Policy 21 — Combating Trafficking in Persons and Forced Labour

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PHIG Policy Framework v1.2 · Policy 21 · Adopted 1 September 2026 · References: ASF Policy 10; US FAR 52.222-50 and 22 CFR 200/USAID anti-trafficking provisions; EU Directive 2011/36/EU; ILO Forced Labour Convention and Protocol; UK Modern Slavery Act principles

1. Purpose and scope

PHIG prohibits trafficking in persons, forced or compulsory labour, child labour and related practices in its own activities and in its supply chain, and complies with the anti-trafficking provisions of US and EU donors. Applies to the Board, the Director, staff, consultants, volunteers, experts, partners and suppliers of PHIG and all platforms of its network.

2. Policy

1. No person acting for PHIG engages in trafficking in persons, procures commercial sex acts, uses forced labour, or uses child labour.
2. No person destroys, conceals, confiscates or denies access to an employee’s identity or immigration documents; no misleading or fraudulent recruitment; no recruitment fees charged to workers; no unreasonable housing; written contracts in a language the worker understands; return transportation provided where required.
3. Suppliers, subcontractors and partners are contractually bound to the same prohibitions and must certify compliance; PHIG terminates any relationship where violations are found.
4. Suspected violations are reported immediately to the Director and, for US-funded actions, to the contracting officer and the Global Human Trafficking Hotline as required; for EU-funded actions, to the granting authority.
5. PHIG’s labour-studies work (GILS) and Sheni Labs’ supply-chain checks apply this policy in their assessments.

3. Procedures

1. Annual certification by the Director; supplier declarations in procurement files; training for staff involved in recruitment and procurement.

Responsibilities

Director; procurement and HR functions; Board.

Review

Every two years and when donor rules change.

Part of the PHIG Policy Framework. Breaches and concerns may be reported under the Whistleblowing Procedure to info@accreditation.ge (subject “Confidential — integrity”).