Introduction 

PSI has zero tolerance for modern day slavery and human trafficking. This statement is made pursuant to the UK Modern Slavery Act of 2015 and constitutes our endeavors to ensure that PSI’s operations and supply chains are free from slavery and human trafficking. 

Organizational Structure

PSI is an international non-governmental organization that provides consumer-driven global health services primarily to women, girls, and children in the areas of malaria; HIV/TB; contraceptives and reproductive health; water, sanitation and hygiene; and non-communicable diseases. With more than 5,000 staff worldwide, PSI is headquartered in Washington, DC and operates branch and affiliate offices in over 45 countries around the world.

Business and Supply Chain

PSI operates through both direct implementation as well as contracting with both local and international non-profits and NGOs, suppliers of health products, host government Ministries of Health, public and private healthcare providers, pharmacies, health promoters and educators, and researchers to provide increased access to affordable healthcare goods and services. In order to meet the objectives under PSI’s awards, PSI works with suppliers and subrecipients across all levels of our activities.

Due Diligence

As part of PSI’s commitment to identify and mitigate potential risks in suppliers’ and subrecipients’ operations, PSI undertakes a process of due diligence prior to issuance and signing of vendor agreements and sub-agreements with entities proposing to work on behalf of PSI.

In implementation of PSI’s supply chain and issuance of sub-agreements, PSI follows the regulatory guidelines based on the US Government Trafficking in Persons wording in all commodity and consultant contracts as well as integrating Modern Slavery Act requirements into UK-funded awards. PSI requires its vendors to prohibit activities directly related to modern day slavery and trafficking in persons. Additionally, it requires entities to report any credible violations to PSI and cooperate with any investigations or corrective actions.

Where PSI believes that a supplier or subrecipient is involved in modern slavery or human trafficking, PSI will take steps to investigate in accordance with policies and take appropriate actions. In 2020, PSI began to integrate safeguarding discussions and policy reviews with sub-recipients before signing new awards to ensure compliance with donor requirements and PSI’s standards. These reviews will continue and expand in 2021.

PSI is committed to continue taking actions which affirm its zero-tolerance approach to modern slavery. In an ongoing effort to improve compliance around modern slavery and human trafficking requirements, in 2021 PSI is undertaking a further review of the risks in its supply chain and with its subrecipients and will assess any areas where risk mitigation around modern slavery can be enhanced.

Our Policies

PSI will not tolerate any forms of abuse or modern-day slavery in its work or supply chains and has incorporated preventive measures into its policies guiding proper behavior and procedures for PSI personnel and into our vendor and sub-agreement templates.

Among these policies are:

• PSI Employee Code of Conduct;
• Trafficking in Persons policy;
• Recruitment and employment policies;
• supply chain agreements
• Implementing Subrecipient/Subcontractor agreements
• PSI’s Safeguarding Policy, updated and expanded in 2020
• Procurement due diligence process

All PSI personnel are expected to follow and uphold the policies above as well as the local and international laws that apply to PSI’s work. PSI’s Employee Code of Conduct must be signed by all staff which includes specifics on anti-trafficking in persons, child protection, and preventing sexual exploitation and abuse in all its forms.

Training, Awareness, and Reporting Concerns

All PSI staff are required to complete an annual code of conduct refresher training online which specifically includes a module on recognizing and preventing trafficking in persons. Compliance with this global requirement is tracked by individual and performance is discussed and followed up on directly by PSI’s Senior Management. Beginning in 2021, PSI will require an annual online training which covers all aspects of safeguarding, to include human trafficking and modern day slavery.

Additionally, the PSI Code of Conduct is signed by all PSI personnel to show that they have read, understood, and will abide by its policies and principles. The code of conduct statement specifically covers trafficking in persons, modern slavery, child welfare, and preventing sexual exploitation and abuse.

In order to confidentially or anonymously report any concerns related to modern day slavery, anyone internal or external to the organization is able to use PSI’s EthicsPoint website and phone numbers to bring forth allegations. All allegations are taken seriously and are investigated thoroughly. PSI offices are required to have posters with this contact information hanging in visible locations for all personnel, partners, and visitors to see and access. The EthicsPoint information is also included in PSI’s sub-agreement and vendor agreement templates.

PSI employees and those outside PSI may also report allegations or concerns about trafficking in persons to the Global Human Trafficking Hotline at 1-844-888-FREE or help@befree.org.

Review and Approval

PSI is a signatory of the UN Global Compact since November 2017 and reaffirms our commitment to the compact and upholding human rights.

This statement has been reviewed and approved on behalf of the PSI Board of Directors by Gail Harmon and Carolyn Brehm on November 11, 2020.