Combating Trafficking in Persons (CTIP) Plan

In accordance with FAR 52.222-50(h), AGE Solutions LLC (AGE) has developed this Anti-Trafficking Compliance Plan (the “Compliance Plan” or the “Plan”) to be implemented for each U.S. Government contract or subcontract that is for supplies, other than commercially available off-the-shelf items, acquired outside the U.S., or services to be performed outside the U.S., that exceeds $550,000 in value. The purpose of this Plan is to ensure that employees, agents, and subcontractors are aware of prohibited conduct under anti-trafficking regulations and laws, as well as actions that may result from violations. The Plan also includes terms for recruitment, wages, and housing, as well as procedures to prevent employees, agents and subcontractors at any tier from trafficking in persons. 

This Compliance Plan (or its implementation) may be sufficiently tailored with respect to the size and complexity of the particular contract under which the employees will work, and to the nature and scope of the activities to be performed for the Government, including the number of non-U.S. citizens expected to be employed and the risk that the contract or subcontract will involve services or supplies susceptible to trafficking in persons. 

• AGE will provide to employees and agents, at least five days prior to any relocation, an overseas assignment letter, written in a language understandable by the employee, that will include, but is not limited to, the following information: wages and fringe benefits; location of work; living conditions; housing and associated costs, if provided or arranged; any significant costs to be charged the employee; and hazardous nature of the work, if applicable.
   

• Employees have the right to ask for clarification of any employment terms they do not understand. AGE will require employees or agents to be presented with and expressly agree to the terms of their employment. 
   

• AGE will provide all employees and agents a copy of the Compliance Plan, prior to the commencement of their assignment. The policy can be found on AGE’s internal website under the Policies, Process, and Instructions SharePoint site. AGE’s HR Policies include the following information: 

• Recruitment: AGE permits only the use of recruitment companies with trained employees and requires recruiters to comply with local labor laws and to provide potential employees and agents with accurate information pertaining to their employment, includeing their duties, hours of work, location of work, wages, housing/living conditions, costs to be charged the employee, and any hazardous nature of the work, at least five days prior to any relocation. AGE prohibits charging employees recruitment fees.
   

• Wages: AGE requires wages to meet applicable host-country legal requirements or explain any variance. 
   

• Housing: If housing is provided by AGE, it must meet host-country housing and safety standards. 
   

• Identity Documents: AGE strictly prohibits destroying, concealing, confiscating or otherwise denying access to employee identity or immigration documents.
   

• Transportation Costs: AGE must provide return transportation at the end of employment for employees brought to a non-U.S. country for the purpose of working on a U.S. government contract. For trafficking victims or witnesses seeking redress in the country of employment, AGE must provide transportation costs in a manner that does not obstruct such redress or witness activity. Non-U.S. nationals brought to the U.S. may also qualify for return transportation costs. An employee may refuse return transportation costs if legally able to stay in the country. AGE may opt to either provide or pay for transportation, based on AGE’s established policies and procedures, as well as the modes and costs of transportation available. Employees who are terminated for cause or who desire to leave prior to completion of the contract are still entitled to these costs, if they would otherwise qualify for them. 
   

• Reporting: AGE has provided several easy and retaliation-free means of reporting suspected trafficking activity as detailed in Section 5 of this Plan below. Such reporting is a critical tool to assist AGE in monitoring and detecting any trafficking violations. AGE must immediately notify appropriate Government officials of any credible information regarding suspected trafficking activity. Such reporting by the Company will be coordinated through AGE’s Human Resource Department. 

• As part of the overseas assignment package, AGE employees will be required to confirm that they have read and understood the Compliance Plan and agree to abide by its terms by executing AGE’s Employee and Agent Certification — Combating Trafficking in Persons Acknowledgement. To the extent AGE has engaged an agent to assist the Company in securing or performing the work, such agent will also be subject to this Plan and must execute the Certification referenced above. ​

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Violations of AGE’s anti-trafficking policies or this Compliance Plan by any AGE employee (or agent) may result in disciplinary action up to, and including, removal from the contract, suspension or debarment of the employee or agent from further Government contracting, and suspension or termination of employment (or termination of the agreement with the agent). Violations may also result in serious consequences for the Company. These may include a negative entry into FAPIIS, non-exercise of an option period, contract termination, suspension of contract payments, and loss of the Company’s award fee under the contract. Additionally, employees or agents may face suspension or debarment from future Government contracts. 

AGE is committed to providing a safe and easy means of reporting suspected trafficking activity. All AGE employees and agents are required to report, anonymously if preferred, any suspected trafficking-related activity through any of the following means: 

• To AGE’s Human Resource Department 

AGE Solutions, LLC 

Attn: Human Resources Director 

6412 Beulah Street, Suite 108 Alexandria, VA 22310 

Email: [email protected] 

Phone: 1-571-622-1103 

• To the Global Human Trafficking Hotline 

Website: humantraffickinghotline.org 
Phone: 1-888-373-7888 
 

AGE has an obligation to protect all employees suspected of being victims of or witnesses to prohibited activities, prior to returning to the country from which the employee was recruited and shall not prevent or hinder the ability of these employees from cooperating fully with Government authorities. 

If AGE is made aware of any credible information from any source pertaining to a suspected trafficking violation, AGE will investigate such allegations, take appropriate remedial measures, and immediately notify the contracting officer and the appropriate agency Inspector General (IG) of that information, as well as what action it has taken with respect to the allegation. 

AGE will fully cooperate with any Federal agency conducting an audit or investigation of potential anti-trafficking violations, including providing timely responses to Government investigators and providing reasonable access to facilities and staff. 

• AGE’s subcontractors must comply, where applicable, with the anti-trafficking requirements detailed in FAR Subpart 22.17, FAR 52.222-50, FAR 52.222-56, DoD FAR Supplement (“DFARS”) and DFARS Procedures, Guidance, and Information (“PGI”) 222.17, DFARS 252.203-7004(c)-(e); DFARS 252.222-7007, and DFARS 252.222-7040(d)(8). 
   

• Failure to comply with the requirements of any anti-trafficking law or regulation will result in swift action by AGE, up to and including immediate termination of any subcontract with AGE, as well as potential suspension and debarment by the Government.
   

• Pursuant to FAR 52.222-50(h) and (i), if an AGE subcontractor is required to submit a certification of compliance, it must provide AGE with a copy of its anti-trafficking compliance plan and any implementing policies when requested, and, prior to subcontract award, certify that it has implemented a compliance plan to prevent any prohibited activities in FAR 52.222-50. It must also certify that it will monitor, detect, and terminate any agent, subcontract or subcontractor employee engaging in prohibited activities, and, after having conducted due diligence, either (a) to the best of the subcontractor’s knowledge and belief, neither it nor any of its agents, subcontractors, or their agents is engaged in any such activities; or (b) if abuses relating to any of the prohibited activities have been found, the subcontractor, or its lower-tier subcontractor, has taken the appropriate remedial and referral actions. 
   

• Subcontractors’ compliance plans must meet the minimum requirements in FAR 52.222- 50(h), and be sufficiently tailored with respect to the size and complexity of the contract under which employees will work, and to the nature and scope of the activities to be performed for the Government, including the number of non-U.S. citizens expected to be employed and the risk that the contract or subcontract will involve services or supplies susceptible to trafficking in persons. 
   

• AGE will monitor subcontractors’ conduct based on the risk of trafficking in persons related to the product or service being acquired. 
   

  • Where AGE has access and it is determined appropriate, AGE will inspect for signs of trafficking in persons at the workplace, and if housing is provided, inspect the housing conditions. 
     

  • Subcontractors must agree to monitor trafficking-related activities, and to inspection and audit by AGE. Any suspected activity will be investigated and reported pursuant to this plan and legal requirements. 
     

  • Where AGE subcontractors are remotely located, and for lower tier subcontractors, AGE will review the plans and certifications of its subcontractors to ensure they include adequate monitoring procedures. These plans must be made available upon request. 
     

• AGE subcontractors have an obligation to protect all employees suspected of being victims of or witnesses to prohibited activities, prior to returning to the country from which the employee was recruited and shall not prevent or hinder the ability of these employees from cooperating fully with Government authorities.
   

• If an AGE subcontractor is made aware of any credible information from any source pertaining to a suspected trafficking violation, that subcontractor must investigate such allegations, take appropriate remedial measures, and immediately notify AGE, the contracting officer and the agency Inspector General (IG) of that information, as well as what action it has taken with respect to the allegation.
   

• AGE subcontractors must fully cooperate with any Federal agency conducting an audit or investigation of potential anti-trafficking violations, including providing timely responses to Government investigators and providing reasonable access to facilities and staff. 

• This Compliance Plan shall be posted at the workplace, unless the work under the contract is performed in the field or not otherwise at a fixed location, or is otherwise impractical to physically post, in which case a written copy of such Plan shall be provided to each affected employee and agent. 
   

• AGE shall also post this Compliance Plan on its internal website as well as its external website, www.age.solutions. 
   

• AGE will post relevant contents of the Compliance Plan no later than the initiation of performance under the contracts subject to be anti-trafficking regulations. 
   

• AGE and its subcontractors will meet any additional posting requirements pursuant to applicable FAR and DFARS anti-trafficking provisions. 

• Annual training will be provided to all AGE employees to ensure familiarity and awareness of the requirements of this Plan and the roles they play in enforcement.