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Anti-Human Trafficking Policy
1. Purpose of the Policy
Consistent with its mission to alleviate poverty, suffering and oppression, The Demography Project is committed to a work environment and operations that are free from human trafficking and exploitation. Human trafficking and exploitation are wholly contrary to our mission. The Demography Project will not allow human trafficking or slavery in any part of our community-based organization or with any of our partners. This policy sets forth the expectations we have of our team members to avoid engagement of, complicity in, or benefiting from human trafficking. .
2. Scope of the Policy
This policy applies to: The Demography Project; Members of Boards of Directors, Officers, Management, Team Members, seconded employees, interns, and volunteers (collectively “Team Members”); and Subrecipients, partner organizations, contractors, outside experts (including advocates), consultants, agents, representatives, and any other organization or individual that acts on The Demography Project’s behalf, at The Demography Project’s direction or with The Demography Project’s funding (collectively “Partners”).
3. Policy Statements
  • It is the policy of The Demography Project to comply with international, regional and local laws and regulations prohibiting trafficking in persons. The Demography Project's Team Members, and Partners must avoid and are prohibited from active engagement, complicity in or benefiting from any practice that constitutes trafficking in persons. The consent of a victim of trafficking is irrelevant.
  • “Trafficking in persons” means the recruitment, transportation (including failure to provide return 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” includes, 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. The recruitment, transportation, transfer, harboring or receipt of someone under the age of 18 for the purpose of exploitation is considered “trafficking in persons”.
  • Examples of Team Member or Partner conduct that would violate this policy because it contributes to trafficking in persons, include (but are not limited to): Procuring commercial sex acts; Using forced labor in the performance of any contract, cooperative agreement or award; Destroying, concealing, confiscating, or otherwise denying any Team Member access to his or her identity or immigration documents, such as passports or drivers’ licenses; Using misleading or fraudulent recruiting practices during the recruitment of Team Members or offering of employment/contract positions; such as failing to disclose, in a format and language accessible to the potential candidate, basic information or making material misrepresentations during the recruitment of candidates regarding the key terms and conditions, including wages and fringe benefits, the location of work, the living conditions, housing and associated costs (if provided by The Demography Project), any significant cost to be charged to the candidate, and, if applicable, the hazardous nature of the work; Using recruiters that do not comply with local labor laws of the country in which the recruiting takes place; Charging applicants/candidates/employees/volunteer recruitment fees; If required by law or contract, failing to provide return transportation or failing to pay for the cost of return transportation upon the end of employment; If required by law or contract, failing to provide or arrange housing that meets the host country housing and safety standards; or If required by law or contract, failing to provide an employment contract, recruitment agreement, or other required work document in writing.
  • Team Members who violate this policy will be subject to discipline, up to termination, and may be subject to criminal prosecution. Partners may have their agreements terminated, be prohibited from working with The Demography Project in the future and/or be subject to criminal prosecution.
  • Team Members and Partners must immediately report violations or suspected violations to The Demography Project's Hotline in accordance with The Demography Project Ethics Complaint and Whistleblower Policy. The Demography Project will not tolerate any form of retaliation against Team Members and Partners who report suspected violations of this policy in good faith.
  • The Demography Project will report Trafficking in Persons to the appropriate authorities and to the donor as required by its donors or by law, or, if not required, as The Demography Project determines to be appropriate. The Demography Project will cooperate with investigators and law enforcement in ensuring those responsible are held accountable.
4. Processes and Procedures Required to Ensure Compliance
5. Policy Administration
Responsibility for ensuring this policy is monitored, enforced, and remains up-to-date and compliant rests with The Demography Project's Legal Department and General Counsel.
6. Approved Policy
This policy was approved by The Demography Project's Board of Directors on August 16, 2021. This policy may only be amended or changed with the approval of the Board.
The Counter Trafficking in Persons Act, 2010 of Kenya
United Nations General Assembly A/RES/55/25: The Palermo Protocol on Human Trafficking

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