Global statistics demonstrate beyond dispute that slavery and exploitation is a reality in our world. "Modern Slavery" is the term commonly used to refer to illegal exploitation of people for personal or commercial gain. Victims often find themselves trapped, against their will, in situations of domestic servitude, sexual exploitation, forced marriage, forced criminality, and forced labor often as the result of coercion, bribery, deceit or human trafficking.
MAG and MAG America value not only our own people, but those whom we serve; our beneficiaries and their communities. We commit to being vigilant in both our recruitment and supply chains.
Our values are to be determined, expert, professional, enabling and responsive. Our response to modern day slavery lives out these values by:
- Raising awareness across our teams to bring forward any concerns about our supply chain activities.
- Ensuring our employment and remuneration practices are fair and transparent across all territories.
- Challenging and supporting our suppliers to lead the fight against slavery and exploitation.
Our structure and business
MAG America is a registered 501(c)3 charity limited by guarantee and is governed by a non-executive Board of Directors. MAG America is headquartered in Washington, D.C. and MAG is headquartered in Manchester, UK. MAG currently delivers activities in countries across Europe, Africa, the Middle East, South and Southeast Asia and Central America. We directly employ over 3,800 staff, 95 percent of whom are local nationals. We work in partnership with six international organizations and 12 national organizations to deliver our work.
Our work has helped more than 16 million people in conflict-affected communities in over 40 countries since 1989, giving them greater safety and the opportunity to rebuild their lives, livelihoods and futures. We provide landmine and unexploded ordnance clearance, risk education, emergency response, training and education, arms management and destruction and contribute to the international mine action and AMD policy arena. Given that the majority of our work is delivered by our directly employed staff on the ground, with relatively small scale supply chains, we believe that the risk of slavery, human trafficking or exploitation having a connection with our business is relatively low, however, the policies and procedures outlined below further mitigate this risk, to the point that we are satisfied that we are compliant with the U.K. 2015 Modern Slavery Act.
Recruitment and selection policy
This policy ensures that all recruitment decisions are made fairly and transparently; that processes are free from all types of unlawful or unfair discrimination and bias to ensure that equality of opportunity is maintained for all candidates and prospective candidates. Recruitment and selection initiatives will be carried out in line with relevant legislative obligations and best practice and appointments will only be made on the basis of the skills, experience and aptitudes required for the role.
This policy seeks to ensure that we pay our people in line with the respective laws, cultures and market conditions of the relevant country context. MAG aims to provide remuneration packages that:
- attract, develop and motivate the caliber and mix of people required
- are fair, transparent and non-discriminatory
- are legally compliant with national legislative requirements, and (in the UK) in line with the modern living wage
- are competitive and comparable with organizations of a similar nature
- are affordable to the organization and ensure accountability to our donors.
Financial crime policy
We recognize that financial crime in all its forms is contrary to MAG America values of professionalism, transparency, accountability and can undermine organizational effectiveness. We are committed to the highest ethical standards and require all staff, consultants, trustees, contractors, partners, agents and other associates to adhere to similar standards and make themselves aware of, and comply with, this policy. We have established a ‘zero tolerance’ culture across the organization in which financial crime and all other forms of corruption and criminality, including slavery, human trafficking and exploitation are unacceptable.
MAG is committed to safeguarding the health, well-being and human rights of all staff, partners, and beneficiaries and to provide a safe and trusted environment for anyone who comes into contact with our work. Within the Safeguarding framework, MAG has a number of policies, procedures and guidelines in place to enable all individuals who are involved with or affected by our work to live free from harm, distress, abuse and neglect.
Our Safeguarding framework was reviewed and updated from February to May 2018. This included the review and update of the majority of the policies, procedures and guidelines that form the framework. Additions and amends were made to bring the policies in line with international NGO best practice. Following this update, implementation and socialization across the organization have begun, including training sessions which are currently being delivered to all staff in their local languages.
Reporting malpractice / whistleblowing policy
MAG America will always strive to maintain the highest standards of openness, integrity and accountability in its work. The reporting malpractice (whistleblowing) policy and procedure encourages employees and others who come into contact with our work who have serious concerns to voice those concerns. MAG America is committed to ensuring that genuinely held concerns will be thoroughly investigated and those who raise them will be protected against victimization and discrimination.
Policy on personal conduct
Employees (including consultants, volunteers and accompanied persons) are required to abide by MAG America’s policies and procedures, terms and conditions of employment, and to ensure that their personal conduct is in keeping with MAG America’s aims and values. By following the policy on personal conduct, all staff should be aware of what is expected of them and make the greatest contribution to achieving MAG America’s mission and vision. The personal conduct policy sets out the expectations that MAG America has of all employees, as well as providing examples of behaviors and actions that will always be unacceptable. The basis of this policy is to ensure that professional and personal action does not bring the organization into disrepute and to ensure that a positive working environment exists, which enables work of the best quality to be completed.
In particular, it requires staff to agree with the following statements:
- I will treat all people inside and outside of the organization fairly, with respect and dignity.
- I will not engage in any forms of humiliating, degrading or exploitative behavior.
- I will refrain from any form of harassment, discrimination, physical or verbal abuse, intimidation or exploitation.
- I will not engage in any exploitative, abusive or corrupt behaviors or relationships during my employment with MAG America.
- I will not knowingly participate in any illegal or criminal activities.
Protection of children and vulnerable adults policy
It is recognized that during the course of their work, MAG representatives may come into contact with children and vulnerable adults. MAG is committed to safeguarding these individuals from harm. Any form of abuse towards children or vulnerable adults by MAG representatives or other parties will not be tolerated. The Protection of Children and Vulnerable Adults Policy recognizes that all MAG representatives have a duty of care to protect children and vulnerable adults from harm. We have measures in place to prevent and minimise the risk of abuse, protect staff and safeguard the reputation of the organization. We will meet its commitment to protect children and vulnerable individuals from abuse through awareness, prevention, reporting and responding.
This policy creates a strict obligation on all staff to report any concerns they may have which involve children and/or vulnerable adults. Anyone who is found to have deliberately or accidentally withheld information or prevented full and thorough reporting to have taken place could face disciplinary action. This policy was updated in 2018, with the new version implemented in February 2018. Training on it is currently being provided to all staff, across the organization
Dignity at work policy
All staff should be free to carry out their work with dignity and respect in an environment that is free from discrimination, intimidation, harassment and bullying. In this policy, MAG sets out that it will take a zero tolerance approach to any behaviors which compromise these basic rights. This policy was updated in 2018, with the new version implemented in April 2018. Training on it is currently being provided to all staff, across the organization.
Procurement policy (transparency in supply chains (TISC) clause)
We are committed to ensuring that all procurement activities adhere to the principles of value for money, transparency and fair and open competition. We will not trade with any suppliers which we have good reason to believe exploit people. Our procurement policy is clear that suppliers must comply with local laws and regulations and that all procurement activities are in accordance with MAG’s Ethical Statement and Financial Crime Policy.
MAG’s Supplier Registration Questionnaire is used to identify any companies who do not meet our Code of Conduct for Suppliers and Ethics which includes the requirement to pay fair wages and the requirements to provide working conditions which are safe and hygienic and free from harsh or inhumane treatment. These standards are in line with the principles and values of the Inter Agency Procurement Group (IAPG) and specifically with the Suppliers’ Code of Conduct for IAPG Agencies: http://www.iapg.org.uk/vendors/.
Ethical statement policy
This protects MAG from engagement in relationships that have the potential to have severe negative impact on our perceived or actual integrity or reputation. Such relationships are those which we judge to be in conflict with our achievement, fulfilment or adherence to our stated vision, mission and values and the activities which institutions and individuals fund MAG to undertake. We take reasonable steps to undertake due diligence on providers of services and individuals and organizations providing financial and in-kind support. The statement sets out our minimum ethical expectations of clients, suppliers, investors, companies, organisational and individual donors. We ensure reasonable due diligence steps to satisfy ourselves that each partnership complies with our ethical statement.
In addition to the training on the MAG Safeguarding Framework, which is currently being delivered to all current staff in their local language as part of the implementation of our revised and updated Safeguarding Framework, as part of a comprehensive induction process, all new staff are given training on MAG policies and procedures, and are required to sign the Policy on Personal Conduct.
During the period from July 2018 to June 2019, MAG plans to further develop its approach toward combating modern slavery. Our plans for this period include:
- Reviewing and updating our Equal Opportunities Policy
- Reviewing and updating our Grievance Policy and Procedure
- Reviewing and updating our Recruitment Policy and Framework
- Providing further and ongoing training to our HQ and international managers on recruitment and Safeguarding
- Continuing the implementation of, and training on, our updated Safeguarding Framework for all staff globally
In addition to these commitments, due to high profile reports about historical failings within the international NGO sector, the MAG board and Global Leadership Team have agreed on the need to ensure that MAG is genuinely building a safeguarding culture and meeting the highest standards in this area. We have therefore commissioned an external review of MAG’s policies and procedures by independent safeguarding experts. The Independent Safeguarding Review will assess current culture and practices. It will do this with a view to strengthening the framework and ensuring that a safeguarding environment of the highest standard is in place.
The review will cover the policies that are included in MAG’s Safeguarding Framework, and engage with staff and communities, through a range of opportunities to determine how safeguarding is working in practice and how this can be strengthened.
The objectives of the independent review are to:
- Assess levels of awareness, understanding, attitudes and approaches towards safeguarding in the past and at present.
- Recommend how MAG can build a culture which sets and adheres to the highest standards of awareness, behavior, investigation and sanction as well as documentation with respect to safeguarding across the organisation.
- Recommend how MAG amends its processes and procedures immediately and over the longer term, while taking into account other sector-wide (humanitarian development sector) and sector-specific (HMA/AMD) initiatives.
- In the event of specific unreported incidents being identified, recommend whether further investigation is required and to make recommendations to MAG management.
The review was completed in September 2018 and its recommendations form a key part of our work plan in this area through 2019.