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Network Travels Limited

Human Trafficking & Modern Slavery Policy

1. POLICY STATEMENT

Network Travels Ltd is committed to preventing and combating human trafficking and modern slavery in all aspects of its business operations.

We adopt a zero-tolerance approach to any form of human trafficking, exploitation, forced labour, or abuse. We are aligned with Nigerian laws, including the Trafficking in Persons (Prohibition), Enforcement and Administration Act 2015, and support the national efforts led by National Agency for the Prohibition of Trafficking in Persons.

2. DEFINITION OF HUMAN TRAFFICKING

In line with NAPTIP guidance, human trafficking is:

The recruitment, transportation, transfer, harbouring or receipt of persons through force, coercion, deception, or abuse of power for the purpose of exploitation.

This includes:

  • Forced labour or domestic servitude

  • Sexual exploitation

  • Child trafficking

  • Debt bondage

  • Removal of organs

Human trafficking is recognised as a form of modern-day slavery and a serious human rights violation.

3. OUR COMMITMENT

Network Travels will:

  • Operate ethically and with integrity in all business dealings

  • Refuse to facilitate any travel linked to exploitation or trafficking

  • Cooperate fully with law enforcement and relevant authorities

  • Promote awareness among staff, partners, and clients

We support the “Prevention, Protection, Prosecution, and Partnership” framework used by National Agency for the Prohibition of Trafficking in Persons to combat trafficking.

4. SCOPE OF THE POLICY

This policy applies to:

  • All employees of Network Travels

  • Contractors, agents, and representatives

  • Suppliers and business partners


5. RESPONSIBILITIES
Management

  • Ensure implementation of this policy

  • Provide staff training and awareness

  • Establish reporting procedures


Employees

  • Remain vigilant to signs of trafficking

  • Report any suspicious activity immediately

  • Follow company procedures at all times


6. RISK AREAS IN TRAVEL INDUSTRY

As a travel agency, we recognise that our services may be misused in:

  • International travel arrangements for vulnerable persons

  • One-way or irregular migration bookings

  • Group bookings controlled by a single individual

  • Travel linked to deceptive employment offers

  • NAPTIP highlights that trafficking often involves movement across borders and organised networks, making the travel sector a key point of intervention.

7. RED FLAGS (WARNING SIGNS)

Staff should be alert to:

  • A third party holding multiple passports or controlling travellers

  • Passengers who appear fearful, distressed, or unable to speak freely

  • Inconsistent or scripted travel information

  • Young or vulnerable individuals travelling without clear purpose

  • Requests to avoid normal identification or documentation processes


8. REPORTING PROCEDURE

If any suspicion arises:

NAPTIP provides confidential reporting channels and coordinates investigations and victim protection.

9. PROTECTION OF VICTIMS

Network Travels recognises that victims of trafficking:

  • Must not be treated as criminals

  • Should be treated with dignity, empathy, and confidentiality

  • This aligns with NAPTIP guidance that victims require protection, rehabilitation, and reintegration support.

10. TRAINING AND AWARENESS

We will:

  • Provide regular staff training on trafficking awareness

  • Share updates and guidance from National Agency for the Prohibition of Trafficking in Persons

  • Promote ethical practices across our operations


11. COMPLIANCE AND REVIEW
This policy will be reviewed annually
Non-compliance may result in disciplinary action
We will continuously improve procedures in line with Nigerian law and international best practice


12. CONTACT AND REPORTING SUPPORT

For reporting or guidance, contact:

Internal: Network Travels Management
External: National Agency for the Prohibition of Trafficking in Persons
Toll-free: 0800CALLNAPTIP
Short code: 627
 

CONCLUSION

Network Travels Ltd is committed to playing its part in eradicating human trafficking. As a travel agency, we recognise our unique position to identify and prevent exploitation and will act responsibly at all times.

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