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Home/Human Trafficking Policy
PolicyLast updated August 31, 2025

Human Trafficking and Modern Slavery Policy

Any tranlation of this policy is made through an automated process which may not result in accurate or precise tranlations. Any discrepancies or differences created in the tranlation from the original English version are not binding and have no legal effect for compliance or enforcement purposes.

1. PURPOSE

Human trafficking and modern slavery are epidemics growing in awareness on the world stage. Due to the severity and rapid growth of these threats, it is the responsibility of you as Novacoast personnel to maintain awareness of the signs of human trafficking and modern slavery and to speak up when your suspect such events to be occurring.

Since both human trafficking and modern slavery are often crimes that are hidden in plain sight, it is important to be aware of the warning signs. Some indications that a person may be a victim of human trafficking or modern slavery include (especially in the case of women and children):

  • Appearing malnourished
  • Showing signs of physical injuries and abuse
  • Avoiding eye contact, social interaction, and authority figures/law enforcement
  • Seeming to adhere to scripted or rehearsed responses in social interaction
  • Lacking official identification documents
  • Appearing destitute/lacking personal possessions
  • Working excessively long hours
  • Living at place of employment
  • Checking into hotels/motels with older males, and referring to those males as boyfriend or “daddy,” which is often street slang for pimp
  • Poor physical or dental health
  • Tattoos/branding on the neck and/or lower back
  • Untreated sexually transmitted diseases
  • Small children serving in a family restaurant
  • Security measures that appear to keep people inside an establishment (e.g., barbed wire inside of a fence, bars covering the insides of windows)
  • Not allowing people to go into public alone or speak for themselves

If you suspect any aspect of human trafficking or modern slavery to be occurring, please contact the following resources as soon as possible:

Corporate Counsel, Margaret Savenelli
esavenelli@novacoast.com

or

1-(800) 373-7888
National Human Trafficking Hotline

or

08000-121-700
Modern Slavery Helpline