Prevention of Modern Slavery and Trafficking in Person's Policy

1. Scope

This Policy applies globally to any of The HALO Trust’s (HALO) employees, partners, and other representatives, both during and outside of working hours. This includes the Trustees, senior managers, officers, other employees, consultants, contractors, trainees, seconded staff, homeworkers, casual workers, agency staff, volunteers, interns, agents, sponsors, or any other person associated with HALO, wherever they are located.

This Policy applies across all HALO operations, except where local legislation imposes more stringent requirements. In all other circumstances, HALO’s standards take precedence.

HALO’s management, overseen by its Board of Trustees, hold accountability to ensure that HALO is vigilant in the prevention of Modern Slavery and the Trafficking in Persons, and that action is taken when this is identified.

All staff are also required to report any actual, or suspected modern slavery and trafficking in persons, using the reporting mechanisms available. There are various reporting mechanisms that are confidential, and reporting can also be done anonymously via SafeCall. Failure to report any concerns about modern slavery or trafficking in persons could result in disciplinary actions being taken.

2. Policy Purpose and Commitment

HALO is committed to taking all reasonable steps to prevent and respond to concerns raised in respect of modern slavery and trafficking in persons, and this Policy outlines our commitments and expectations in relation to this commitment.

Modern Slavery, trafficking in persons and exploitation are a reality in the world and according to the UN in 2022, approximately 50 million people around the world were held in modern slavery, with a significant increase in the last five years. HALO values not only HALO staff, but also communities impacted by HALO work and anyone who comes in contact with the HALO organisation – it is essential to be vigilant in both recruitment and supply chains.

HALO has zero tolerance towards modern slavery and trafficking in persons and requires contractors, supply chains and all those associated with our work to comply with our values. We also have a zero tolerance to inaction on any concerns raised in respect of Modern Slavery and Trafficking in Persons.

3. HALO Minimum Standards

The following behaviours are all forbidden under this Policy:

• The use of forced labour – work or service that was not voluntarily entered into;

• Bonded labour – using debt as a mechanism of control and forcing people to work to pay off the debt;

• Trafficking in persons- recruiting, harbouring, or transporting people, using violence, deception, or coercion to achieve control over them;

• Using deception or fraudulent pretences to solicit someone into employment;

• Child trafficking – the recruitment, transportation, transfer, harbouring, or receipt of a person under the age of 18 years of age, for the purpose of exploitation;

• Forced marriage – forcing someone to marry against their will, including those under the age of 18;

• Domestic servitude – denying someone working within the home the right to freedom of movement (including the confiscation of identity documents), withholding wages or limiting contact with their families;

• Descent based slavery – where someone born into a group or caste is identified as ‘slave class’;

• Child slavery – the enforced exploitation of any child under the age of 18 years of age for their labour, used for someone else’s gain;

• Child Labour – the engagement of children in work that is not appropriate for their age and stage of development, that impacts on their welfare and their education and that prevents appropriate childhood socialization;

• Withholding access to identify documents or immigration documents;

• Failure to provide return transportation to country of recruitment (unless the person is seeking survivor assistance or is a witness to human trafficking enforcement actions;

• The procurement of a commercial sex act;

• Charging recruited employees a placement or recruitment fee; or

• Providing accommodation that fails to meet the host country’s housing or safety standards.

Acts that directly support or advance trafficking in persons, including the following acts:

• Destroying, concealing, removing, confiscating, or otherwise denying an employee access to that employee's identity or immigration documents;

• Failing to provide return transportation or pay for return transportation costs to an employee from a country outside the host country to the country from which the employee was recruited, upon the end of employment if requested by the employee;

• Soliciting a person for the purpose of employment, or offering employment, by means of materially false or fraudulent pretences, representations, or promises regarding that employment;

• Charging recruited employees a placement or recruitment fee; or

• Providing or arranging housing that fails to meet the host country's housing and safety standards.

4. What Staff and Partners Should Expect From HALO

• Freedom of employees to terminate employment.

• Freedom to decline employment-based accommodation.

• Commitment to fair pay and working conditions.

• Prohibition of any threat of violence, harassment and intimidation.

• Prohibition of debt bondage and bonded labour.

• Prohibition of any disciplinary measure which includes an obligation to work.

• Prohibition of compulsory overtime.

• Prohibition of the use of worker-paid recruitment fees

• Prohibition of domestic servitude.

5. Remuneration

HALO aims to provide renumeration packages that:

• Attract the calibre and develop and motivate the mix of people required;

• Are fair, transparent, and non-discriminatory;

• Are legally compliant with relevant HR requirements;

• Are competitive and comparable with organisations of a similar nature; and

• Are affordable to HALO and ensure accountability to our donors.

6. Reporting

The HALO Trust ensures that staff, related personnel and impacted communities have multiple ways to report any concerns of modern slavery or trafficking in persons. These reporting channels are listed in the Safeguarding Policy.

7. Response to Reported Allegations of Modern Slavery

All modern slavery and trafficking in persons concerns reported will be investigated in the appropriate manner, in accordance with HALO procedures and guided by organisations expert in this area. This is likely to include a criminal investigation alongside an internal administrative investigation into breaches of HALO policies and the Code of Conduct. Any staff who has modern slavery or trafficking in persons charges upheld against them will face internal disciplinary procedures, in addition to any criminal investigation, and will face dismissal. Any supplier or other partner who has charges of modern slavery upheld against them will face an immediate ending of the contract.

HALO follows a survivor-centred approach. This means that the welfare and well-being of any victim/survivors are at the heart of any response to allegations of modern slavery or trafficking in persons. Confidentiality is an essential element of this – anyone found to have breached confidentiality may face disciplinary procedures. Our approach to allegations of modern slavery and trafficking in persons will ensure that solutions are sought to mitigate the survivor’s current situation and to prevent further risks from occurring.

It is recognised that there may be risks associated with the investigation of Modern Slavery and trafficking in persons and therefore a risk assessment will be completed with the victim/survivor on a case-by-case basis to ensure that they suffer no further harm as a consequence of HALO investigation. HALO will work with recognised experts in the field to ensure safe investigations.

Last updated: 12 August 2026