Combatting Trafficking In Persons

As outlined in the Federal Acquisition Regulation (FAR 52.222-50) and Executive Order 13627 Strengthening Protections Against Trafficking in Persons in Federal Contracts, One Federal Solution is required to develop and maintain a compliance plan during the performance of contract(s) or subcontract(s) that is appropriate for the size and complexity of the contract or subcontract and the nature and scope of the activities performed, including the risk that the contract or subcontract will involve services or supplies susceptible to trafficking. One Federal Solution

strictly prohibits its employees and all subcontractors and agents from the following

Engaging in severe forms of trafficking in persons; procuring commercial sex acts; using forced labor;
Destroying, concealing, confiscating, or otherwise denying an employee access to the employee’s identity or immigration documents, such as passports or drivers’ licenses, regardless of issuing authority;
Using misleading or fraudulent practices during the recruitment of employees or offering of employment, such as failing to disclose, in a format and language accessible to the employee, basic information or making material misrepresentations during the recruitment of employees regarding the key terms and conditions of employment, including wages and fringe benefits, the location of work, the living conditions, housing and associated costs (if employer- or agent-provided or arranged), any significant costs to be charged to the employee, and, if applicable, the hazardous nature of the work;
Using recruiters that do not comply with local labor laws of the country in which the recruiting takes place;
Charging employees recruitment fees (as defined by the S. F ederal A cquisition Regu lation (FAR): Combating Trafficking in Persons);
Failing to pay return transportation costs upon the end of employment for employees who are not nationals of the country in which the work is taking place;
Providing or arranging housing that fails to meet the host country housing and safety standards; and,
If required by law or contract, failing to provide an employment contract, recruitment agreement, or other legally required work document in writing in a language the employee understands, containing a detailed description of the terms and conditions of employment, at least five days before an employee relocates to perform work.

EMPLOYEE AWARENESS PROGRAM

The Company has developed and implemented an awareness program to inform all employees about the FAR’s prohibitions against trafficking-related activities described in FAR 52.222-50(b), the activities prohibited, and the actions that will be taken against the employee for violations. Employees are trained on:

The Company Human Trafficking Policy and Supplier Code of Conduct;
Consequences for violating Company policy;
The violation reporting process, and
A summary of the U.S. Government’s policy prohibiting trafficking related activities as contained in the provisions of FAR 222-50(b), Combating Trafficking in Persons.

Employees are trained both prior to departing from their origin countries and again upon arriving in the country where the work will be performed. They are also provided with written materials that include all subjects covered in the training. Both the training and written materials are in each employee’s own language or a language the employee understands. A verbal explanation of the contents is given upon request to individuals unable to read the printed information.

EMPLOYEE REPORTING/GRIEVANCE PROCESS

All employees of the Company or its suppliers, subcontractors, and agents are encouraged to report any activity or condition that may violate the Company Human Trafficking Policy or the requirements of FAR 52.222-50. The Company has established procedures and policies to ensure employees can do so confidentially and without retaliation to the Company Human Resources Department Hotline or confidential email address workplacerights@onefederalsolution.com. All reported concerns will be promptly investigated by an impartial Grievance Company HR and Ethics staff. Where employees disagree with the results, they may appeal the decision to the Grievance Committee.

One Federal Solution has also established a process to interview and protect from retaliation all employees suspected of being victims of or witnesses to alleged violations of the Corporate Human Trafficking Policy and FAR 52.222-50. This will be done prior to the employee returning to his or her country of origin if the employee is located outside their country of origin at the time of the incident being reported. Additionally, the Company will not interfere with employees cooperating fully with government authorities.

Employees may also report their concerns directly to the Global Human Trafficking Hotline at 1-844-888-FREE or its email address at help@befree.org. The Company reporting process and the Global Human Trafficking hotline and email address have been made available to all employees in the Employee Awareness Program and via postings in all worksites.

RECRUITMENT AND WAGE PLAN

One Federal Solution’s Hiring Managers, Recruitment team, and contracted recruitment agencies that support recruitment activities must adhere to all internal policies (domestic and international) and host-country recruitment standards to combat trafficking in persons and trafficking related activities. One Federal Solution prohibits charging of recruitment fees, as defined in FAR 52.222-50, to employees and prospective employees and prohibits the use of any recruiting firms unless the firm’s employees have received training on combating trafficking related activities.

One Federal Solution ensures that employee wages meet host-country legal requirements or explains any variance. One Federal Solution maintains a comprehensive total remuneration program providing compensation and benefits that comply with country-specific laws and regulations and are competitive with external, country-specific labor markets and levels of employee performance.

HOUSING PLAN

One Federal Solution will provide and/or arrange housing that meets the host country housing and safety standards

VIOLATION MONITORING, REPORTING, AND REMEDIATION

The Company has established a performance monitoring, detection, and remediation program to identify and address any violations of the requirements of FAR 52.222-50(b) and the Company Human Trafficking Policy on an ongoing basis. In the event of the receipt of credible information alleging violation of FAR 52.222-50(b), the Company will immediately

Notify the Contracting Officer and the agency Inspector General of the specific nature of the activity, including specific remedial actions taken, and
Take appropriate corrective and preventive action, up to and including the dismissal of Company employees and termination of contracts with subcontractors, suppliers, and

All subcontractors of the One Federal Solution are required by contract to fully cooperate with Company staff, contracting agencies, and other Federal agencies to conduct audits and investigations on compliance with the provisions of FAR 52.222-50(b), Combating Trafficking in Persons. One Federal Solution subcontractors, and agents have also provided the Company with copies of their Compliance Plans prepared in accordance with Company requirements and FAR 52.222-50(h).

The Company requires its subcontractors and agents whose subcontracts are covered by 52.222-50(i)(A) and (B) to certify prior to subcontract award and annually thereafter that they have implemented compliance plans that comply with 52.222-50(h) and that, after having conducted due diligence, either (1) to the best of the subcontractor’s knowledge and belief, neither it nor any of its agents, subcontractors, or their agents, has engaged in any such activities; or (2) if abuses relating to any of the prohibited activities identified in 52.222–50(b) have been found, the subcontractor has taken the appropriate remedial and referral actions.

Additionally, all subcontractors have agreed to on-going monitoring and random auditing by the Company or its agents for compliance with FAR 52.222-50 and the Company Human Trafficking Policy. Any credible indication of noncompliance will be investigated, reported, and addressed accordingly.

Failure to comply with the requirements of the FAR 52.222-50 is grounds for the Company to take any and all appropriate actions, up to and including immediate termination of that supplier’s contract with the One Federal Solution. One Federal Solution will monitor its agents and subcontractors at any tier and at any dollar value from engaging in trafficking in persons and terminate any agents, subcontracts, or subcontractor employees that have engaged in such activities.