IIE Combatting Trafficking in Persons and Safeguarding Against Exploitation, Sexual Abuse, Child
Abuse and Child Neglect Compliance Plan (“Plan”)

I.

Background

The United States Government has adopted laws, regulations, and provisions to combat trafficking inpersons (“CTIP”), and safeguard against exploitation, sexual abuse, child abuse and child neglect1(“Safeguarding”). This body of laws, regulations and provisions prohibits IIE, a U.S. Government
contractor/implementer, or any member of the IIE Community, from engaging in activities consideredtrafficking in persons, exploitation, sexual abuse, child abuse and child neglect. IIE has prepared this Plan,
which describes the general requirements of these laws, regulations and provisions and outlines the meansby which IIE will comply with them. IIE Team Members and members of the IIE Community must comply
with this Plan and promptly report violations to Grants and Contracts, the Legal Department or through thebelow hotline if a Team Member prefers to report anonymously.
Recipients of USG funds and USG funded contractors are prohibited from engaging in activities consideredtrafficking in persons, exploitation, sexual abuse, child abuse and child neglect, as further described below.
Members of the IIE Community or its agents must not:
1.
2.
3.
4.

Engage in severe forms of trafficking in persons;Procure commercial sex acts;
Use forced labor;
Engage in any exploitation, sexual abuse, child abuse, or child neglect, support or advance theseactions, or intentionally ignore or fail to act upon allegations of these actions.
5. Engage in acts that directly support or advance trafficking in persons, including the following acts:a) Deny access by any means to an employee’s identification or immigration documents;b) Use misleading or fraudulent practices during the recruitment of employees or offers ofemployment;c) Charge recruitment fees to employees (or prospective employees);d) Fail to provide return transportation or not pay return transportation costs at the end ofemployment (for third country nationals/cooperating country nationals or for non-U.S. nationals
brought to the U.S. for work on a specific USG award);e) Provide or arrange housing that does not meet host country housing and safety standards;f) Fail to provide an employment contract, recruitment agreement, contract in written form, or otherrequired work document if required by law.

A violation of this Plan or of the Code of Conduct may result in disciplinary action.
II.

Definitions

Child, Children, Minor or Minors: Anyone under the age of 18 regardless of the age of majority or ageof consent in the local context or country.
1FAR 52.222-50. Combating Trafficking in Persons (March 2015). Similar information can be found in the USAID Mandatory Standard Provisions
and the State Department Terms and Conditions. 2 CFR 175 – Award Terms for Trafficking in Persons. USAID’s Mandatory Standard Provision on
Safeguarding Against Exploitation, Sexual Abuse, Child Abuse and Child Neglect

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Child Abuse: Emotional, physical, sexual, or any other ill-treatment carried out against a child by an adult.
Child Neglect: The failure to meet a child’s basic physical and/or psychological needs either intentionallyor through carelessness within activities supported by IIE that are responsible for the care of a child in theabsence of the child’s parent, guardian, or caregiver.
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 anyperson.
Covered Individuals: IIE employees, interns, volunteers, trustees, and representatives, as well as IIE
contractors, suppliers, consultants and their employees, subcontractors and representatives engaged by IIE,
working for IIE or on IIE’s behalf in any capacity, including for the performance of programs sponsored by
the US federal government, foreign governments, corporation and foundations.
Debt bondage: 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 asreasonably assessed is not applied toward the liquidation of the debt or the length and nature of those services
are not respectively limited and defined.
Employee: means an individual who is engaged in the performance of an award as a direct employee,
consultant, or volunteer of the recipient/contractor or any subrecipient/subcontractor.
Exploitation: Any actual or attempted abuse of a position of vulnerability, power differential, or trust for thebenefit of the individual leveraging their position, power, privilege, or wealth (through enticement,manipulation, coercion, or trickery). When carried out for a sexual purpose this constitutes sexualexploitation.
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 theperson 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.
IIE Community/IIE Team Member: all employees of IIE, including temporary employees, interns,volunteers, and members of the Board of Trustees and Officers.
Involuntary servitude: includes a condition of servitude induced by means of:(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 theperson did not perform such labor or services, that person or another person would suffer serious

Page 2 of 6harm or physical restraint, or(3) By means of the abuse or threatened abuse of law or the legal process.

Severe forms of trafficking in persons:(1) Sex trafficking in which a 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) The recruitment, harboring, transportation, provision, or obtaining of a person for labor orservices, through the use of force, fraud, or coercion for the purpose of subjection to involuntary
servitude, peonage, debt bondage, or slavery.
Sex trafficking: the recruitment, harboring, transportation, provision, or obtaining of a person for the purposeof a commercial sex act.
Sexual Abuse: Any actual or threatened physical intrusion of a sexual nature toward another person whether
by force or under unequal or coercive conditions. When carried out against a child by an adult, such conduct
is considered sexual abuse even in the absence of force or unequal or coercive conditions. All sexual activity
with a child is sexual abuse.
Subaward: an award provided by a pass-through entity to a subrecipient for the subrecipient to carry out partof a Federal award received by the pass-through entity. It does not include payments to a contractor or
payments to an individual that is a beneficiary of a Federal program. A subaward may be provided throughany form of legal agreement, including an agreement that the pass-through entity considers a contract.
Subcontract: any contract entered into by a legal entity to furnish supplies or services for performance of aprime contract or another subcontract.
Subcontractor: any supplier, distributor, vendor, or firm that furnishes supplies or services to or for a prime
contractor or another subcontractor.
Subrecipient: means a non-Federal entity that receives a subaward from a pass-through entity to carry out
part of a Federal program; but does not include an individual that is a beneficiary of such program. Asubrecipient may also be a recipient of other Federal awards directly from a Federal awarding agency.
III.

Applicability

Unless otherwise indicated below, this Plan applies to all IIE Team Members and the IIE Community,
including interns, volunteers, and members of the Board of Trustees. IIE Team Members with access to orcontact with program beneficiaries, involved in recruitment, housing arrangements, subawarding andsubcontracting, and program implementation, in particular, must ensure compliance in applying theapplicable elements of this Plan when carrying out their daily work.

IV.

Plan

IIE’s Plan includes the following key elements, each explained in further detail below:
A. CTIP and Safeguarding Awareness
B. Reporting Process
C. Recruitment and Wage Plan

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D. Housing Plan
E. CTIP and Safeguarding Guidelines
F. Prevention Procedures for Agents, Subawardees and Subcontractors
A. Awareness Programa. IIE Worldwide Code of Conduct
The IIE Worldwide Code of Conduct contains principles, guidelines, and requirements for all
IIE Team Members that reflect the highest ethical standards. The Code informs Team
Members of the USG’s and IIE’s commitment to Safeguarding and this Plan outlines theprohibited activities. Upon beginning work with IIE, all new Team Members are required
to read and sign IIE’s Worldwide Code of Conduct. Team Members are also required to readand certify their compliance with the Code of Conduct every year.
b. Training
The Grants and Contracts Department provides periodic mandatory training in Ethics andCompliance. In addition, Grants and Contracts holds periodic training activities with Team
Members in IIE’s regional and international offices in order to review the requirements ofspecific awards, including CTIP and Safeguarding requirements.
An online Combatting Trafficking in Persons training developed by the U.S. Department ofState and the U.S. Department of Homeland Security are also available to Team Members atthe following link: https://www.state.gov/humantrafficking-public-awareness-training/.
Additional resources on Safeguarding developed by USAID are available online at thefollowing link: https://www.usaid.gov/safeguarding-and-compliance/partners.
c. CTIP and Safeguarding AwarenessThis Plan is posted on Eddie.
For IIE Team Members, the IIE Worldwide Code of Conduct contains principles, guidelines,and requirements that reflect high ethical standards. The Code informs Team Members of theU.S. Government’s and IIE’s commitment to safeguarding against the prohibited activities
outlined in this Plan.
For program participants, this Plan will be posted in IIE’s application portal, Slate.
For subrecipients, subcontractors, and vendors, this Plan and additional resources will beposted on IIE’s procurement page.

B. Reporting Procedures
IIE’s Worldwide Code of Conduct requires I I E Team Members to report all violations of the Code,including any known or suspected cases of human trafficking activities, exploitation, sexual abuse, childneglect and child abuse. It contains procedures for raising compliance questions, concerns, and violations
without fear of retaliation including through an anonymous hotline.

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IIE requires all Team Members to report known or suspected cases of human trafficking, exploitation, sexualabuse, child neglect and child abuse to Grants and Contracts, the Legal Department, or through the hotline
if a Team Member prefers to report anonymously.
IIE maintains a Hotline for individuals who prefer not to discuss their concerns in a face-to-face setting.
Individuals can contact the Hotline through a toll-free telephone number (for domestic offices) or via awebsite. The Hotline is available 24 hours per day, seven days per week:
U.S. Hotline Number:

1-800-461-9330

Web Hotline: www.convercent.com/report
In addition, individuals may use an external hotline phone number provided by the Global Human
Trafficking Hotline at 1-844-888-FREE and its email address at help@befree.org, or the National HumanTrafficking Resource Center at 1-888-373-7888. Reports of human trafficking can also be submitted on its
website: http://www.traffickingresourcecenter.org/report-trafficking.
Upon receipt of credible information of human trafficking or safeguarding violations, IIE will report thematter to the appropriate agency Inspector General in a timely manner and cooperate in any investigation.
In investigating and responding to the alleged violations, IIE will take a “survivor-centered approach”.
Such an approach ensures the survivor’s dignity, experiences, considerations, needs, and resiliencies areplaced at the center of the process.
C. Recruitment and Wage Plan
IIE is committed to the highest ethical standards in recruitment and fair wage practices. IIE only uses
credible and established recruitment companies with trained employees, and prohibits charging recruitment
fees to the employee or prospective employee. IIE conducts market research to determine fair and equitablewages for its overseas employees that meet applicable host-country standards. IIE maintains a writtencompensation guide which is available to IIE Team Members on Eddie.
D. Housing Plan
While IIE does not typically provide or arrange housing for Team Members, occasionally temporary
living accommodations may be arranged for program beneficiaries. Team Members are required to takesteps to ensure that IIE contracts with responsible providers, and to the extent possible, that such housing
meets local housing and safety standards.
E. Safeguarding Guidelines
IIE has a zero-tolerance approach to any form of exploitation, sexual abuse, child neglect and child abuse
by any Covered Individual with access to, or contact with, program beneficiaries. IIE strictly prohibits all
Covered Individuals from engaging in any form of prohibited activities with program beneficiaries. All
Covered Individuals must fully comply with local and international child welfare legislation, and U.S. childprotection laws, or international standards, whichever affords greater protection. IIE has developed adetailed set of Safeguarding Guidelines that are available on Eddie.
F. Prevention Procedures for Agents, Subawardees and Subcontractors

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a. Flow-down of Anti-Trafficking and Safeguarding Requirements
IIE requires subawardee and subcontractor awareness of and compliance with anti- trafficking andSafeguarding requirements by including the applicable CTIP and Safeguarding provisions in theiragreements, whenever required by US laws and regulations or other sponsor requirements.
Subawards and subcontracts will include the Combating Trafficking in Persons clause, and otherapplicable regulations or provisions related to Safeguarding will be incorporated by reference.
Subrecipients and Subcontractors under USAID funding that receive agreements greater than
$500,000 are required to annually certify or provide an acknowledgement to IIE that they are incompliance with the CTIP regulations.
b. Subawardee and Subcontractor Monitoring and Management
IIE has a robust subawardee and subcontractor monitoring and management program. Team
Members who engage third parties as suppliers, consultants, independent contractors, or vendors
must use reasonable care to engage third parties who will act in a manner consistent with IIE’sprinciples. Responsibility determinations or pre-award questionnaires (risk assessments) areconducted for all subawardees and programmatic contractors under USG contracts, cooperative
agreements, and grants. Based on the results of the risk assessment, IIE may require special
award conditions, monitoring, and audit plans for the subawardee or programmatic contractors
under USG contracts. The appropriate regulations and/or provisions related to the USG agency
and award type must be flowed-down to all subawardees and subcontractors.

V.

Internal and External References:• 22 U.S.C. Chapter 78 Trafficking Victims Protection Act• 2 CFR 175 – Award Term for Trafficking in Persons• FAR 52.222-50 Combating Trafficking in Persons• FAR 52.222-56 Certification Regarding Trafficking in Persons Compliance• USAID’s Standard Provision M27. Safeguarding Against Exploitation, Sexual Abuse,Child Abuse and Child Neglect• USAID’s Standard Provision M.20 Trafficking in Persons• USAID’s Required as Applicable Standard Provision - Prohibition on the Use of AntiTrafficking Funds to Promote, Support, or Advocate for the Legalization or Practice ofProstitution• USAID’s Required as Applicable Standard Provision - Prohibition on the Promotion orAdvocacy of the Legalization or Practice of Prostitution or Sex Trafficking• U.S. Department of State Standard Terms and Conditions – Trafficking in Persons• IIE’s Safeguarding Guidelines• Department of State’s Office to Monitor and Combat Trafficking in Persons.

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