Zinc Network Modern Slavery and Anti Trafficking
Compliance Plan (2023)
Zinc Network has zero tolerance for any form of Modern Slavery(1). This Anti-Trafficking Compliance Plan (“Plan”) has been developed pursuant to the US Government’s (USG) Anti-Trafficking Provisions, (FAR) subpart 22.17, 52.222-50(h), FAR 52.222-56 regarding the USG’s zero tolerance policy on trafficking in persons by government contractors and award recipients; the UK Government’s Modern Slavery Act 2015; and Zinc Network’s commitment to safeguard all persons against Modern Slavery throughout our operations and supply chains.
Zinc Network is headquartered in London, UK, with additional offices and hubs in Tbilisi, Georgia; Washington, D.C.; Riga, Latvia; and a future location in Poland. Zinc Network currently employs approximately 80 staff, working locally and remotely, in our international offices and in the UK.
Zinc Network is a global international development company headquartered in London and with offices in Washington, D.C., Tbilisi, and Warsaw. We’re on a mission to achieve meaningful, measurable change through communications, technology, and behavioural science. We are a B-Corp certified, ethical business with 80+ team members from diverse professional and cultural backgrounds. We work with a broad range of governmental, NGO, and private sector clients, including USAID; the U.S. Department of State; the UK Foreign, Commonwealth and Development Office; UN agencies and missions; the European Commission; major charities and the private sector.
We conceptualise and create award-winning programmes, interventions, and campaigns that change the way that people think, feel, and act across a range of social issues including disinformation and misinformation, violent extremism, poor governance, threats to children and young people’s online safety, and gender-based violence.
Scope and Purpose
This Plan applies to all Zinc Network employees and representatives including but not limited to partners, independent consultants, suppliers, contractors, freelancers, influencers (e.g., social media collaborators and contributors), volunteers, interns, and others working on our behalf.
The purpose of this plan is to ensure that all Zinc Network employees and representatives, including partners and suppliers, are aware of the behaviours prohibited by the Anti-Trafficking Provisions, and to abstain from any behaviours that contravene the provisions of our Modern Slavery Policy. We also endeavour to make employees and representatives aware of the remedial and disciplinary actions that may be taken against persons who breach this Plan. Lastly, this Plan affirms our recruitment practices, wage allocation, and housing standards.
Certification of the Compliance Plan (2)
Zinc Network will submit, prior to a USG award, a certification for the portion (if any) of the contract that:
- Is for supplies, other than commercially available off-the-shelf items, to be acquired outside the United States, or services to be performed outside the United States; and
- Has an estimated value that exceeds $550,000.
The certification shall state that Zinc Network has implemented a compliance plan to prevent any prohibited activities and to monitor, detect, and terminate the contract with a subcontractor engaging in prohibited activities.
After having conducted due diligence, Zinc Network will attest that either (a) to its knowledge and belief, neither it nor any of its proposed agents, subcontractors, or their agents is engaged in any such activities; or (b) if abuses relating to any of the prohibited activities have been found, Zinc Network or its proposed partner has taken the appropriate remedial and referral actions.
Due Diligence and Risk Management
Zinc Network engages in a due diligence process for our staff, civil society organisations (CSOs), and partners (including suppliers and contractors). For projects deemed to be higher risk, the due diligence process is conducted by an external firm. As part of our due diligence procedures, we assess key safeguarding risks – including robust gender analyses – to prevent trafficking-related activities. Mitigation measures are routinely monitored and assessed throughout the project lifecycle.
Zinc Network maintains a Risk Management Framework to ensure robust assessments across all projects. We do not engage in activities where the residual risk is assessed as high or extreme, unless there is a critical reason for doing so. All project risks are monitored through the Project Risk Register, which is completed during the proposal and award stages. The assessment phase of the Risk Management Methodology, as articulated in our Risk Management Policy, utilises Zinc Network’s Risk Register template to identify, categorise, score, and apply strategies to threats and risks. To ensure that risks are effectively managed throughout the organisation (and with corporate or delivery/consortium partners and civil society groups), we operate three levels of risk registers, as follows:
- Corporate Risk Register
- Operational Risk Register
- Project Risk Register / Partner’s Risk Register
Safeguarding, including prevention of Modern Slavery, is an integral part of our risk management approach and is integrated across the three levels of risk registers. Project leads are responsible in ensuring they integrate safeguarding into the project risk assessments and accompanying mitigation plans and ensure regular monitoring throughout the project. Essential to accurately identifying and mitigating safeguarding risks are three key activities:
- Risk Assessments identify specific safeguarding risks based on the context of the project and location where activities occur.
- Risk Mitigation Plans respond directly to the identified risks by articulating specific actions to reduce the possibility of the risk happening.
- Monitoring through routine assessments ensures that mitigation measures are effective, and any newfound risks are adequately addressed
All Zinc Network employees must acknowledge the Modern Slavery Policy and attest that they have familiarised themselves with all policies contained on our Human Resources platform, Bamboo. As described in our policy, Zinc Network employees and representatives, including partners and suppliers, are prohibited from engaging in any form of Human Trafficking, also known as Trafficking in Persons (TiP), including but not limited to:
- Procuring commercial sex acts before, during, or after business hours or while traveling for work.
- Sex trafficking in which a commercial sex act is induced by force, fraud, or coercion.
- Recruiting, transporting, or harbouring a person for labour or services by force, fraud, or coercion for the purposes of bonded or debt labour, involuntary servitude, or slavery.
- Destroying, concealing, confiscating, or otherwise denying any employee access to their identity or immigration documents, such as passport, national identification card, or driver’s license.
- Providing and/or arranging housing that fails to meet the host country’s housing and safety standards.
- Engaging in misleading or fraudulent recruitment practices during the recruitment of employees or offering of employment to employees. This includes failing to disclose or making material misrepresentations about key terms and conditions of employment, including wage and benefits, work location(s), living conditions, housing accommodations and associated costs (if provided by Zinc Network), significant costs to be charged to the employee, and hazardous or unsafe work, if applicable.
Failing to provide an employment contract or other required work documents, if required by law or contract, or contravening the standards outlined in Recruitment & Wage Allocation.
Induction and refresher training modules on safeguarding policies and ethical practices, including our Modern Slavery Policy, are provided at the time of onboarding, as needed, and on a rolling basis, organised by the Managing Director (MD) in collaboration with the Human Resources Manager. Employees may contact the MD with any questions, clarifications, or for further discussion.
Recruitment and Wages
Zinc Network is committed to fair and lawful recruitment practices and wage allocation. We prohibit charging recruitment or placements fees for any candidate or employee, and we are committed to ensuring that any recruitment agencies contracted to find candidates or employees comply with this prohibition. As such, we will only work with professional recruiters made up of sufficiently trained employees that comply with all labour laws of the country where the recruitment takes place.
Zinc Network will pay to all employees such wages that meet applicable host-country legal requirements or will explain any variance. Where required by law or contract, Zinc Network will provide to every employee an employment agreement or other required work document, written in a language the employee understands, containing all required information about the terms of conditions of employment, which may include, by way of example, the work description, wages, fringe benefits, prohibition on charging recruitment fees, work location(s), living accommodations and associated costs, time off, roundtrip transportation arrangements, grievance process, and content pertaining to applicable laws and regulations prohibiting trafficking in persons. If the employee must relocate to perform work, Zinc Network will provide the required work document at least five (5) days in advance.
Zinc Network will fully and accurately disclose, in a format and language accessible to the employee, all key terms and conditions of employment, including wages and benefits, work location, living conditions, housing and associated costs (where provided or arranged by Zinc Network), significant costs to be charged to the employee, and, if applicable, the hazardous nature of the work. For any staff required to relocate for work, Zinc Network will provide or pay the cost of return transportation at the end of employment for any employee who is not a national of the country where the work took place and was brought into that country by Zinc Network for purposes of working on the contracted project.
Additionally, Zinc Network will provide or pay the cost of return transportation at the end of employment for any employee who is not a US or UK national and was brought into the US or UK for purposes of working on a Covered Agreement, if payment of such costs is required under existing temporary work programs or pursuant to a written agreement with the employee for portions of Covered Agreements performed outside the US. This requirement does not apply to employees who are:
- Legally permitted to remain in the country of employment and who chooses to do so; or
- Exempted by an authorized official of the contracting agency from the requirement to provide return transportation or pay for the cost of return transportation.
For a victim of trafficking in persons who is seeking victim services or legal redress in the country of employment, or for a witness in an enforcement action related to trafficking in persons, Zinc Network will provide the return transportation or pay the cost of return transportation in a way that does not obstruct the victim services, legal redress, or witness activity.
Zinc Network employs robust recruitment practices to assess each prospective candidate’s suitability to work with vulnerable populations and contribute to a safe and healthy workplace culture, which includes but is not limited to:
Interview Questions: At least one question will be a standard part of the interview process to evaluate candidate’s values, beliefs, or attitudes and gauge suitability to work with project participants, vulnerable populations, and/or with sensitive data, personally identifiable information (PII), and private information.
Reference Checks: A minimum of two reference checks will be completed for any candidate who has received a job offer. Each reference check will include one question about the candidate’s suitability to work with vulnerable populations and capacity to contribute to a safe workplace culture.
Background Record Checks (BRCs): Comprehensive BRCs are completed within all locations where a candidate has lived. BRCs may include but are not limited to police checks, employment verification, sexual offender registry (as available), identity confirmation, and anti-terrorism vetting.
Affirmative Disclosure: As part of the BRC process, candidates who have received a job offer will disclose any previous disciplinary action against them resulting from a substantiated safeguarding (including any breaches involving trafficking- related activities) or workplace investigation.
Probationary Period: Staff will be monitored during their probationary period to ensure compliance with the Safeguarding and Modern Slavery policies.
If providing accommodation, Zinc Network will provide or arrange housing that meets the host country’s housing and safety standards.
This Plan applies to all downstream partners and will be made available via the Zinc Network website and a copy provided at the time of any signed agreement, at which time the partner will certify their understanding to comply with the Modern Slavery Policy and Compliance Plan. Any downstream partner awarded a project valued at $550,000 USD or more who are performing work overseas is required to have a compliance plan of their own to prevent prohibited activities associated with this Plan, and to monitor, detect, and terminate any of its contractors, consultants, suppliers, subcontractors, or sub-recipients engaging in prohibited activities. The Partner will provide a copy of the compliance plan to Zinc Network upon request.
Zinc Network has zero tolerance for breaches of this Plan. In accordance with our Safeguarding, Modern Slavery, and Whistleblowing policies, we encourage all employees and representatives, including Partners and Suppliers, to report any concern, suspicion, or knowledge about the misconduct of another person within our organisation that contravenes this policy – no matter how seemingly small or trivial – to ensure accountability for creating and sustaining a culture to combat trafficking-related activities. Failure to report a concern, suspicion, or known incident is a serious violation of this policy and may result in disciplinary action, up to and including termination of employment or contract.
Zinc Network employees and representatives may report concerns through our Whistleblowing email via firstname.lastname@example.org or hotline 0800 030 5182, directly to our Safeguarding Officer via email@example.com , or directly to the Global Human Trafficking Hotline at 1-844-888-FREE and its e-mail address at firstname.lastname@example.org.
Zinc Network will take appropriate action against anyone who retaliates against an employee or representative for reporting a concern believed or known to be a breach of this Policy. Anyone found to have engaged in retaliatory behaviours will be subject to disciplinary action, up to and including termination of employment or contract.
If Zinc Network receives an allegation of trafficking-related activities, we are committed to responding in a timely and effectively way to interrupt the continuation of harm and deliver the necessary care to help the affected person(s) heal and recover. This is outlined in our Modern Slavery Policy, Safeguarding Policy, and covered in our Safeguarding Complaint Procedures.
Upon receipt of any credible information alleging prohibited trafficking-related activities, Zinc Network will investigate and report its findings and determine what, if any, remedial action is required. Zinc Network will comply with all external reporting requirements related to a breach of this Plan. Zinc Network’s management will review the final investigation report to determine the necessity of proportionate disciplinary action, in accordance with our Disciplinary Procedures.
Zinc Network’s Managing Director (MD) will be responsible for immediately notifying the contracting officer and the appropriate agency Inspector General, when applicable, of the information received and any resulting remedial action taken. We will cooperate fully with the respective government agency responsible for ensuring accountability with the Policy and Compliance Plan, which may include but is not limited to investigations, audits, or corrective actions about trafficking-related activities, and where Zinc Network
is responsible to provide timely and complete responses to document requests and providing reasonable access to Zinc Network facilities and employees.
Zinc Network will protect all employees suspected of being victims of or witnesses to prohibited activities, prior to returning to the country from which the employee was recruited and will not prevent or hinder these employees from cooperating fully with authorities.
Communications and Awareness
Zinc Network will post the policy and Compliance Plan on our Human Resources platform, Bamboo.