Combating Trafficking in Persons Plan

Overview

The United States Government has adopted a policy prohibiting trafficking in persons including the trafficking‐ related activities. The Federal Acquisition Regulations (FAR) Clause 52.222‐50 outlines what Prime Contractors and subcontractors shall and shall not do regarding trafficking in persons. The compliance plan outlines how NI and its applicable subcontractors will comply with the requirements of this clause.

Applicability

This Plan sets out NI’s baseline standards for anti‐trafficking compliance and applies presumptively to all U.S. Government contracts, subcontracts, cooperative agreements, awards and subawards. However, it may need to be adapted or modified for projects that are larger, more complex, or involve greater risk of trafficking activity. For all contracts and awards with an estimated value of $550,000 or more, or involve activities outside the U.S., Project staff must examine each one individually to assess the risk of trafficking activity, based on factors such as the number of non-U.S. citizens to be employed and whether the contract or award will involve services or supplies susceptible to trafficking in persons. Project staff must adapt or modify the Plan as necessary to ensure that it is appropriate to the size and complexity of the contract or award and the nature and scope of the activities to be performed.

Employee Awareness Program

NI has adopted a policy on Combating Trafficking in Persons (“Policy”) that reflects the Anti‐ Trafficking Provisions’ provisions prohibiting trafficking‐related activities, describes the actions NI may take against employees and agents who violate the Policy, and sets out the procedure for reporting and investigating Policy violations. The Policy is also summarized in NI’s Code of Ethics and Conduct (the “Code”). Navigator International, LLC will not tolerate retaliation against an employee for reporting a concern in good faith or for cooperating with a compliance investigation, even when no evidence is found to substantiate the report.

Any violation of this policy may be grounds for disciplinary action, up to and including termination. Navigator International, LLC and its subsidiaries have the exclusive right to interpret this policy regarding their respective employees.

NI posts both the Policy and the Code on its Human Resource System, where they can be accessed by all NI personnel at any time.

All NI personnel will be notified of the Policy via a company‐wide email containing a link to the Policy on the Human Resource System with instructions to access and review the Policy. Thereafter, NI will send annual email reminders to all personnel directing them to review the Policy and summarizing any Policy updates.

All new personnel are required to read and acknowledge the Policy and the Code at the time of hire and must also complete an on‐line training program on the Code, including its anti‐trafficking provisions.

NI also periodically conducts specialized training on the Anti‐Trafficking Provisions, the Policy and the Compliance Plan on an as‐needed basis.

Recruitment and Wage Plan

NI prohibits the use of any misleading or fraudulent recruitment practices during the recruitment of employees or offering of employment to employees. NI employees and subcontractors must fully and accurately disclose, in a format and language accessible to the employee, all key terms and conditions of employment, including wages and benefits, work location, living conditions, housing and associated costs (where provided or arranged by NI), significant costs to be charged to the employee, and, if applicable, the hazardous nature of the work.

NI prohibits the use of recruiters that do not have trained employees, or that do not comply with all labor laws of the country where the recruitment takes place.

NI prohibits charging recruitment fees to any employee.

NI will pay to all employees wages that meet applicable host‐country legal requirements, or will explain any variance.

Where required by law or contract, NI will provide to every employee an employment contract, recruitment agreement or other required work document, written in a language the employee understands, containing all required information about the terms of conditions of employment, which may include, by way of example, the work description, wages, work location, living accommodations and associated costs, time off, transportation arrangements, grievance process, the content of applicable laws and regulations prohibiting trafficking in persons, and the prohibition on recruitment fees. If the employee must relocate to perform the work, NI will provide the required work document at least five (5) days prior to relocation.

NI prohibits destroying, concealing, confiscating or otherwise denying any employee access to his or her identity or immigration documents.

NI will provide or pay the cost of return transportation at the end of employment for any employee who is not a US national and was brought into the US for purposes of working on a covered US Government contract or award, if payment of such costs is required under existing temporary work programs or pursuant to a written agreement with the Worker for portions of contracts and awards performed outside the US.

Housing Plan

In situations where NI provides housing to employees, the housing will meet host country housing and safety standards.

Supplier Compliance

All NI contractors, consultants, vendors, suppliers, subcontractors and subrecipients (“Suppliers”) must agree to comply with the Policy and all applicable Anti‐Trafficking Provisions. NI will include language to that effect in all Supplier contracts, subcontracts and sub agreements (“Supplier Contracts”), including inserting FAR 52.222‐50, FAR 52.222‐56 and USAID Standard Provisions where applicable.

All NI Suppliers must have a compliance plan to prevent prohibited trafficking‐related activities and to monitor, detect and terminate any of its contractors, consultants, suppliers, subcontractors or subrecipients engaging in prohibited trafficking‐relating activities, and provide a copy of its plan to NI. The Supplier’s compliance plan must meet the minimum requirements in the Anti‐Trafficking Provisions and be appropriate to the size and complexity of the contract, subcontractor sub agreement with NI and the nature of the activities to be performed under it. If the supplier does not have a compliance plan, the subcontractor must agree to NI’s compliance plan and adhere to all guidance, compliance, and ongoing education regarding combatting trafficking in persons.

Prior to the award of any Supplier Contract, and on an annual basis thereafter, all NI Suppliers must submit a certification to NI:

That the Supplier has implemented a compliance plan and has complied with its plan such a compliance plan; and
That after conducting due diligence, to the best of the Supplier’s knowledge and belief, neither it nor any of its employees, or its contractors, consultants, suppliers, subcontractors, subrecipients or their employees, have engaged in any prohibited trafficking-related activities, or if any abuses relating to prohibited trafficking-related activities have been found, Supplier has taken appropriate remedial and referral actions.

For Suppliers and Supplier Contracts that may be more susceptible to trafficking-related activities, NI may, in situations where it has direct access, inspect the Supplier’s workplace or any housing provided by the Supplier for signs of trafficking-related activities. In lower-risk situations, and in situations where the Supplier is distant, NI will review the plans and certifications of its Suppliers to ensure they include adequate monitoring procedures and reporting mechanisms.

If any Supplier fails to comply with the Policy or applicable Anti-Trafficking Provisions, NI will take appropriate action to remediate the violation and prevent future violations, including, but not limited to:

Requiring the Supplier to remove an employee or agent from a project
Requiring the Supplier to terminate its relationship with any Supplier contractor, consultant, supplier, subcontractor or subrecipient
Suspending payments to Supplier until violation is remedied
Immediately terminating the Supplier Contract

Reporting Requirements and Procedure

All NI personnel, Suppliers and Supplier Personnel are required to report any suspected trafficking‐ related activity or violation of this policy to NI. Reports may be made to NI’s Human Resource Department or anonymously through the U.S. Government Global Human Trafficking Hotline at 1‐844‐888‐FREE or 1‐888‐373‐7888 or via the internet at the following email address: help@befree.org. In addition, reports may be made to any NI supervisor, senior Country Office management, or HQ HR representative. Any NI supervisor, member of Senior Country Office management, or HQ HR representative who receives such a report is required to immediately forward the report to NI’s Office of Compliance and Internal Audit or Office of General Counsel.

NI Human Resources Department and Chief of Staff will investigate all reports of prohibited trafficking‐related activity or violations of this policy and take appropriate action. The Office of Compliance and Internal Audit will make all required notifications to government agencies, as more fully set out in the Model Compliance Plan. NI strictly prohibits retaliation against any NI employee who reports prohibited trafficking‐ related activity or other violations of this policy, or who cooperates with any internal or government investigations of such reports. Employees may do so without fear of reprisal. NI personnel who engage in any form of retaliation against those who report prohibited trafficking‐related activities or other violations of this policy are subject to disciplinary action, up to and including termination of employment with NI.

Investigations

If NI receives credible information from an employee report or any other source alleging prohibited trafficking‐ related activity, the NI Department of Human Resources will conduct an investigation and report its findings and determine what, if any, remedial action is appropriate. NI Department of Human Resources will also monitor NI management’s implementation of such remedial action.

NI’s Human Resource Department will be responsible for immediately notifying the contracting officer and the appropriate agency Inspector General of the information received and any resulting remedial action taken.

NI will cooperate fully with any US Government agencies responsible for any investigations, audits or corrective actions relating to trafficking in persons, including, but not limited to, providing timely and complete responses to document requests, and providing reasonable access to NI facilities and staff.

NI will protect all employees suspected of being victims of or witnesses to prohibited activities, prior to returning to the country from which the employee was recruited and will not prevent or hinder these employees from cooperating fully with US government authorities.

Posting

NI will post this Plan on the company Human Resource System. The compliance plan will be posted at all workplaces, except where the work is being performed in the field or not otherwise at a fixed location. It may also be found on the company website: https://nav‐int.com