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.​
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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

“It is against Amazon’s policy for any employee or Contingent Worker to engage in any sex buying activities of any kind in Amazon’s workplace or in any work-related setting outside of the workplace, such as during business trips, business meetings or business-related social events. When Amazon suspects that an employee has used company funds or resources to engage in criminal conduct, the company will immediately investigate and take appropriate action up to and including termination. The company may also refer the matter to law enforcement.”



Click here for King County's Policy​
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.
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.
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

In order to create a more equitable environment for female employees, Morgan Stanley adopted a no strip club policy in 2004.
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.    
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

“Computers and computer networks provided by the Company to employees should not be used to knowingly, recklessly, or maliciously post, store, transmit, view, download, or distribute any abusive, libelous, defamatory, obscene, or pornographic materials of any kind constituting a criminal offense, giving rise to civil liability, or otherwise violating any laws or Company policy.”
Carlson

“The Company and its employees shall strictly comply with all applicable laws and regulations regarding the prevention of the commercial sexual exploitation of children, including the prevention of the use of its premises for such exploitation.”
Reporting Policies & Procedures
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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. 
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Carlson

“All employees must be vigilant and immediately report to managers, supervisors, the Legal department or the Business Conduct and Ethics Hotline, as appropriate, all situations that come to their attention in the Company’s premises or businesses where sexual exploitation of children is suspected or appears to be intended.”
ManpowerGroup

Reporting: “We believe working with integrity and treating each other with respect fosters a culture that encourages innovation and helps all to be successful. We must report, as soon as possible, any activity that is suspected to be unlawful, fraudulent, or unethical.” 
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Process for employees to report: "(a) Talk to your supervisor, manager, local compliance officer, or ManpowerGroup’s Global Ethics Compliance Officer; (b) Use the business ethics hotline; (c) Contact the Global Ethics Compliance Officer and Assistant to the General Counsel."

Retaliation: “Our Company will not tolerate retaliation against anyone who makes a report in good faith. Anyone who experiences what they believe to be any form of retaliation should report this concern as soon as possible to a supervisor, local compliance officer or the Global Ethics Compliance Officer.”
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

“Failure to comply with the Code, the required certification process or failure to cooperate with an internal investigation of an actual or apparent violation of this Code may constitute grounds for disciplinary action, up to, and including, termination.”
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​.
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

“ManpowerGroup stands for the dignity of work, employment opportunities for all, ethical and effective business practices, a sustainable environment, and successful local communities. ManpowerGroup stands against practices that exploit people and limit opportunities for individuals to fully enjoy the dignity of work, especially the most vulnerable in society. We attempt to reduce abuse, focusing on creating awareness of, and opposition to [practices such as] . . . human trafficking.”
Supplier-related policies, including a code of conduct for suppliers and a procurement policy, are available on our Align Suppliers page.
Definitions of sex trafficking and sex buying

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