Human Trafficking Policy and Supplier Code of Conduct

This document describes the program requirements and processes established and implemented by Kajeet, Inc. d/b/a Arterra Mobility (hereafter referred to as ‘the Company’) to comply with FAR 52.222-50, Combating Trafficking in Persons. The scope of the plan includes the operations and activities of the Company as well as those subcontractors and agents in its supply chain performing on this contract. This Plan is maintained by Company at its corporate headquarters at 7901 Jones Branch Drive Suite 350 McLean, VA 22102.

Awareness Program

Pursuant to the FAR, 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 local labor laws of the country in which the recruitment 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 to that country for the purposes of working on a U.S. Government contract, subcontract or portion(s) of contracts or subcontracts performed outside the United States; or
  • Failing to provide return transportation or pay for the costs of return transportation upon the end of employment, for an employee who is not a United States national and who was brought into the United States for the purpose of working on a U.S. Government contract or subcontract if the payment of such costs is required under existing temporary worker programs or pursuant to a written agreement with the employee for portions of contracts and subcontracts performed inside the United States;
  • 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 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 FAR or this policy could result in disciplinary actions which may include, but are not limited to, an employee’s removal from the contract or termination of employment.  For subcontractors and subcontractor employees, failure to comply with the requirements of the FAR is grounds for the Company to take any and all appropriate actions, up to and including immediate termination of that subcontractor’s contract with the Company.

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

Subcontractors and Vendors

The FAR clause is “flowed down” to our subcontractors, as applicable.  Subcontractors are also asked to certify that they have read and understood the Company’s policy and asked to certify that they have read and understood the document.  Copies of the subcontractor certifications are maintained on file with the Company.

Inquiries/Questions

Questions regarding the Company’s policy and actions to combat trafficking in persons may be directed to compliance@kajeet.com.

Reporting and Grievance Process

Employees should consult the Company’s Compliance Officer (Daniel Neal) if they are uncertain whether a specific action would be in violation of the FAR or the Policy.  Employees may report, in good faith, and have a responsibility to, without fear of retaliation and subject to protection under 10 U.S.C. 2409, as implemented in DFARS subpart 203.9, for reprisal for whistle-blowing on trafficking in persons violations, any activity that violates the FAR or the Company’s Policy to the Company’s management or report via the Company’s email at compliance@kajeet.com or as otherwise specified in the Company’s Whistleblower Policy.

In addition, employees may contact the Global Human Trafficking Hotline at 1-844-888-FREE or via its email address at help@befree.org.  Anyone else, including subcontractors, agents, and consultants may use the hotlines or websites.

Notification

The Company shall promptly inform the Contracting Officer upon receipt of credible information alleging a violation of FAR 52.222-50; and any actions taken against a Company employee, subcontractor, subcontractor employee, or their agent pursuant to FAR 52.222-50.

Posting

The Company shall post its compliance program no later than the initiation of contract performance, at the workplace and on its website at www.arterra.com.

Certifications

The Company will provide certifications to the contracting officer annually as required by the FAR.  Prior to the award of a subcontract, and annually during performance of the contract, the Company shall obtain from each subcontractor with subcontracts for supplies, other than COTS items, to be acquired outside the United States, or services to be performed outside the United States, as certification is required by the FAR.

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