Combating Trafficking in Persons (“CTIP”):
SOSi Compliance Plan Summary

 

INTRODUCTION

SOSi is committed to ensuring that its employees, independent contractors, subcontractors, and agents do not engage in any form of trafficking in persons and comply with all applicable legal requirements prohibiting human trafficking and trafficking-related activities, particularly when performing work outside the United States.  The following information provides a summary of the relevant portions of SOSi’s CTIP Compliance Plan (“Plan Summary”).  To submit questions or request further information about SOSi’s CTIP Compliance Plan, please contact the SOSi Legal Department at legal@sosi.com.

PLAN SUMMARY

  1. Employee Awareness Program.  SOSi provides a comprehensive awareness program to inform employees about its commitment to prohibiting trafficking-related activities as described below.
    1. General (Non-Program Specific).  All employees are required to read and acknowledge the SOSi Code of Business Ethics and Conduct (“SOSi Code of Conduct”) during onboarding and annual thereafter.  The SOSi Code of Conduct contains a specific section describing SOSi’s policy against any form of human trafficking.  Additionally, SOSi distributes an annual CTIP program newsletter and provides its employees with mandatory annual ethics and compliance training and periodic targeted learning sessions on its CTIP program.  SOSi furthermore has placed posters in common areas of its workspaces concerning employee rights to be free of any trafficking activities or conduct.
    2. Program Work Outside of the United States.  In addition to the foregoing general practices, SOSi places appropriate CTIP “Know Your Rights” posters at its program worksites outside of the United States and conducts program-specific anti-human trafficking briefings (through written materials, orientation meetings, and periodic team discussions) during program initiation and annually thereafter.
  2. Reporting Concerns.  SOSi provides all of its employees a process to report, without fear of retaliation, activity inconsistent with its policy prohibiting trafficking in persons.  SOSi informs its personnel (as described herein) of: (i) methods to report issues to the SOSi Ethics and Compliance Department via sosi.ethicspoint.com or compliance@sosi.com; (ii) the National Human Trafficking Hotline at 1-888-373-7888, Global Human Trafficking Hotline at 1-844-888-FREE, and human trafficking hotline email address at help@befree.org; and (iii) the applicable agency Office of Inspector General hotlines.  These reporting methods are documented and made available to SOSi employees through SOSi’s Code of Conduct, CTIP Policy, this Compliance Plan Summary, SOSiConnect intranet reporting link, workplace and worksite posters, and annual and periodic general and program-specific training materials and newsletters.
  3. Recruitment.  SOSi’s CTIP Policy specifically prohibits the charging of any recruitment fees to employees or potential employees.  Additionally, the SOSi human resources and recruiting departments are responsible for ensuring that all employee wages meet applicable host country legal requirements.  SOSi occasionally engages recruiting companies and such companies are required to comply with all applicable SOSi CTIP compliance requirements and use only trained personnel in support of SOSi.
  4. Housing Plan.  SOSi requires that all housing provided by SOSi or its subcontractors meets host country housing and safety standards.  Whenever possible, SOSi includes appropriate terms and conditions regarding compliance with zoning, housing, and safety requirements in its housing agreements and leases.  Furthermore, SOSi conducts periodic audits and visits to SOSi or subcontractor provided housing locations to ensure compliance with SOSi’s CTIP Policy and host country housing and safety standards.
  5. Agent and Subcontractor Compliance.  SOSi has adopted several processes and procedures to prevent all its agents and subcontractors from engaging in trafficking in persons and to monitor, detect, and terminate any agents, subcontracts, or subcontractor employees that have engaged in such activities.
    1. General (Non-Program Specific).  SOSi requires all of its subcontractors, vendors, and suppliers to agree to SOSi’s CTIP requirements prior to any engagement through: (i) adherence to SOSi’s Supplier Code of Business Ethics and Conduct (“Supplier Code of Conduct”), which contains a specific section describing SOSi’s policy against any form of human trafficking; and (ii) specific CTIP provisions in supplier agreements, such as the Federal Acquisition Regulation clause 52.222-50 (“Combating Trafficking in Persons”) and a customized SOSi developed clause for “Prohibition on Trafficking in Persons.”  This customized clause explicitly states that SOSi may terminate the applicable agreement if the subcontractor, vendor, supplier, or any of their personnel engage in any prohibited trafficking activity.
    2. Program Work Outside of the United States.  In addition to the foregoing general practices, SOSi: (i) requires its subcontractors performing work outside of the United States for a specific program to certify to having and maintaining their own CTIP compliance program and plan; (ii) informs subcontractor personnel of SOSi’s CTIP compliance requirements and reporting methods; (iii) reviews subcontractor CTIP compliance program materials for adequacy and sufficiency (including ensuring that CTIP training materials are adequately translated into the predominant languages of third country nationals supporting work overseas); and (iv) audits and monitors subcontractor CTIP compliance through periodic visits to and inspections at subcontractor work and housing locations (such as validating that “Know Your Rights” posters are appropriately displayed and local housing code requirements are being followed).
  6. Posting.  SOSi’s CTIP Policy and this Compliance Plan Summary are available to all employees through SOSi’s intranet, SOSiConnect.  SOSi also has posted this Compliance Plan Summary on its website at www.sosi.com.
  7. Full Plan Availability.  SOSi shall provide the compliance plan to the Contracting Officer upon request.