Purpose
The purpose of this policy is to state The Center for Mind-Body Medicine (CMBM)’s commitment to: protect employees, Faculty/Supervisors, participants and the communities we serve from trafficking and abuse, and to respond to instances of human trafficking, both nationally and internationally. Our procedures include efforts to increase awareness about trafficking, explain
reporting processes, and maintain a system of accountability to ensure that CMBM employees, active contractors (faculty/supervisors), participants, and the communities we serve are protected from trafficking.
Moreover, it is CMBM policy that its partner organizations (including but not limited to PACT partners) are prohibited from engaging in or abetting human trafficking. CMBM will refrain from working with partner organizations, vendors or suppliers who may be involved in human trafficking. CMBM’s accompanying anti-trafficking plan describes how CMBM enforces this policy through education, procedures, compliance, and accountability.
Applicability
This policy applies to all CMBM employees, to faculty/supervisors who are currently conducting in-person or online mind-body training and/or engaged in training-related activities, to all CMBM partners, including but not limited to PACT employees, and to participants in CMBM programs and workshops.
Definitions
“Human trafficking,” “worker exploitation,” and “modern-day slavery” are terms used to describe situations where one person is exploited by another person for profit. The person or child may be forced to perform labor or engage in a commercial sex act. These are broad terms that cover many types of exploitation that use force, fraud, harassment, trickery or abuse of power.
Human trafficking involves three elements: 1) Perpetrator’s actions to obtain or maintain labor; 2) Perpetrator’s use of force, fraud, or coercion over the victim; and 3) Perpetrator’s intent to take advantage of the victim. The use of force, fraud, or coercion over a victim may include preventing a victim from controlling their own freedom, safety, personal documents, working and living conditions, and wages. If a worker does not have control over these areas, it is a potential sign of trafficking or exploitation.
Examples of forced labor can include situations where a worker is paid less than promised, does not receive pay, does not have access to their identification documents, or has no control over their money.
Prohibitive Behaviors
In addition to human trafficking as defined above, actions that directly support or advance trafficking are prohibited. Such actions include, but are not limited to:
- Procuring a commercial sex act
- Destroying, hiding, taking, or denying an employee access to their identity or immigration documents
- Offering employment under false pretenses
- Charging employees recruitment fees
- Providing wages and benefits that do not meet local legally required minimum standards
- Providing housing that does not meet local housing and safety standards
- Failing to provide transportation to an employee working outside of the country from which they were recruited upon the end of employment.
Mandatory Reporting
All CMBM employees and faculty/supervisors must report any/all suspicions or allegations of human trafficking and or child abuse. CMBM’s guide to the topics of Mandated Reporting and Duty to Warn is attached, and is also located here.
To report (a) a suspected trafficking incident (b) suspicious of child abuse or neglect, or (c) immediate safety concerns, CMBM has reporting systems in place to ensure that reporting is done quickly and appropriately. Please refer to CMBM’s anti-trafficking plan for additional details.
Inside the United States:
CMBM employees and contractors are mandated to report suspected incidents of trafficking through the National Human Trafficking Hotline at 1-888-373-7888.
CMBM employees and contractors are mandated to report suspected or confirmed instances of child abuse/neglect through The National Child Abuse Hotline 1-800-422-4453.
CMBM employees and contractors are mandated to call 911 if there is an immediate safety concern (such as witnessing a kidnapping or a child being abused)
Outside of the United States:
CMBM employees and contractors are mandated to report suspected incidents of trafficking through the Global Human Trafficking Hotline number, which is 1-844-888-FREE or e-mail (help@befree.org).
Ukraine:
CMBM employees and contractors in the Ukraine are mandated to report 1547, which is Ukraine’s Government hotline on anti-trafficking, prevention and response to domestic violence, gender-based violence, and violence against children. CMBM’s PACT Grants Officer and PACT Technical Assistance Monitor will be notified when a report is made in the Ukraine.
Within CMBM:
In addition to calling the National Human Trafficking Hotline and/or the National Child Abuse Hotline, employees and contractors may report, in confidence, suspected incidents of trafficking
or abuse/neglect by employees or contractors of the organization. The point of contacts within the organization to report suspected trafficking incidents are:
- CMBM Chief Operating Officer Randi Mitev 202-571-7758
- CMBM Human Resources Manager Jennifer Seager 202-765-2472
Training and Awareness
CMBM uses a variety of methods to create awareness around trafficking. These methods include written materials such as (i.e. onboarding documents, faculty contracts, participant registration
materials), visual and auditory materials (i.e. Zoom presentations), and through dialogue with participants, employees and contractors. CMBM ensures that participants, employees and contractors receive: Indicator Card.
CMBM has also posted our commitment to anti-trafficking on our website on our Hope and Healing for Ukraine page.
Human Resources
CMBM has an Anti-Trafficking Compliance Plan that outlines how CMBM operationalizes the requirements in this policy, including providing specific instructions on the appropriate implementation of recruitment and wage plans and non-salary benefits so that CMBM does not engage in any acts that could be perceived as human trafficking.
Compliance Officers for this Plan are:
- CMBM Chief Operating Officer Randi Mitev 202-571-7758
- CMBM Human Resources Manager Jennifer Seager 202-765-2472
All CMBM employees and faculty/supervisors must report any/all suspicions or allegations of human trafficking or non-compliance with the Human Trafficking and Worker Exploitation Policy.
Assessing Risks at the Project Level
The Clinical Director and Program Director share responsibility for identifying, mitigating, and monitoring specific trafficking risks in their programs related to programming and country challenges. This includes, but is not limited to: Having a procedure for ensuring that personnel and others recognize trafficking as well as child abuse, exploitation, or neglect; mandating that
personnel and others report allegations; investigating and managing allegations; and taking appropriate action in response to such allegations, including, but not limited to, dismissal of
personnel. Please refer to our accompanying plan, as well as to our mandated reporting policy listed above for details.
Enforcement
CMBM’s compliance managers are Chief Operating Officer Randi Mitev and HR Manager Jennifer Seager. If it is suspected that a CMBM employee or contractor is engaging in any prohibited activities including trafficking, failing to report suspicious activities including trafficking, or engaging in retaliatory actions for reporting said activities, the HR Manager (in consult with the COO) will complete a thorough investigation and take appropriate disciplinary actions including termination and reporting as appropriate. In the event that the suspected incident involves the COO or the HR Manager, the Chairperson of the Board of Directors is the
Point of Contact. Legal Counsel will be consulted throughout the process as needed.
CMBM’s Whistleblower policy is located here: Grievance & Whistleblower Policies.
Any/all questions about CMBM’s Anti-Trafficking Policy should be directed to HR Manager Jennifer Seager at 202-765-2472.
