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Wildlife Trade Specialists

Safeguarding statement

Background

TRAFFIC International takes very seriously its responsibility to protect people, including our staff, volunteers, partners, consultants, contractors, trustees and others affected by our work, from any harm that may result from coming into contact with our organisation. 

TRAFFIC is a wildlife conservation charity primarily involved in researching legal and illegal wildlife trade globally, and encouraging necessary action by governments, businesses, and others. Since TRAFFIC does not work with vulnerable adults or children as key constituencies nor do we carry out aid-funded relief work, we do not have detailed safeguarding policies in place for working with children or vulnerable adults. 

Nevertheless, TRAFFIC employs around 150 staff carrying out a wide range of activities in different countries and works with a wide range of public and private sector partner organisations in carrying out work related to people and their use of natural resources. This document details TRAFFIC’s approach to safeguarding in this context. 

Guidelines for the Operation of TRAFFIC

The Guidelines for the Operation of TRAFFIC (2018) or the ‘TRAFFIC Guidelines’ provide the overarching framework for all TRAFFIC staff irrespective of country of residence or local hosting arrangements. The TRAFFIC Guidelines provide higher level guidance on professional behaviour and standards with more detailed guidance given in specific policies and guidance documents. TRAFFIC has the appropriate oversight, recruitment, and performance management policies and practices in place to support the standards of behaviour set out in its relevant policy documents. 

Professional conduct

TRAFFIC is a global, multicultural and multilingual organisation and an equal opportunities employer who aims to provide a supportive and flexible environment to encourage productivity, creativity and collaboration. TRAFFIC applies objective and fair criteria to ensure that staff members are selected, assessed and treated on the basis of their merits, abilities and experience relevant to their post.

TRAFFIC is committed to excellence, transparency and accountability in delivering its work, responding to the needs of its constituencies, and in conducting business with its stakeholders and suppliers. Staff members have the obligation to protect and promote the organisation’s interests, avoiding or declaring conflicts of interest should they arise, and acting with due respect for other people. This obligation includes refraining from infringing the physical and mental health, safety, privacy and human rights of others; refraining from any kind of coercion or harassment; and adopting practices that enhance human value and development in the workplace.

Any TRAFFIC staff member wishing to seek redress for grievances relating to his/her employment shall in the first instance report the grievance or dispute to his/her line manager who shall undertake to investigate the problem without delay and to seek resolution. If the staff member feels, for whatever reason, that his/her grievance or the dispute has not been or cannot be dealt with or easily resolved through this channel, he/she shall communicate directly with the Senior HR Manager at TRAFFIC International who shall organise the mediation of a solution. For staff reporting direct to the Executive Director of TRAFFIC International, such grievances shall be communicated to the Chair of the TRAFFIC Board who shall organise mediation of a solution.

It is the policy of TRAFFIC to conduct its business in an honest and ethical manner. TRAFFIC takes a zero-tolerance approach to bribery and corruption and is committed to acting professionally, fairly and with integrity in all its business dealings and relationships wherever it operates and implementing and enforcing effective systems to counter bribery. TRAFFIC will uphold all laws relevant to countering bribery and corruption. In particular, it is bound by the laws of the UK, including the Bribery Act 2010, in respect of its conduct both in the UK and abroad. TRAFFIC’s board has adopted an Anti-bribery Policy (2016),

It is the policy of TRAFFIC to monitor and control the risks that the organisation faces. Managing these risks helps TRAFFIC meet its objectives more successfully. It helps protect donor funds, staff, and the organisation’s reputation.  TRAFFIC’s board has adopted a Risk Management Policy (2016). 

TRAFFIC is committed to protecting against retaliation those staff members who report, as provided for hereunder, what they reasonably and in good faith believe to be ethical misconduct in accordance with this or any other TRAFFIC policy. TRAFFIC’s board has adopted a Whistleblowing Policy (2019). 

Information Management Policies

TRAFFIC’S IT Policy (2017) includes guidelines and procedures designed to ensure global consistency in approach to information technology and clarity regarding the use of equipment and related information management resources. All TRAFFIC staff are expected to follow this policy and to adhere to the recommendations to ensure the protection of TRAFFIC’s data and information.

Under the EU’s General Data Protection Regulation (GDPR) introduced in 2018, TRAFFIC needs to maintain records about the personal data it holds, how it uses it, and how it keeps it secure. Central principles of data protection legislation include ensuring that is that personal data is i) accurate; ii) not be kept for longer than necessary. Data protection requirements extend to staff, consultants, volunteers, and supporters in the wider sense (e.g. individuals who make donations, subscribers to newsletters, etc.).  

TRAFFIC’s Data Protection Policy (2020) includes guidelines and procedures to ensure consistency in TRAFFIC’s approach to handling personal data. Compliance with the Data Protection Policy is compulsory within TRAFFIC and with external implementing partners and service providers. TRAFFIC’s Privacy Statement (2018) is on its website; internal Data Protection Notices can be found on its intranet site.

Duty of care

Social safeguarding

TRAFFIC is committed to providing effective, legal, and safe support to wildlife law enforcement in order to deliver our conservation goals. At the same time, TRAFFIC recognises the complexities inherent in wildlife law enforcement actions and the need for appropriate conduct on the part of wildlife law enforcement personnel and non-governmental organisations supporting their work.  TRAFFIC therefore supports activities designed to respect and protect human dignity and to comply with international standards on human rights. As part of this commitment, TRAFFIC will not purchase, or provide funding for firearms or ammunition.

Information collection procedures and data security – safety and integrity

Some aspects of TRAFFIC's work deal with gathering sensitive information about illegal or unsustainable wildlife trade, carrying out analyses and providing actionable reports to responsible authorities and businesses. As part of this, TRAFFIC has a duty of care to its staff. There is a recognised risk assessment process that must be completed and receive appropriate authorisation prior to work/activities commencing. TRAFFIC Directors must be informed whenever projects involving sensitive activities are planned and must inform the Global Office. 

TRAFFIC must ensure all staff (including consultants) are adequately insured to carry out such work, including full medical and emergency evacuation insurance when on overseas duty travel, and that emergency contact details are held on file for all staff. 

Similarly, TRAFFIC also has a duty of care to protect those who provide information and to ensure the information is graded and evaluated so its quality and confidentiality is recorded and issued with a handling code to ensure correct dissemination. 

Any work of this type must be in compliance with the laws of the country where they are carried out, including data protection laws, and in accordance with TRAFFIC’s Sensitive Activity Management Policy (2019).

Additional guidance for staff is provided in TRAFFIC’s Law Enforcement Support Guidelines (2020) and Market Monitoring Guidelines (2018). 

Policy dissemination & monitoring - staff

Staff are taken through the above referenced policies as part of their induction and are sent copies by email to ensure that there is a record that the person has received them. All staff are also asked to sign annual statements on conflict of interest of which a record is kept on the HR Database (IUCN’s HRMS) and is monitored by the Global HR Manager.  All volunteers and interns receive contracts which include clauses on professional conduct, harassment and anti-bribery.

Periodic mandatory online training is provided to staff including training on cybersecurity, anti-bribery, data protection, bullying and harassment, and, from Spring 2020, on WWF’s Human Rights in Conservation and WWF’s Making sense of Safeguards modules.

Policy dissemination & monitoring – implementing partners and service providers

TRAFFIC carries out due diligence assessments (pre-award surveys) when engaging with new project implementing partners or awarding service contracts via tender. The assessment specifically refers to safeguarding, fraud and anti-bribery. Copies of the organisation’s Conflict of Interest Policy and Code of Ethics Policy are requested in addition to the most recent externally audited or prepared Financial Statements. 

TRAFFIC attaches its Standard Terms to third-party agreements /contracts which include obligations with respect to Commitment, Conflicts of Interest, Professional Conduct, Safeguarding, Counter-terrorism, Anti-Bribery and Anti-Fraud. The standard terms also state the need for a similar level of due diligence with any sub-contracts.

Statutory compliance

TRAFFIC International is aware that it is bound by the laws of the UK in respect of conduct both at home and abroad. We are committed to acting professionally, fairly, and with integrity in our business dealings and relationships wherever we operate. This includes implementing and enforcing effective systems including maintenance of a serious incidents register and reporting to the appropriate authorities. 

Feedback from the general public

Anyone wishing more information regarding TRAFFIC’s approach to safeguarding or to raise any concerns can contact TRAFFIC here.