COMBATTING TRAFFICKING IN PERSONS DUE DILIGENCE QUESTIONNAIRE

INTRODUCTION As a U.S. Government Contractor, IAP Worldwide Services, Inc. and its subsidiaries (“IAP”), its subcontractors, and their subcontractors are subject to U.S. Government anti-human trafficking rules. In this procurement, the following rules apply to IAP, your company, your employees, and your subcontractors, both while at work and outside of work. FAR 52.222-50 - Combating Trafficking in Persons FAR 52.222-56 - Certification Regarding Trafficking in Persons Compliance Plan In certain cases, the following additional clauses may apply: DFARS 252.222-7007 - Representation Regarding Combating Trafficking in Persons DFARS 22.225-7995 (Deviation 2015-00009) (Jan 2015) - Contractor Personnel Performing in the United States Central Command Area of Responsibility DFARS 5152.222-5900 (Mar 2014) - Prohibition Against Human Trafficking, Inhumane Living Conditions and Withholding of Employee Passports

Included in these rules is a responsibility of your company, your employees, and your subcontractors to report trafficking in persons violations. You must communicate this responsibility to your employees and your subcontractors. All employees and subcontractors who report to you are protected under U.S. law from reprisal for whistleblowing on trafficking in persons violations. You should also communicate this protection to your employees and subcontractors. QUESTIONNAIRE 1. Use of Subcontractors 1a. Will you use subcontractors to perform the work under this contract? Yes No

1b. If yes, provide full name and contact information for any subcontractors. Name: Email: Phone Address: 2. Employee Documentation 2a. Do you have a policy that prohibits destroying, concealing, confiscating, or otherwise denying Yes No access by an employee to the employee’s identity or immigration documents, such as passports or drivers’ licenses, regardless of the issuing authority?

2b. Please confirm that your company shall only hold employee passports and other identification Yes No documents for the shortest period of time reasonable for administrative processing purposes.

3. Employment Agreements 3a. Do you and your subcontractors provide employees with written employment agreements, Yes No recruitment agreements, or other required work documents in writing?

Form # 1950-002 Page 1 of 5 25 Sep 15 This material contains proprietary information of IAP Worldwide Services, Inc. (IAP). Disclosure to others, use, or copying without the express written authorization of IAP is strictly prohibited. Any authorized copying of this material, in whole or in part, must include this legend. COMBATTING TRAFFICKING IN PERSONS DUE DILIGENCE QUESTIONNAIRE

3b. Is a copy of the employment agreement, signed by the subcontractor and employee, provided Yes No to the employee?

3c. Will the job performance be considered hazardous? Yes No

3d. Are the agreements in a language that the employee understands? Yes No

Note: All employees must be provided with a signed copy of their employment contract in English and the employee’s native language or a language that the employee understands, that define the terms of their employment and compensation. 3e. If the employee must relocate to perform the work, is the work document provided to the Yes No employee at least five (5) days prior to the employee relocating?

3f. Do the employment agreements include details about work descriptions, wages, prohibition on Yes No charging recruitment fees, work location(s), living accommodations and associated costs, time off, roundtrip transportation arrangements, grievance process, and the contents of applicable laws and regulations that prohibit trafficking in persons? 4. Housing 4a. Will the subcontractor employees be provided with housing that meets the host country Yes No standards, including safety standards?

4b. Will the employee living space be at least 50 square feet per person? Yes No

4c. Will the employee be charged for housing and food service? Yes No

5. Recruitment 5a. Do you and your subcontractor use recruiters to obtain workers? Yes No

5a(i) If yes, are the recruiters licensed in the country in which they will be recruiting? Yes No Subcontractor, and its subcontractors, shall not utilize unlicensed recruiting firms.

5a(ii) If yes, do the recruiters comply with the local labor laws of the country in which the recruiting takes place? Yes No

5b. Are your employees and/or the employees of your subcontractors charged recruitment fees? Yes No Recruitment fees are prohibited.

5c. Do you and your subcontractors and agents, have policies that prohibit the use of misleading or Yes No

Form # 1950-002 Page 2 of 5 25 Sep 15 This material contains proprietary information of IAP Worldwide Services, Inc. (IAP). Disclosure to others, use, or copying without the express written authorization of IAP is strictly prohibited. Any authorized copying of this material, in whole or in part, must include this legend. COMBATTING TRAFFICKING IN PERSONS DUE DILIGENCE QUESTIONNAIRE fraudulent 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 cost to be charged to the employee, and, if applicable, the hazardous nature of the work?

6. Compliance Plan 6a. Do you and your subcontractors have a Trafficking in Persons compliance plan or awareness Yes No program? Please provide copies of such compliance plans. Note that these compliance plans shall be provided to the Contracting Officer upon request.

6b. Do the compliance plans provide the following at a minimum: Yes No  Make employees and subcontractors aware of the Human Trafficking rules and requirements;

 Provide a process for employees to report, without fear of retaliation, including a means to make available to all employees and subcontractors a worry free hotline reporting mechanism and/or the hotline phone number of the Global Human Trafficking Hotline at 1-844-888-FREE and its email address at [email protected];

 A recruitment and wage plan that only permits the use of recruitment companies with trained employees, prohibits charging recruitment fees to the employee, and ensures that wages meet applicable host-country legal requirements or explains any variance;

 A housing plan, if you or your subcontractors intend to provide or arrange housing, that ensures that the housing meets host-country housing and safety standards;

 Procedures to prevent your company, your subcontractors, and agents at any tier and any dollar value from engaging in trafficking in persons and to monitor, detect, and terminate any employees, agents, subcontracts, or subcontractor employees who have engaged in such activities; and

 Prohibit the use of forced labor in the performance of the subcontract?

6c. Do you and your subcontractors post the relevant contents of the compliance plan, no later Yes No than the initiation of contract performance, at the workplace (unless the work is performed in the field, not in a fixed location, or at the offices of the local government) and on your and your subcontractors’ web sites.

6c(i) If this is impracticable, do you and your subcontractors provide the relevant contents of the compliance plan to each worker in writing? Yes No

Form # 1950-002 Page 3 of 5 25 Sep 15 This material contains proprietary information of IAP Worldwide Services, Inc. (IAP). Disclosure to others, use, or copying without the express written authorization of IAP is strictly prohibited. Any authorized copying of this material, in whole or in part, must include this legend. COMBATTING TRAFFICKING IN PERSONS DUE DILIGENCE QUESTIONNAIRE

7. Return Travel Costs

7a. Do you and your subcontractors pay the return travel costs to the country of origin upon the Yes No end of employment for employees who are not nationals of the country in which the work is taking place and who were brought into that country for the purpose of working on a US Government contract or subcontract?

7b. Do you and your subcontractors provide return transportation or pay the cost of return Yes No transportation in a way that does not obstruct the victim services, legal redress, or witness activity for a witness in an enforcement action related to trafficking in persons?

7c. Do you and your subcontractors pay for the return travel costs even if the employee is Yes No terminated (including for cause) or wants to leave before one year of employment?

8. Commercial Sex Acts 8a. Do you have a policy that prohibits employees from procuring commercial sex acts during Yes No the term of the performance of the subcontract?

ACKNOWLEDGEMENT and AGREEMENT

The Subcontractor acknowledges and agrees that it will comply with U.S. and local laws and regulations regarding transit/exit/entry procedures and the requirements for visas and work permits, and not engage in the illegal trafficking of persons.

The Subcontractor acknowledges and agrees that it: 1.a) has been notified of the human trafficking rules that apply to this U.S. Government contract, that it will notify its employees and subcontractors of such human trafficking rules, that the Contractor and Subcontractor may be required to take appropriate action, up to and including termination against employees, agents, or subcontractors that violate the policy. 1.b) has been informed that the Contractor is required to inform the Contracting Officer and the agency Inspector General immediately of: i. any credible information it receives from any source (including local law enforcement) that alleges a subcontractor or subcontractor employee or their agent has engaged in conduct that violates the policy; and ii. any actions taken against a subcontractor, subcontractor employee, or their agent with respect to a contractor informing the Contracting Officer and agency Inspector General of conduct that violates the policy, c) has been informed, and it shall inform its subcontractors, that failure to comply with the human trafficking rules may result in: 1.i. Termination of the subcontract; 1.ii. Suspension of subcontract payments until the subcontractor has taken appropriate remedial action; 1.iii. Declining to exercise available option periods under the contract; and

Form # 1950-002 Page 4 of 5 25 Sep 15 This material contains proprietary information of IAP Worldwide Services, Inc. (IAP). Disclosure to others, use, or copying without the express written authorization of IAP is strictly prohibited. Any authorized copying of this material, in whole or in part, must include this legend. COMBATTING TRAFFICKING IN PERSONS DUE DILIGENCE QUESTIONNAIRE

1.iv. Suspension or debarment by the U.S. Government d) shall, and it shall require, its subcontractors to: 1.i. provide timely and complete responses to Contractor and/or U.S. Government auditors’ and investigators’ requests for documents; 1.ii. cooperate fully in providing reasonable access to its facilities and staff to allow Contractor and/or the U.S. Government to conduct audits, investigations, or other actions to ascertain compliance; 1.iii. protect all employees suspected of being victims of or witnesses to prohibited activities.

CERTIFICATION

As of the date of this questionnaire, Subcontractor certifies that:

a) it will flow down to its subcontractors contract clauses that confirm that they will not engage in the illegal trafficking of persons; b) it and its employees will not procure commercial sex acts during the period of performance of the contract; c) neither it nor its subcontractors will use forced labor in performance of its services; d) it has implemented a compliance program to prevent any prohibited activities and to monitor, detect, and terminate any agent, subcontract, or subcontractor employee engaging in prohibited activities; and e) after having conducted due diligence, either: i. 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 ii. if abuses relating to any of the prohibited activities identified have been found, it or its subcontractor has taken the appropriate remedial and referral actions f) Subcontractor agrees to make such certification annually after award of the subcontract.

______Name Date Title Company name

Form # 1950-002 Page 5 of 5 25 Sep 15 This material contains proprietary information of IAP Worldwide Services, Inc. (IAP). Disclosure to others, use, or copying without the express written authorization of IAP is strictly prohibited. Any authorized copying of this material, in whole or in part, must include this legend.