Adopt Policies *
An organization has two options:
(A) Create one central policy addressing all activities that are prohibited.
(B) Address sex trafficking and sex buying within existing policies.
Option A: Create One Central Policy *
Update company handbooks or internal policies to make clear what activities are prohibited. After consulting with an attorney, require contractors (e.g., consultants and other independent contractors) to comply with similar restrictions.
Update company handbooks or internal policies to make clear what activities are prohibited. After consulting with an attorney, require contractors (e.g., consultants and other independent contractors) to comply with similar restrictions.
SAMPLE LANGUAGE for Sex Trafficking Policy:
Our organization condemns all forms of sex trafficking, and any employee who engages in any sex trafficking activity, whether on company or personal time, will be terminated immediately. SAMPLE LANGUAGE for Sex Buying Policy: It is strictly against our organization's policy for any employee to engage in any sex buying activities of any kind during company time, while working on company business, or while engaged in any work-related activities (including during business travel), or using any company or work properties or resources whatsoever (including, without limitation, company credit cards, expense accounts, buildings, parking lots, grounds, equipment, computers, storage devices, software, websites, social media channels, networks, vehicles, and phones). This prohibition applies regardless of whether the activity is legal or tolerated in a particular jurisdiction, foreign or domestic. |
Amazon's Owner's Manual |
Option B: Update Existing Policies *
Update existing company policies to make clear what activities are prohibited. After consulting with an attorney, require contractors (e.g., consultants and other independent contractors) to comply with similar restrictions.
Update existing company policies to make clear what activities are prohibited. After consulting with an attorney, require contractors (e.g., consultants and other independent contractors) to comply with similar restrictions.
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Travel Policy
Prohibit the purchase of sexual services while traveling as a representative of the organization. |
SAMPLE LANGUAGE:
While traveling on business for the company, employees are prohibited from engaging in any sex buying activities of any kind. |
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Entertainment & Business Expense Policy
Prohibit the use of business expense accounts for the purchase of sexual services. SAMPLE LANGUAGE:
Employees are prohibited from using corporate credit cards or expense accounts or from submitting expense reimbursements in any manner related to sex buying activities. |
Morgan Stanley |
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Work Time Policy
Prohibit the use of work time to purchase sexual services. SAMPLE LANGUAGE: Employees are prohibited from engaging in any sex buying activities of any kind during company work time, while working on company business, or while engaged in any work-related activities. |
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Work Properties Policy
Prohibit the use of work properties (including buildings, grounds, computers, vehicles, and phones) to purchase sexual services. SAMPLE LANGUAGE: Employees are prohibited from using any company or work properties or resources whatsoever (including, without limitation, buildings, parking lots, grounds, computers, storage devices, software, websites, social media channels, networks, vehicles, and phones) to engage in any sex buying activities. |
Simon Corporation |
Carlson |
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Reporting Policies & Procedures
Clarify the process for employees to report suspected, planned, or actual violations. If possible, enable employees to self-report through an existing Employee Assistance Program; ensure that EAP counselors are trained. Include a commitment not to retaliate against employees who report. SAMPLE LANGUAGE for Reporting Policy: Employees are required to report any potential or suspected violation of this policy that comes to his or her attention and to participate fully in any investigation or resolution of any such violation. Failure to report any potential or suspected violation by any employee violates company policy and constitutes grounds for disciplinary action, up to and including immediate termination of employment. SAMPLE LANGUAGE for Non-Retaliation Policy: Our organization strictly prohibits retaliation against any employee for making a good faith report of any potential or suspected violation of our policy against sex buying activities and sex trafficking or for cooperating in an investigation of any such violation. SAMPLE LANGUAGE for Commitment to Act Policy: Our organization takes seriously all non-frivolous reports of potential or suspected violations of our policies against sex buying activities and sex trafficking and will investigate promptly and take appropriate remedial action based on our findings. |
Carlson |
ManpowerGroup |
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Disciplinary Policies & Procedures
Use your company’s existing disciplinary process for employees who violate your policies against sex buying activities and sex trafficking. Clarify the disciplinary process for managers who fail to report evidence of employees who are not compliant with these policies. |
SAMPLE LANGUAGE:
Any failure by a manager to report any potential or suspected policy violation that comes to his or her attention or to participate fully in any investigation or resolution of any such violation also violates our policy and constitutes grounds for disciplinary action, up to and including immediate termination of employment |
ManpowerGroup |
Organization-Wide Values Statement *
Some organizations add statements about sex trafficking and sex buying to their organization-wide statements about the values that the organization seeks to uphold.
Some organizations add statements about sex trafficking and sex buying to their organization-wide statements about the values that the organization seeks to uphold.
SAMPLE LANGUAGE:
Our organization upholds the value of each human life. We stand against abuse and exploitation, including sex trafficking and sex buying. In support of this stance, we have implemented policies and practices that clearly set forth prohibited activities by our employees and have educated them about these policies and practices, and will take remedial action for any violations of these policies. |
ManpowerGroup |
Supplier-related policies, including a code of conduct for suppliers and a procurement policy, are available on our Align Suppliers page.
Did your organization adopt a policy? Please let us know.
* We are not providing legal advice and you should not rely on any information we provide without consulting an attorney. We take reasonable steps in collecting, preparing, and providing our BEST Practices, but in no event are we liable for its truth, accuracy, or completeness. To the fullest extent permissible by law, we are not liable for use of any information under any circumstances.
© BEST 2018
© BEST 2018