trafficking in persons to the intended exploitation set forth in subparagraph (a) of this article shall be irrelevant where any of the means set forth in subparagraph (a) have been used;

(c) The recruitment, transportation, transfer, harbouring or receipt of a child for the purpose of exploitation shall be considered “trafficking in persons” even if this does not involve any of the means set forth in subparagraph (a) of this article;

(d) “Child” shall mean any person under eighteen years of age.

[2] Polaris, Recognizing the Signs,