Modern Slavery and Human Trafficking Policy

Last modified: May 6, 2024

1. Introduction

The International HR Institute (IHRI) is committed to ensuring that there is no modern slavery or human trafficking within our organization, our supply chains, or our business operations. This policy outlines IHRI’s approach to preventing and addressing modern slavery and human trafficking in accordance with applicable international laws and human rights standards.

Modern slavery is an umbrella term that refers to situations of exploitation where individuals cannot refuse or leave due to threats, violence, coercion, deception, or abuse of power. Human trafficking involves recruiting, transporting, transferring, harboring, or receiving individuals through force, coercion, or deception for the purpose of exploitation.

We recognize that modern slavery and human trafficking can take many forms, including:

Slavery: Exercising powers of ownership over another person.
Servitude: The obligation to provide services imposed by coercion or force.
Forced or compulsory labor: The extraction of work or services from an individual under threat of punishment, without the individual’s voluntary consent.
Human trafficking: Facilitating the travel of individuals for the purpose of exploiting them.

2. Scope and Relevance

Modern slavery is a global issue that affects multiple sectors and industries, including those in which IHRI operates. This policy is applicable across all regions and countries where IHRI conducts business and applies to all employees, contractors, suppliers, and any other third parties working with or on behalf of IHRI.

It is crucial for IHRI and its stakeholders to recognize that modern slavery can occur in the form of:

Labor exploitation in supply chains.
Unethical recruitment practices.
Coercive labor practices in outsourced services.
Human trafficking facilitated through fraudulent employment offers.

While this may seem irrelevant to IHRI’s operations at first glance, it is essential to understand that every organization has a responsibility to ensure that no exploitation occurs in its workforce or supply chain. Preventing the exploitation of individuals not only aligns with our ethical standards but also protects our reputation and workforce.

3. Key Responsibilities

3.1 IHRI as an Organization
IHRI has the ultimate responsibility to ensure that modern slavery and human trafficking are prevented within our organization and across our supply chains. We commit to:

Maintaining robust policies and procedures aimed at preventing modern slavery and human trafficking.
Implementing due diligence checks throughout our supply chain to assess and address potential risks.
Ensuring transparent recruitment processes and compliance with labor laws.
Leading by example by conducting checks on all employees, contractors, and recruitment agencies.
Establishing open grievance channels and an accessible reporting mechanism.
Raising awareness about modern slavery within the organization and with our business partners.
Publishing an annual anti-slavery and human trafficking statement outlining the steps taken to prevent exploitation.

3.2 Managers and Leaders
Managers at IHRI play a key role in upholding this policy by:

Being approachable and attentive to employees’ concerns, particularly those related to exploitation.
Monitoring for signs of modern slavery or human trafficking, including in areas of recruitment and supply chain management.
Raising awareness of modern slavery risks among their teams.
Ensuring that employees are trained to recognize signs of human trafficking and exploitation.
Using their professional judgment to assess and respond to potential cases of modern slavery.
Ensuring that any concerns raised by staff are acted upon promptly and appropriately.

3.3 Employees and Contractors
Every employee, regardless of their role or seniority, has a responsibility to contribute to preventing modern slavery and human trafficking. This includes:

Being vigilant for any signs of exploitation or coercion in the workplace or supply chain.
Reporting any suspicions of modern slavery or human trafficking via the procedures outlined in this policy.
Speaking up if there are areas where IHRI can improve its practices to combat exploitation.

4. Risk Areas

IHRI recognizes several areas where modern slavery risks are higher:

Supply Chains: Particularly in regions or sectors with weak labor protections or high levels of informal work.
Recruitment Practices: Using third-party recruitment agencies without proper vetting can lead to unethical practices.
Outsourced Services: Industries like cleaning, catering, hospitality, and facilities management are often vulnerable to exploitation.
International Operations: Working across borders can create additional risks, particularly in jurisdictions with less stringent anti-slavery laws.

To manage these risks, IHRI will implement rigorous checks and monitoring systems, including:

Audits of suppliers to ensure compliance with anti-slavery standards.
Vetting processes for recruitment agencies and third-party contractors.
Detailed risk assessments of supply chain partners and outsourced service providers.

5. Policies and Procedures

5.1 Anti-Slavery Statement
IHRI will publish an annual anti-slavery and human trafficking statement, which will be made publicly available on our website. The statement will:

Detail the sectors in which IHRI operates.
Identify high-risk areas in our supply chain and operations.
Outline the steps taken to mitigate modern slavery risks.
Describe the actions IHRI has taken to ensure that slavery and trafficking are not occurring in our supply chains or organization.
Be reviewed and updated annually to reflect changes in business operations and evolving best practices.

5.2 Supply Chain Management
IHRI will implement a range of measures to monitor and manage supply chain risks, including:

Supplier Mapping: We will map all our suppliers to ensure transparency and traceability.
Risk Assessments: Regular risk assessments will be conducted to identify areas where modern slavery risks are higher, including conducting questionnaires for suppliers.
Audits and Compliance: Periodic audits will be conducted on suppliers, particularly those in high-risk regions or sectors. Any non-compliance will result in corrective actions, up to and including the termination of contracts.

All supplier contracts will include anti-slavery and human trafficking clauses, which will flow down through the entire supply chain. These clauses will strictly prohibit any form of slavery or exploitation.

5.3 Recruitment Practices
IHRI will ensure that all recruitment practices comply with applicable labor laws and ethical standards:

Approved Recruitment Agencies: IHRI will only engage with vetted, reputable recruitment agencies. All agencies must undergo background checks, and assurances will be required that they operate in compliance with anti-slavery laws.
Written Contracts: All employees, whether direct hires or temporary staff, will be provided with written contracts outlining their rights and responsibilities.
Direct and Indirect Fees: IHRI strictly prohibits the charging of any fees to individuals seeking employment, either directly or indirectly.
Legal Work Status: IHRI will verify the legal work status of all employees and contractors to ensure compliance with immigration laws.

If any signs of exploitation are detected during the recruitment process, IHRI’s reporting procedures will be followed immediately.

6. Identifying Modern Slavery

Modern slavery can be challenging to identify, but the following signs may indicate an individual is a victim:

The individual is not in possession of their identification documents (e.g., passport or work visa).
The individual is being controlled or directed by another person.
The individual appears withdrawn, frightened, or unable to engage in social activities.
The individual has little to no contact with their family or friends and seems isolated.
The individual appears to be living in overcrowded or substandard conditions.

While these indicators are not definitive, employees and managers should remain vigilant and report any concerns using the established procedures.

7. Reporting Modern Slavery

If anyone suspects that modern slavery or human trafficking is occurring, it is crucial to report it immediately. IHRI has established a confidential reporting process that allows employees, contractors, and third parties to raise concerns.

7.1 Reporting Channels
Reports of suspected slavery or trafficking can be made by:

Discussing the concern directly with a manager or supervisor.
Submitting a report through the ethics hotline by sending an email to: et****@ih**.ph.
If there is an immediate risk to safety, call local authorities or dial the national helpline for urgent assistance.

7.2 Confidentiality and Anonymity
All reports will be treated confidentially, and IHRI will take steps to protect the identity of individuals making reports. Anonymous reporting is also available, though providing contact details may assist in a more thorough investigation.

8. Training and Awareness

8.1 General Training
IHRI will provide training to all employees to raise awareness of modern slavery and human trafficking risks. This training will:

Teach employees how to identify signs of exploitation.
Explain the reporting mechanisms in place.
Promote a culture of vigilance and responsibility.

8.2 Specialist Training
Staff members directly involved in recruitment, supply chain management, and auditing processes will receive additional training on modern slavery risks specific to their areas of responsibility.

9. Monitoring and Review

IHRI’s Modern Slavery and Human Trafficking Policy will be reviewed annually to ensure it remains effective and aligned with current legislation and best practices. The outcomes of audits and reports will inform the review, and any changes will be communicated to all employees and stakeholders.

By committing to these measures, IHRI reaffirms its dedication to upholding human rights, preventing modern slavery, and ensuring that all individuals are treated with dignity and respect across our global operations.