Revision 1.0

​

Policy

​

IDEAS-TEK is opposed to human trafficking and forced labor in any form. We are committed to working to mitigate the risk of human trafficking and forced labor in all aspects of our business. The US Government has a zero-tolerance policy regarding any Government 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.

​

Pursuant to the FAR 52.222-50(h), 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 illegal 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 on a U.S. Government contract, subcontract or portion(s) of contracts or subcontracts performed outside the United States;

• 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 FARs, the DFARS, the Executive Order and/or IDEAS-TEK’s 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. For subcontractors and subcontractor employees, failure to comply with the requirements of the FARs, the DFARS and the Executive Order is grounds for IDEAS-TEK to take any and all appropriate actions, up to and including immediate termination of that subcontractor’s contract with IDEAS-TEK.

​

Procedures

​

On an annual basis, IDEAS-TEK requires all employees to certify via receipt of IDEAS-TEK’s Employee Handbook that they have read and understand the IDEAS-TEK’s policy on Combating Human Trafficking and agree to comply with the policies, procedures and principles of the policy and report any violations of which they are aware.

 

Applicable FAR and DFARS clauses are “flowed down” to our subcontractors. Subcontractors are also provided links to the IDEAS-TEK policy on Combating Human Trafficking and asked to certify that they have read and understood this policy. A copy of subcontractor certifications is maintained on file with IDEAS-TEK. Failure to comply with the requirements of the FARs is grounds for IDEAS-TEK to take any and all appropriate actions, up to and including immediate termination of that subcontractor’s or agent’s contract with IDEAS-TEK.

 

To the extent that IDEAS-TEK 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 or explain any variance.

​

Reporting Process

​

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 whistleblowing on trafficking in persons violations, any activity that violates the FARs, the DFARS, the Executive Order or the IDEAS-TEK Policy to IDEAS-TEK Management or to the Global Human Trafficking Hotline at 1-844-888-FREE or via its email address at help@befree.org or the Department of Defense at www.dodig.mil/hotline/ or toll free at 800-424-9098.

​

Notification

​

IDEAS-TEK shall immediately inform the Contracting Officer and the agency Inspector General upon receipt of credible information alleging a violation of FAR 52.222-50; and any actions taken against an IDEAS-TEK employee, subcontractor, subcontractor employee, or their agent pursuant to FAR 52.222-50.

​

Postings and Certifications

​

IDEAS-TEK shall post its compliance plan in a noticeable spot at the work place. IDEAS-TEK shall provide its compliance plan to the Contracting Officer upon request and provide annual certifications to the contracting officers as required by the FARs.

Prior to award of a subcontract, and annually during performance of the contract, IDEAS-TEK 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, a certification of compliance as required by the FARs.

 

In addition, for individual contracts that are for supplies, other than commercially available off-the-shelf items, acquired outside the United States or services to be performed outside the United States, and has an estimated value exceeding $500,000, before entering into a subcontract, IDEAS-TEK will obtain from each subcontractor whose subcontract meets the above requirements, a certification of compliance as required in FAR 1703(c)(3)(i) and (ii).