Anti-modern slavery and anti-human trafficking policy February 2026 Page 2 of 10 Anti-modern slavery and anti-human trafficking policy Authors: Deputy Director General - Corporate Services Senior Supply Chain Manager Approval date: February 2026 Lead manager responsible for operational delivery: Senior Supply Chain Manager Version: 2.0 Effective date: February 2026 Revision history Version No. Effective date Approved by and date Summary of changes Next scheduled review 1.0 11 September 2020 ILRI Board of Trustees Date: 11 September 2020 Original policy Modern slavery and human trafficking policy February 2026 2.0 February 2026 ILRI Board of Trustees Date: February 2026 Updated policy Anti-modern slavery and anti-human trafficking policy January 2029 Related documents ILRI policies: • Supply chain management • Safeguarding policy on protection from sexual exploitation, abuse, and harassment (PSEAH) • Workplace conduct and protection • Whistleblowing • Anti-fraud and anti-corruption • IRS and NRS PPMs • Risk management • Conflict of interest • Code of conduct Global framework The Universal Declaration of Human Rights CGIAR framework/policy CGIAR Integrated Partnership: Protection against sexual misconduct, exploitation, abuse, and human trafficking Page 3 of 10 ILRI Procedures • Policy procedures on Reporting Ethical Breaches • Disciplinary policy procedures Other relevant documents Appendix Definitions Page 4 of 10 Contents Summary of key updates .............................................................................................................. 5 1. Policy statement ................................................................................................................. 6 2. Context and purpose .......................................................................................................... 6 3. Scope and applicability ....................................................................................................... 6 4. Key principles ..................................................................................................................... 7 5. Legal and institutional framework ...................................................................................... 7 6. Prevention and due diligence .............................................................................................. 7 6.1. Ethical recruitment and employment practices .................................................................... 7 6.2. Third-party labour suppliers ................................................................................................. 7 6.3. Systematic review of third parties and supply chain ............................................................ 7 6.4. Vendor onboarding risk assessment ..................................................................................... 7 6.5. Ongoing due diligence for existing vendors and partners .................................................... 8 6.6. Communication, awareness and training ............................................................................. 8 6.7. No-fee recruitment ............................................................................................................... 8 7. Reporting ............................................................................................................................ 8 7.1. Investigation, remediation, and consequences .................................................................... 8 8. Roles and responsibilities ................................................................................................... 8 8.1. Institutional Leadership Team .............................................................................................. 8 8.2. People and Culture ................................................................................................................ 8 8.3. Supply Chain .......................................................................................................................... 9 8.4. Supervisors ............................................................................................................................ 9 8.5. All staff, partners, and contractors ....................................................................................... 9 9. Monitoring and review ....................................................................................................... 9 Appendix .................................................................................................................................... 10 Definitions .................................................................................................................................. 10 Page 5 of 10 Summary of key updates This revised policy strengthens ILRI’s framework for preventing and addressing modern slavery and human trafficking across its operations and supply chains. It introduces clearer and more robust prevention and due diligence measures, including a firm commitment to no fee recruitment, enhanced supplier and partner due diligence, and the application of additional scrutiny and audits in higher risk contexts. Modern slavery risk considerations are embedded across procurement, recruitment, partnerships, and field-based activities to support a consistent, risk-based approach to prevention and mitigation, diligence measures, including a firm commitment to no fee recruitment risk contexts. The policy also enhances reporting and protection arrangements by clearly setting out ILRI’s reporting channels, reaffirming the availability of anonymous reporting, and reinforcing protections against retaliation for individuals who raise concerns in good faith. In addition, the policy clarifies roles and responsibilities across ILRI functions, strengthens expectations for awareness and capacity building in higher risk areas, and reaffirms alignment with applicable international standards, CGIAR frameworks, and legal requirements. All core protections including ILRI’s zero-tolerance stance, supplier and contractor obligations, whistleblowing safeguards, and disciplinary consequences, are fully retained and consolidated within a clearer, more coherent policy structure. Key changes since last version • Prevention and due diligence strengthened. The policy introduces explicit requirements for no-fee recruitment and reinforces supplier and partner due diligence measures, including enhanced scrutiny and audits for higher-risk engagements. • Reporting and protection arrangements clarified. ILRI’s reporting channels (Ethics Point and the dedicated complaints mailbox) are clearly specified, with anonymous reporting and nonretaliation protections reaffirmed through alignment with the Whistleblowing Policy. • Roles and responsibilities clarified. Responsibilities are clearly articulated for the Institutional Leadership Team, People & Culture, Ethics and Business Conduct, Supply Chain, Supervisors, and all staff, partners, and contractors. • Legal and institutional alignment reaffirmed. The policy calls for alignment with best practices designed to combat forced labor, servitude, and human trafficking, e.g., the UK Modern Slavery Act (2015), the UN Guiding Principles on Business and Human Rights, ILO Forced and Child Labour Conventions, OECD Guidelines, and applicable CGIAR frameworks. • Core protections are retained and consolidated. ILRI’s zero-tolerance stance, supplier and contractor obligations, whistleblowing safeguards, and disciplinary and contractual consequences are fully retained, with improved clarity and coherence and no reduction in safeguards. Page 6 of 10 1. Policy statement ILRI is committed to upholding the highest standards of integrity, ethics, and respect for human rights across its global operations, research programs, partnerships, and supply chains. ILRI maintains a zero-tolerance approach to all forms of modern slavery and human trafficking, including forced labor, bonded labor, involuntary servitude, child labor, and trafficking in persons. ILRI expects all staff, partners, contractors, and suppliers to uphold standards and is committed to taking reasonable, proportionate, and risk-based measures to prevent, identify, and address modern slavery and human trafficking risks. 2. Context and purpose This policy on modern slavery and human trafficking sets out the approach to: • Preventing modern slavery and human trafficking • Identifying and mitigating related risks across operations and supply chains • Ensuring ethical labour and human-rights practices in employment, procurement, research, and partnerships • Ensuring concerns are reported promptly and addressed appropriately • Demonstrating compliance with applicable laws, CGIAR standards, and donor requirements. Modern slavery and human trafficking of any kind and nature are against the core principles and values of ILRI. ILRI views these issues as unacceptable and is committed to preventing them and to taking effective action if they are found to be occurring. This policy shall be applied along other policies relevant to preventing modern slavery and human trafficking in the institute’s operations and that bring to bear measures that will prevent modern slavery and human trafficking of any kind in relation to ILRI’s activities and operations including Supply Chain. The policy is benchmarked to the provisions made by United Nation conventions and treaties whose subject matter touches or may touch on modern slavery and human trafficking, including but not limited to the UN Compact; the United Nations Convention Against Transnational Organized Crime and the protocols thereto; International Covenant on Civil and Political Rights (ICCPR); International Covenant on Economic, Social and Cultural Rights (ICESCR); Convention on the Elimination of All Forms of Discrimination against Women (CEDAW); Convention against Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment (CAT); Convention on the Rights of the Child (CRC); International Convention on Protection of the Rights of All Migrant Workers and Members of Their Families (ICMRW); and ILRI's People and Culture policies and Code of Conduct and all applicable laws and regulations. 3. Scope and applicability The policy applies globally to all parties engaged in ILRI’s research programs, field activities, and operational functions: • All staff and ILRI Board of rustees • Consultants, interns, fellows, visiting scientists, and contractors • Suppliers, service providers, partners, agents and subcontractors Where ILRI policies and procedures differ from local laws and this policy has more rigorous expectations, this policy must be followed. Conversely, where local law establishes higher or mandatory requirements, those requirements shall prevail. Page 7 of 10 4. Key principles ILRI’s activities and approach to anti-modern slavery and anti-human trafficking are grounded in: • Respect for Human Rights: Upholding international labor and human-rights standards • Zero Tolerance: Strictly prohibiting all forms of exploitation and abuse • Prevention and Due Diligence: Identifying and mitigating related risks proactively • Proportionality: Applying controls based on assessed risk • Continuous Improvement: Strengthening systems as risks evolve 5. Legal and institutional framework The Policy focuses specifically on prevention, supply-chain integrity, and due diligence obligations, and does not replace or duplicate the protections and processes outlined in the Safeguarding policy. Where concerns involve sexual exploitation, abuse, or harm to children or vulnerable persons, these matters shall be addressed under ILRI’s Safeguarding policy on protection against sexual misconduct, exploitation, abuse, and human trafficking. ILRI shall comply with all applicable laws, statutes, regulations, and codes in force, including but not limited to: • UK Modern Slavery Act (2015) • UN Guiding Principles on Business and Human Rights • ILO Forced Labor and Child Labor Conventions • OECD Guidelines for Multinational Enterprises • CGIAR Ethics Framework, Code of Conduct, and Procurement Standards • Applicable host-countries (Kenya and Ethiopia) labor legislation 6. Prevention and due diligence 6.1. Ethical recruitment and employment practices Recruitment and engagement shall follow ILRI’s established processes and shall be supported by written contracts that clearly define the employment relationship and terms of engagement. ILRI shall ensure that recruitment and employment practices do not create conditions that increase vulnerability to modern slavery or human trafficking. 6.2. Third-party labour suppliers Third parties supplying workers or labor to ILRI (including contractors, service providers and labor intermediaries) shall comply with this policy and any related ILRI standards incorporated into contractual arrangements. 6.3. Systematic review of third parties and supply chain ILRI shall conduct risk-based systematic reviews of third parties, partners, and suppliers to identify and mitigate risks of modern slavery and human trafficking across ILRI’s operations and supply chains. 6.4. Vendor onboarding risk assessment ILRI shall identify and assess potential risk areas when engaging new vendors, partners, or contractors, and shall reinforce due diligence checks in high-risk contexts as part of the selection and contracting process. Page 8 of 10 6.5. Ongoing due diligence for existing vendors and partners ILRI shall perform ongoing due diligence when reassessing existing vendors, partners, and suppliers, and shall periodically reassess key supply networks, including through supplier screening, audits where appropriate, and targeted due diligence questions related to labor practices and the treatment of workers. 6.6. Communication, awareness and training ILRI shall promote awareness of modern slavery and human trafficking risks across its activities and operational networks, supported through training, internal and external communication, and clear guidance on how and where to report concerns. 6.7. No-fee recruitment ILRI shall ensure that no-fee recruitment is practiced across all ILRI hiring and engagement processes. Recruitment agencies, service providers, and any intermediaries engaged by ILRI shall be prohibited from charging fees of any kind to job applicants or candidates. 7. Reporting Any suspicion or concern relating to modern slavery or human trafficking must be reported promptly. ILRI provides multiple secure channels for reporting any suspicion or concern related to modern slavery or human trafficking. Reports may be submitted through ILRI’s designated whistleblowing reporting channels: • A secure online whistleblowing platform that provides reporting, case tracking, and investigation management https://report.syntrio.com/ilri/ • A secure whistleblowing email address (ilricomplaints@cgiar.org) accessible to the Director General and the Head of People and Culture Anonymous reporting is permitted, and ILRI strictly prohibits retaliation against any individual who reports concerns in good faith or participates in related investigations. Reporting suspected cases of modern slavery is the responsibility of all. The reporting of concerns or breaches of procedures via Whistleblowing shall ensure the protection of any Whistleblower. 7.1. Investigation, remediation, and consequences Allegations of modern slavery or human trafficking will be assessed promptly and objectively investigated to determine the appropriate action in accordance with ILRI’s established procedures. Confirmed violations shall result in disciplinary action, up to and including dismissal, contract termination, and referral to relevant authorities. 8. Roles and responsibilities 8.1. Institutional Leadership Team Provide oversight and resources to ensure effective prevention, detection and response to modern slavery and human trafficking across the institute and its global operations. 8.2. People and Culture • Integrate relevant measures into employment practices to ensure an ethical, safe and compliant workplace • Facilitate periodic training and awareness sessions to staff, contractors, and relevant partners to ensure understanding of modern-slavery risks, reporting obligations, and required due diligence standards. https://report.syntrio.com/ilri/ mailto:ilricomplaints@cgiar.org Page 9 of 10 8.3. Supply Chain • Embed due-diligence and supplier screening measures • Review and update the policy as required 8.4. Supervisors • Ensure compliance in day-to-day operations and escalate concerns 8.5. All staff, partners, and contractors • Act with integrity, remain vigilant to risks, and report concerns • Completion of mandatory training. 9. Monitoring and review This policy shall be reviewed periodically to ensure alignment with changes in legislation, donor requirements, CGIAR governance, or risk context. Audit & Assurance: ILRI’s implementation of this policy shall be subject to periodic internal audit, donor audit, and compliance assurance reviews. Supply-chain and partner-related controls, including due-diligence requirements, may be independently verified to ensure adherence to ILRI’s modern-slavery and human trafficking prevention standards and applicable CGIAR system expectations. All staff shall cooperate fully with audit processes and provide accurate, timely documentation upon request. Page 10 of 10 10. Appendix 10.1. Definitions • Modern slavery, for the purposes of this policy, shall be defined as the recruitment, movement, harboring or receiving of children, women or men using force, coercion, abuse of vulnerability, deception or other means for the purpose of exploitation. • Human trafficking is the trade of humans for the purpose of forced labor, sexual slavery, or commercial sexual exploitation for the trafficker or others. • Exploitation shall mean the action or fact of treating someone unfairly in order to benefit from their work. • Child shall be considered as any human being under eighteen years of age. • Forced labor means work or service exacted under threat or penalty and not offered voluntarily. • Bonded labor refers to labor undertaken to repay a debt or obligation that restricts the individual’s freedom.