EngenderHealth Anti-Modern Slavery and Human Trafficking Policy

This document sets out EngenderHealth’s principles in tackling modern slavery and human trafficking in its operations and supply chain. EngenderHealth has a zero-tolerance policy for modern slavery and human trafficking in our business operations and will not permit the use of the organization’s resources (human, material, time, or funds) to support any activity constituting or connected to modern slavery, including human trafficking and exploitation.

Why do we have an anti-modern slavery and human trafficking policy?

EngenderHealth is committed to high standards of ethics and integrity throughout all operations, including the prohibition of actions that would support trafficking in persons and all forms of modern slavery. EngenderHealth will mitigate the risk of slavery and human trafficking in connection with our business operations and will enforce procedures to prevent such acts and report any violations.

What does this policy prohibit?

Slavery is forced labor conducted without proper compensation through ownership or control by another, with restrictions on the slave’s freedom of movement.

Human trafficking is a form of modern slavery. It involves recruitment, transportation, housing, transfer, or receipt of a person through threats, coercion, abduction, fraud, deception, abuse of power, or the giving/receiving of payments or benefits for an improper purpose including forced labor, sexual exploitation and/or slavery.

Whom does this policy apply to?

The anti-modern slavery and trafficking policy applies to all persons at EngenderHealth, including all employees and representatives.

EngenderHealth representatives are non-employees and other entities who are acting or could reasonably be understood by others to be acting as agents of EngenderHealth, including contractors, interns, volunteers, subrecipients, vendors and partners.

Who is responsible for implementing this policy?

All EngenderHealth employees and representatives are responsible for contributing to an environment that prevents slavery and human trafficking in our business operations, and for reporting suspected instances of these in compliance with the reporting and investigations procedures.

Violations of this policy will result in disciplinary action, up to and including termination of employment or supplier contract.

A. Awareness and Prevention

    Each EngenderHealth office is responsible for training employees to recognize and report the signs of slavery and human trafficking in accordance with this policy.

    B. Representatives

    EngenderHealth will not knowingly use forced labor in any of the services we provide, nor will we knowingly accept products or services from suppliers that employ or utilize forced labor. In turn, EngenderHealth expects our representatives to comply with this policy to ensure slavery and trafficking is not present in any of our supply chains or business practices.

    C. Reporting

    Suspicions and instances of attempted or actual breaches of EngenderHealth’s zero-tolerance for slavery, trafficking, and forced labor must be reported in accordance with the reporting and investigations procedures.

    Will I receive anti-modern slavery and human trafficking training?

    EngenderHealth ensures the dissemination of this policy through the following processes:

    This policy is published in the following locations:

    Who should I contact with questions about the policy or to report an incident?

    All employees, contractors, interns, volunteers, subrecipients, vendors and partners are required to report suspected violations of this policy immediately. Reports may be submitted through the following channels:

    Will my report remain anonymous?

    We will treat the identity of any victim(s), EngenderHealth employee or representatives who speak up, and any person suspected of wrongdoing or malpractice as confidential, to the extent that we are able to do so. Information will be shared on a strictly need to know basis and never openly discussed. We may need to reveal individuals’ identities during a disciplinary process, court proceedings, or otherwise as required by law, however, we will always make every effort to maintain confidentiality and will consult with relevant parties first.

    This Anti-Trafficking Policy is implemented in conjunction with the protections afforded by the EngenderHealth Whistleblower Policy. EngenderHealth will not tolerate any harassment, victimization, or other form of reprisal, against any person who raises concerns which they genuinely believe to be true and will take appropriate action to protect the reporter. Any harassment, victimization, or other form of reprisal will be treated as a serious disciplinary offence and may result in dismissal.

    However, any claims or allegations made by any EngenderHealth employee or representative that are found to be malicious or fabricated may result in disciplinary action being taken against the person making false allegations.

    The Whistleblower Policy is available for full review on both the EngenderHealth intranet and the public website at www.ethicspoint.com.

    How are investigations handled?

    EngenderHealth will carry out thorough and objective investigations into suspected acts of modern slavery or other breaches of this policy that are reported or discovered. We will investigate suspected violations as appropriate and determine what, if any, remedial or disciplinary action is appropriate.

    If, after an investigation has been conducted, it appears that an EngenderHealth representative or partner is involved, or is more likely than not to be involved, in an act of modern slavery or any other breach of this policy, then: