of Experience
Combating Trafficking in Persons (CTIP) Compliance Plan
1.0 Executive Summary
Masafat introduces its Combating Trafficking in Persons (CTIP) Compliance Plan which lays the groundwork and strictly opposes human trafficking and forced labor in any form. Our team is committed to best practices and requirements for CTIP. The company has a zero-tolerance policy regarding any employees and contractor personnel and their agents engaging in any severe form of trafficking in persons, defined to mean the recruitment, harboring, transportation, provision or obtaining of a person for labor or services, through the use of force, fraud, or coercion for the purpose of subjection to involuntary servitude, peonage, debt bondage or slavery and sex trafficking.
To the extent these provisions differ in their requirements, stricter requirements must be followed.
The following sets forth Masafat’s Compliance Plan for Combating Trafficking in Persons.
2.0 Awareness Program
Pursuant to the FARs, contractors, contractor employees and their agents are prohibited from:
Engaging in severe forms (i.e., using force, fraud or coercion) of trafficking in persons during the period of performance of a contract.
Procuring commercial sex acts during the period of performance of a contract.
Using forced labor in the performance of a contract.
Destroying, concealing, confiscating, or otherwise denying access by an employee to the employee’s identity or immigration documents, such as passports or drivers’ licenses, regardless of issuing authority.
Using misleading or fraudulent recruiting practices during the recruitment of employees or offering of employment, such as failing to disclose, in a format and language accessible to the worker, 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 the local labor laws of the country in which the recruiting takes place.
Charging employees recruitment fees.
Failing to provide return transportation or pay for the cost of return transportation upon the end of employment, for an employee who was not a national of the country in which the work is taking place and who was brought into that country for the purposes of working, subcontract or portion(s) of contracts or subcontracts performed.
Providing or arranging housing that fails to meet the host country housing and safety standards.
If required by law or contract, failing to provide an employment contract, recruitment agreement or other required work document in writing in a language the employee understands. If the employee must relocate to perform the work, the work document shall be provided to the employee at least five days prior to the employee relocating.
Any violation of the FARs, the Executive Order and/or the Masafat CTIP Policy could result in disciplinary action which may include but is not limited to, an employee’s removal from a contract, reduction in benefits, or termination of employment.
3.0 Employees
Masafat requires all employees to complete compliance training (online or in-person) and to certify that they have read, are aware of, understand, and agree to comply with the policies, procedures and principles of the Masafat CTIP Policy and report any violations of which they are aware. Masafat conducts compliance training upon initial hiring and as needed throughout the year. Such compliance training is targeted and customized for various business units and appropriate to the nature and scope of the activities to be performed.
4.0 Subcontractors / Suppliers
Applicable FAR and DFARS clauses are flowed down to our subcontractors. Subcontractors shall be provided the Masafat CTIP Policy and asked to certify that they have read and understand the policy.
5.0 Questions
Questions regarding Masafat’s policy and actions to combat trafficking in persons may be directed to Masafat Human Resources or Supervisory personnel.
6.0 Reporting Process
Employees having knowledge of credible information concerning actual or potential violations of this policy must report it immediately. Failure to report actual or potential illegal behavior or actual or potential violations of this policy may subject employees to disciplinary action, up to and including termination of employment.
Employees may report in good faith and have a responsibility to report without fear of retaliation, any activity that violates the FARs, the DFARS, the Executive Order or the Masafat CTIP Policy to their direct supervisor and/or Senior Management.
Employees should consult their direct supervisor and/or Senior Management if they are uncertain whether a specific action would be in violation of the FARs, the DFARS, the Executive Order or the Masafat Employee Handbook CTIP Policy.
7.0 Recruitment and Wage Plan
To the extent that Masafat uses recruitment companies, only recruitment companies with trained employees may be used. No recruitment fees may be charged to the employee and all wages must meet applicable host-country legal requirements, unless variances are documented, explained and approved by Masafat President and Vice President.
8.0 Procedures to Prevent Agents and Subcontractors from Engaging in Trafficking in Persons and to Monitor, Detect and Terminate
8.1 Agents and Subcontractors
All agents and subcontractors, as a part of the Masafat set-up process to allow payments, are screened against Government and international denied and debarred party watchlists. Not less than annually, Masafat will require each of its subcontractors to certify:
1. Its policies and practices prohibit engaging in the trafficking of persons, the use of forced labor, or the procuring of commercial sex acts in the country or countries in which it conducts business;
2. After having conducted due diligence, either
o to the best of its knowledge and belief, neither it nor any of its agents, subcontractors, or their agents is engaged in any such activities; or
3. Has reviewed and understands the Masafat CTIP Policy as referenced herein.
As required by the FARs, Masafat shall flow down all applicable clauses to its subcontractors and agents.
Failure to comply with the requirements of the FARs is grounds for Masafat to take any and all appropriate actions, up to and including immediate termination of that subcontractor’s or agent’s contract with Masafat.
8.2 Suppliers
Masafat has made written information on combating human trafficking available to its suppliers. In addition, Masafat training for internal personnel includes information on recognizing the signs of human trafficking and the appropriate action to take if human trafficking is suspected and monitors suppliers whenever possible while on supplier premises.
9.0 Notification
Masafat shall immediately inform the Contracting Officer and the agency Inspector General upon receipt of credible information alleging a violation; and any actions taken against a Masafat employee, subcontractor, subcontractor employee, or their agent pursuant. As described above, employees may, in good faith, report, (without fear of retaliation and with employee protection, any activity that violates the FARs, the DFARS, the Executive Order
or Masafat’s CTIP Policy to their management. Anyone else, including subcontractors, agents, and contingent workers, may also use the hotlines or websites to report any issues relating to human trafficking.
10.0 Certifications
Prior to contract award and annually after receiving an award, Masafat will provide certifications to the contracting officer as required by the FARs. Prior to award of a subcontract and annually during performance of the contract, Masafat shall obtain from each subcontractor a certification as required by the FARs
www.massafat.com