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Trafficking in Persons Compliance Plan

Harirod Group Trafficking in Persons Compliance Plan

Trafficking in Persons Policy Harirod Group of Companies (“HARIROD”) has a robust compliance and ethics program aligned with our corporate values, particularly our dedication to enabling children to achieve their full potential and ensuring their overall well‐being in a protective and conducive environment. In September 2015, HARIROD formally adopted a zero tolerance policy regarding trafficking in persons (TIP). Plan’s leadership understands the importance of counter‐trafficking initiatives and has devoted sufficient resources to ensure compliance. The Compliance, Operations, and Awards Unit has led the organization’s efforts to draft the policy in the wake of updated Federal Acquisition Regulations. In summary, the policy prohibits individuals from:

  • Engaging in trafficking in persons
  • Procuring commercial sex acts
  • Using forced labor in the performance of the award
  • Directly supporting or advancing trafficking in persons

HARIROD’s TIP policy does not distinguish between severe and non‐severe forms of TIP activities, and therefore its employees are held to the highest standard of not engaging in or supporting any form of trafficking. HARIROD’s compliance plan consists of four pillars: awareness, prevention, recognition, and reporting.  


HARIROD’s TIP policy applies to all employees, including direct employees, consultants, and volunteers. It also applies to sub recipients whose contracts are valued at over $500,000. Where applicable, HARIROD includes the relevant FAR/CFR clauses in all subcontracts/sub agreements with sub recipients and recruiting agents. Harirod’s Business Development Unit (BDU) will share the responsibility of (1) ensuring that countertrafficking policies are known to third parties, (2) vetting third parties, and (3) obtaining certifications from third parties at the proposal stage. Third parties include suppliers, sub awardees, and recruiting agents.

Responsibility to Keep Children Safe

As one in four trafficking victims are children, this new TIP policy complements HARIROD’s longtime Child Protection Policy, Say Yes! To Keeping Children Safe. Harirod believes that in a world where children face so many threats of harm, especially in Afghanistan, it is our duty to ensure that we, as an organization, do not contribute in any way to harming or placing children at risk. Our Child Protection Policy provides the framework for the organization’s responsibility to keep children safe, ensuring that no child comes to harm as a result of their engagement with us, whether that be via their interaction with staff and those who represent us, or their participation in our programs, sponsorship, activities, and fundraising or advocacy campaigns.

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