Anti-Trafficking Policy & Compliance Plan

Updated December 2025

Organizational Commitment

JSI Research & Training Institute, Inc. (JSI) is committed to protecting the rights and dignity of the populations we serve, as well as creating safe workplaces for our staff and associates. Trafficking in persons is a human rights violation and a betrayal of our core values.

JSI has zero-tolerance for any form of trafficking in persons, supporting or advancing trafficking in persons, or intentionally ignoring or failing to act upon allegations of trafficking. JSI will take every reasonable measure to prevent such incidents and will investigate, act upon, and report suspected anti-trafficking violations in accordance with the provisions of this policy and JSI’s policies for investigating ethics and fraud violations.

Goals of Anti-Trafficking Policy

The overall goal of our anti-trafficking efforts is to create an organizational culture that opposes and prevents trafficking in persons in connection with JSI operations. We recognize that we have a responsibility to protect against the abuses and harms caused by human trafficking. In line with those goals, JSI prohibits JSI employees and associates from trafficking in persons, supporting or advancing trafficking in persons, or intentionally ignoring or failing to act upon allegations of trafficking.

This Anti-trafficking Policy and Compliance Plan describes the steps JSI will take to prevent and respond to trafficking violations. This includes (1) making employees aware of the conduct prohibited by JSI’s Anti-Trafficking Policy and the actions that may be taken against employees for violations; (2) employing fair recruitment, wage and housing practices; (3) preventing trafficking activity by JSI associates, and; (4) putting procedures in place to respond to and investigate allegations of trafficking.

It is JSI’s policy to fully comply with the U.S. Government’s zero-tolerance policy regarding trafficking in persons as well as those of other funders. JSI has developed this Anti-Trafficking Policy and Compliance Plan in accordance FAR 52.222-50, “Combatting Trafficking in Persons”, 2 CFR Part 175, “Award Term for Trafficking in Persons”, USAID “Trafficking in Persons” Mandatory Standard Provisions, and Executive Order 13627 “Strengthening Protections Against Trafficking In Persons In Federal Contracts”, as well as international anti-trafficking standards.

This policy compliments, and works in conjunction with, JSI’s Safeguarding and Sexual Harassment policies, which are included within the JSI Code of Conduct.

Scope

The JSI Anti-Trafficking Policy applies to everyone associated with JSI, including but not limited to:

• All full-time, part-time, and temporary JSI employees
• Volunteers and interns
• Consultants
• Business partners (subcontractors, subrecipients, vendors) and their employees

Standards of Behavior

These standards of behavior provide specific principles that must be followed and actions that must be avoided in order to comply with this policy. These standards are expected of and apply to all JSI staff and associates. Any breach or failure to comply with these standards will be taken seriously by JSI and will result in disciplinary action, up to and including termination.

JSI and associates are prohibited from engaging in:

1. Trafficking in persons which includes the recruitment, harboring, transportation, provision, or obtaining of a person for:
   1. The purpose of a commercial sex act in which the commercial sex act is induced by force, fraud, or coercion, or in which the person induced to perform such act has not attained 18 years of age; or
   2. Labor or services, through the use of force, fraud, or coercion for the purpose of subjection to involuntary servitude, debt bondage, or slavery;
2. Procurement of a commercial sex act;
3. Use of forced labor;
4. Acts that directly support or advance trafficking in persons, including but not limited to:
   1. Destroying, concealing, confiscating, or otherwise denying an employee access to their identity or immigration documents;
   2. Failing to provide return transportation to an employee relocated by JSI to a posting outside the country in which they were recruited, unless:
      1. exempted from the requirement to provide or pay for such return transportation by the contract or award to JSI; 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; or
      3. the employee is legally permitted to remain in the country of employment and chooses to do so.
5. Use of misleading or fraudulent recruitment practices;
6. Use of recruiters that do not comply with local labor laws of the country in which the recruiting takes place;
7. Charging employees recruitment fees;
8. Providing or arranging housing that fails to meet housing and safety standards.

If required by law or contract, fail to provide an employment contract, recruitment agreement, or other required work document in a language the employee understands.

Compliance Plan

The following requirements represent JSI’s baseline anti-trafficking compliance plan. JSI will ensure compliance with anti-trafficking standards through the procedures described and referenced throughout this policy. All JSI operations are subject to this policy and it will be enforced across all JSI locations and activities.

Safe Programming

Assessment

JSI will consider anti-trafficking in project planning and implementation. It is each project’s responsibility to ensure full compliance with this policy and ensure its integration into program planning and implementation.

Prevention and Monitoring Procedure

JSI will monitor and ensure compliance with this policy in a manner commensurate with the trafficking risk posed by the activities. At a minimum, every project must ensure compliance with the Standards of Behavior and the baseline Compliance Plan stated in this policy.

Awareness Program

JSI will take the following steps, at a minimum, to inform staff and associates about the requirements of this policy:

• This Anti-trafficking Policy is incorporated in full in the JSI Code of Conduct. All JSI employees receive orientation on their duties and obligations under the code of conduct, including this policy and the standards of behavior included herein. All staff are required to confirm, in writing, their receipt of the code of conduct and their commitment to abide by JSI policies and procedures.
• All staff are required to take the “Ethics at JSI” training and JSI Safeguarding course within 30 days of hire and annually thereafter. All staff will receive the appropriate level of anti-trafficking training.
• Ensuring that JSI staff and associates know that this policy can be publicly accessed on the JSI website.
• All contractual instruments issued by JSI to associates include anti-trafficking requirements commensurate with the risk posed by the associate or its work. At a minimum, contractual instruments issued by JSI will include the URL for the location of this policy and require confirmation that the associate has read, understands and agrees to comply with the Standards of Behavior listed in this policy.

Recruitment and Wage Plan

Recruitment Practices

JSI prohibits the use of any misleading or fraudulent recruitment practices during the recruitment of employees or offering of employment to employees. JSI hiring managers must fully and accurately disclose, in a format and language accessible to the employee, all key terms and conditions of employment, including wages and benefits, work location, living conditions, housing and associated costs (where provided or arranged by JSI), significant costs to be charged to the employee, and, if applicable, the hazardous nature of the work.

JSI prohibits destroying, concealing, confiscating or otherwise denying any employee access to his or her identity or immigration documents.

Recruitment Companies

JSI will only use the services of recruiters, staffing agencies and other recruitment companies with employees trained in anti-trafficking requirements and local employment rules. Recruiters, staffing agencies and other recruitment companies must agree to comply with all labor laws of the host country and JSI’s Anti-Trafficking Standards of Behavior.

Recruitment Fees

JSI prohibits charging recruitment fees to any employee or potential employee. “Recruitment fees” are any fees associated with the recruiting process paid to JSI, JSI employees or recruiters, staffing firms or other agents recruiting on behalf of JSI. Recruitment fees are prohibited regardless of how they are paid (cash, wage deduction, wage/benefit concession, bribe, kickback, etc.).

Costs incidental to recruitment that a potential employee pays to a third-party with no relationship to JSI (for example, the cost paid to a government agency for a passport necessary to be eligible for a position) are not “recruitment costs”. This prohibition does not affect the allowability of costs. Fees that fall within the definition of recruitment fees may still be incurred by JSI and charged as direct project costs. However, those costs cannot be passed on to the employee or potential employee.

Wage Plan

JSI’s Local Hire Employee Manual (LHEM) and implemented hiring practices must comply with all labor laws of the host country. Local compensation plans must meet applicable host-country legal requirements, comply with funder regulations and ensure fair compensation for the work being performed.

Hire Letter or Contract

At a minimum, JSI will provide all employees with a hire letter stating the terms of employment including job title, job description, salary, work location(s), compensation package (including paid time off) and the incorporation of the applicable employee manual and/or JSI Code of Conduct. If applicable, the hire letter will also include roundtrip transportation arrangements and living accommodations provided by JSI and associated costs. When required by local labor law, JSI will provide employees with compliant employment contracts or other required agreements that include additional information and terms as required by local law. If the employee must relocate to perform the work, the hire letter or employment contract must be provided at least five days prior to relocation.

All employees will receive a copy of the applicable employee manual and JSI Code of Conduct. JSI employee manuals will include grievance and dispute resolution procedures. JSI’s Code of Conduct incorporates this policy including the prohibition on trafficking in persons and charging recruitment fees.

Housing Plan

Generally, JSI does not provide housing to its employees. Rather, eligible JSI employees posted overseas receive a living quarters allowance in accordance with USG regulations to defray the cost of renting and maintaining suitable housing at post. In the event that JSI were to provide housing to employees, that housing must meet host country housing and safety standards.

Reporting

Mechanisms

JSI will ensure the availability of safe and accessible reporting mechanisms. Everyone involved in program activities must be made aware of the JSI reporting mechanisms and how to report anti-trafficking concerns.

JSI’s standard method of reporting violations of JSI’s Code of Conduct, as well as this anti-trafficking policy, is the JSI Code of Conduct Helpline. The Helpline is available internally and externally at www.jsi.org. Individuals may report violations via the online portal, toll-free telephone number, mobile intake, and, in some countries, a country specific telephone number. Reports made through the Helpline are confidential and reporters may remain anonymous if they choose.

Reports may also be made to the Global Human Trafficking Hotline at 1-844-888-FREE or help@befree.org.

Recognizing the special responsibility of protecting the privacy of the survivor and the confidentiality of the implicated person, JSI discourages communication about the details of anti-trafficking concerns via e-mail unless absolutely necessary. If e-mail is necessary, subject headings should be vague and inoffensive, and must be flagged as confidential.

Requirements

JSI employees are required to report any suspected violations of this policy they become aware of to the JSI Code of Conduct Helpline immediately. Failure to report suspected violations of this policy is itself a violation of this policy and will result in disciplinary action.

When JSI receives credible evidence from any source that alleges a violation of this policy, JSI Vice President, Contracts & Compliance, or his/her designee, will immediately report to USG or other funders as required by the terms of our agreements with those funders. When appropriate, JSI will also report allegations to local authorities.

Responding to Allegations

Any action to respond to or investigate a trafficking concern must be survivor-centered. JSI will immediately initiate an investigation of any trafficking concern it becomes aware of. This investigation will follow our established policies and processes for all ethics/fraud incident reports. Additionally, for trafficking-related incidents, investigations will adhere to the following:

1. Ensuring the safety of the survivor and witnesses is always the first priority. JSI will take appropriate action to protect and support individuals who are the subject of concerns regarding possible anti-trafficking violations and the witnesses who report such violations. These actions may include referrals to organizations that can provide medical care, security, legal aid, and counseling. The safety of other potentially involved individuals (survivor’s family, alleged perpetrator, JSI staff, etc) must also be considered.
2. When JSI is required to provide return transportation to a trafficking survivor who is seeking survivor services or legal redress in the country of employment, or to a witness in an anti-trafficking enforcement action, JSI shall provide the return transportation or pay the cost of return transportation in a way that does not obstruct the survivor services, legal redress, or witness activity. For example, JSI shall not only offer return transportation to a witness at a time when the witness is still needed to testify.
3. The investigation will be conducted by a qualified, impartial team free of any influence that could impair the team’s judgment. If internal capacity is not available, JSI will engage outside experts to conduct the investigation.
4. Persons reporting the incident and persons who have witnessed trafficking will be treated respectfully. Statements made by the complainant will be kept in appropriate confidentiality. The complainant will be:
   1. Interviewed to confirm all relevant facts.
   2. Given the opportunity to provide relevant facts.
   3. Given the opportunity to participate in the investigation by providing names/identities of other witnesses and recommending questions to be asked by investigators.
5. Appropriate confidentiality must be maintained. Personally identifiable information (PII) pertaining to incidents in which a survivor’s rights have been violated should be shared only to a limited number of specified people on a ‘need to know’ basis, as deemed by the VP, Contracts & Compliance or designee, in consultation with the designated safeguarding focal person. Appropriate steps must be taken to ensure the secure transfer and storing of information. In all instances, PII, including survivors’, witnesses’ and alleged perpetrators’ identities, must not be disclosed beyond the appropriate management personnel, unless authorized.
6. While appropriate confidentiality must be maintained, JSI reserves the right to disclose, to the extent allowed by law: information required to be disclosed to proper authorities; information required to comply with funder reporting requirements, and; information involving employees terminated on the basis of anti-trafficking violations to other organizations or authorities.
7. JSI will cooperate fully with any US Government agencies responsible for any investigations, audits or corrective actions relating to this policy, including, but not limited to, providing timely and complete responses to document requests, providing reasonable access to JSI facilities and not preventing or hindering employees from cooperating fully.

Whistleblowing

JSI’s whistleblowing policy encourages people who become aware of wrongdoing in the organization to report their concerns immediately. All incidents are investigated fairly and confidentially. We are committed to non-retaliation against staff members who report possible or actual violation of this policy. JSI will not discharge, demote, discriminate or otherwise retaliate against an employee or any other person who, in good faith, reports or threatens to report a violation of this policy, or who cooperates with any government investigation of such reports.

JSI treats malicious allegations with the utmost seriousness and takes appropriate disciplinary action.

For more information, employees should refer to the whistleblower policy in the JSI Code of Conduct or country-specific Local Hire Employee Manual (LHEM), as applicable.

Business Partners and Other Agents

JSI includes anti-trafficking requirements in all contractual documents. At a minimum, JSI business partners must:

• Confirm that they have read and will comply with the JSI Anti-trafficking Standards of Behavior.
• Maintain procedures to prevent and punish anti-trafficking violations.
• Immediately report to JSI any credible allegations of trafficking in persons related to the contract or agreement.

Contractual documents will also include funder-required anti-trafficking clauses including, as applicable, FAR 52.222-50, “Combating Trafficking in Persons.”

During the performance of their work, JSI will monitor and ensure business partner compliance in a manner commensurate with the trafficking risk posed by the partner, activities or goods or services being procured.

JSI’s zero-tolerance for any form of trafficking in persons extends to the actions of its business partners and their employees. The consequences of a partner’s trafficking violation are explicit and include termination of the contract, along with additional action as required (e.g., referral to appropriate authorities or funder). If JSI determines that a partner or a partner employee has committed an anti-trafficking violation, including failing to report or take reasonable steps to prevent violations, we will take appropriate action including but not limited to:

• Requiring the party to remove an employee or agent from a project
• Requiring the party to terminate its relationship with any other contractor, vendor, consultant, supplier, subcontractor or subrecipient found to be in violation
• Suspending payments to the party until the violation is remedied,
• Immediately terminating the party’s agreement, grant, or contract,
• Excluding the party from further work and other opportunities with JSI, and
• Reporting the violation to the funder and appropriate authorities.

Certifications

Cooperative Agreements/Grants

For USAID awards containing Mandatory Standard Provision M20 that exceed an estimated value of $500,000, JSI must submit the annual “Certification Regarding Trafficking in Persons, Implementing Title XVII of the National Defense Authorization Act for Fiscal Year 2013” to the Agreement Officer upon request.

Contracts

For US Government-funded contracts that exceed an estimated value of $550,000 and are to be performed outside the United States, JSI must submit the certification contained in FAR 52.222-56, “Certification Regarding Trafficking in Persons Compliance Plan” to the Contracting Officer annually.

Definitions

Associates: Any individual or organization working with JSI including, but not limited to, business partners (consultants, subcontractors, subrecipients, vendors and other entities in a contractual relationship with JSI), interns, and volunteers.

Coercion:

1. Threats of serious harm to or physical restraint against any person;
2. Any scheme, plan, or pattern intended to cause a person to believe that failure to perform an act would result in serious harm to or physical restraint against any person; or
3. The abuse or threatened abuse of the legal process.

Commercial sex act: any sex act on account of which anything of value is given to or received by any person.

Debt bondage (also known as peonage): the status or condition of a debtor arising from a pledge by the debtor of his or her personal services or of those of a person under his or her control as a security for debt, if the value of those services as reasonably assessed is not applied toward the liquidation of the debt or the length and nature of those services are not respectively limited and defined.

Forced Labor: knowingly providing or obtaining the labor or services of a person—

1. By threats of serious harm to, or physical restraint against, that person or another person;
2. By means of any scheme, plan, or pattern intended to cause the person to believe that, if the person did not perform such labor or services, that person or another person would suffer serious harm or physical restraint; or
3. By means of the abuse or threatened abuse of law or the legal process.

Involuntary servitude: a condition of servitude induced by means of—

1. Any scheme, plan, or pattern intended to cause a person to believe that, if the person did not enter into or continue in such conditions, that person or another person would suffer serious harm or physical restraint; or
2. The abuse or threatened abuse of the legal process.

Misleading or fraudulent recruitment practices:

1. 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;
2. Failing to disclose, in a format and language accessible to the worker, basic information regarding the employment; or
3. 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.

Recruitment fees: fees of any type, including charges, costs, assessments, or other financial obligations, charged by JSI, or a recruiter working on behalf of JSI, to employees or potential employees to secure employment regardless of the time, manner, or location of imposition or collection of the fee.