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PURPOSE

 

As outlined in the Federal Acquisition Regulation (FAR 52.222-50) and Executive Order 13627 Strengthening Protections Against Trafficking in Persons in Federal Contracts, Venone Public Relations LLC, is required to develop and maintain a compliance plan during the performance of contract(s) or subcontract(s) that is appropriate for the size and complexity of the contract or subcontract and the nature and scope of the activities performed, including the risk that the contract or subcontract will involve services or supplies susceptible to trafficking. In accordance with CPS-734, Combating Trafficking in Persons, this document represents Venone Public Relations LLC compliance plan and must be provided to the contracting officer upon request. Additionally, relevant contents of the plan will be posted on our website.

 

COMBATING TRAFFICKING IN PERSONS

RECRUITMENT ACTIVITIES & EMPLOYEE AWARENESS

 

Introduction

Our global policies, procedures, and practices reflect our strong commitment to good company citizenship. This commitment underlies our code of ethics and values. Respect for human rights is an important part of being a good company citizen and applies to all employees, contractors, and those who represent us.

 

Venone Public Relations LLC employs and contracts the best qualified talent to support the business mission, goals, and services. Employees, agents, subcontractors, and recruiters play a key role in preventing human trafficking and related activities. Human trafficking and related activities include harboring, transportation, provision,or obtaining of a person for labor or services, through the use of force, fraud, or coercion for thepurpose of subjection to involuntary servitude, peonage, debt bondage, or slavery.

 

To minimize the risk of human trafficking and to comply with contractual requirements

regarding human trafficking and related activities, Venone Public Relations LLC takes a multifaceted approach to address the risk of human trafficking and related activities outlined below.

 

Applicability

The Venone Public Relations LLC compliance program applies to all employees, owners, contractors, and others who represent and act for our company. With respect to any subsidiaries that are wholly owned or controlled by Venone Public Relations LLC the Responsible Organization will ensure such entities have adopted our compliance program as outlined below. With respect to entities Venone Public Relations LLC neither wholly owns nor controls, but in which Venone Public Relations LLC owns a substantial interest, the company will communication an expectation that the entity will adopt this compliance program consistent with the Venone Public Relations LLC Supplier Code of Conduct.

 

EXTERNAL RECRUITMENT AGENCY SUPPORT

In collaboration with the program for monitoring components, Venone Public Relations LLC will ensure all contracts with external recruitment agencies or firms include the following contract clauses, as applicable, to facilitate compliance with prime contract requirements regarding human trafficking, in addition to requiring such agencies or firms to adhere to all applicable local, state, and national government laws:

 

  • FAR 52.222-50 Combating Trafficking in Persons (applies to all subcontracts and contracts with agents).

  • DFARS 252.203-7004 Display of Hotline Posters, as appropriate (applies to subcontracts under Department of Defense prime contracts that exceed $5 million except when the subcontract is for the acquisition of a commercial item).

  • DFARS 252.225-7040 Contractor Personnel Supporting U.S. Armed Forces Deployed Outside the United States (applies to subcontracts under Department of Defense prime contracts that require subcontractor personnel to be available to deploy with or otherwise provide support in the theater of operations to U.S. military forces deployed outside the United States in:

    • (1) contingency operations;

    • (2) humanitarian or peacekeeping operations; or

    • (3) other military operations or exercises designated by the Combatant Commander).

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EMPLOYEE AWARENESS PROGRAM

Venone Public Relations LLC  Policy Statement is published on our website and is the primary tool for employee awareness. This policy requires all employees and contractors to comply with FAR 52.222-50, Combatting Trafficking in Persons, and specifies that violations may result in disciplinary action, up to and including termination of employment. Venone Public Relations LLC’s awareness program includes a communications plan to ensure ongoing awareness is provided.

 

Training and other Assistance

Venone Public Relations LLC has developed initial training for internal recruiters and hiring managers. Venone Public Relations LLC will continue to develop and maintain training modules that support our commitment to human rights, including child or forced labor, trafficking of persons, adherence to labor laws, including adherence to truthful and trustworthy practices during the recruitment of employees or offering of employment, proper disclosure of information, and proper representations during the recruitment process to include key terms and conditions of employment, wages, fringe benefits, work location, housing, and nature of work. As this program evolves, employees will be required to read our policy and affirm their understanding of the policy.

 

Should an employee be unsure of what to do in a particular situation or for guidance on any

aspect of the policy, they should consult their manager, Human Resources, or Legal Counsel for guidance on the policies, procedures, or the law.

 

REPORTING VIOLATIONS

Any credible information received from any source (including host country law enforcement) that an employee, subcontractor, subcontractor employee, or agent has violated FAR 52.222-50 must be reported immediately to your supervisor and human resources manager. If the event may require reporting under FAR 52.222-50, he or she immediately shall notify: (1) the corporate President or designee, and Human Resources. If the matter involves subcontractors, contractors, or vendors, the same reporting parameters apply.

 

Employees may also report, without fear of retaliation, activity inconsistent with the policy prohibiting trafficking in persons to the Global Human Trafficking Hotline (1-844-888-FREE; help@befree.org). If a violation of FAR 52.222-50 is substantiated, Human Resources, in consultation with our Legal Counsel and company President, will ensure the appropriate disciplinary action is taken. In consultation with Legal Counsel, suitable remedies may be imposed upon subcontractors, agents, and external recruitment agencies who fail to comply with FAR 52.222-50. Legal Counsel is responsible for preparing a written draft report of the violation and investigation and providing it to the President or designee for review.

 

REASSESSMENT OF COMPLIANCE PLANS

Human Resources is responsible for identifying the need for supplementation of this

primary compliance plan to address the risk of human trafficking for a particular business

opportunity. When a supplement is determined to be required, Human Resources and

shall prepare and provide a supplement describing any additional measures that will be undertaken to enhance the compliance plan for a particular business opportunity.

 

For purposes of the supplemental plan, the primary compliance plan template can be used with the inclusion of the necessary additional information in the recruitment, wage, housing, and training plan areas.

 

Periodic Reassessment of the Plan

Venone Public Relations LLC will periodically review and assess the internal controls assuring compliance with this Plan. Modification of controls and measures will be implemented as required.

 

TRAFFICKING IN PERSONS COMPLIANCE PLAN FOR GLOBAL SUPPLY CHAIN CONTRACTS

Any subcontractors used by Venone Public Relations LLC performance of its contracts.

This includes domestic U.S. suppliers, including recruitment agencies, that perform work under contracts outside the United States and international subcontractors that perform work throughout the world. Subcontractors play a key role in preventing human trafficking and related activities. To minimize the risk of human trafficking in its supply chain, and to comply with contractual requirements to prevent human trafficking in connection with Venone Public Relations LLC contracts, Venone Public Relations LLC employs a multifaceted approach to address the risk of human trafficking in its supply chain.

 

Monitoring of Government Databases

Venone Public Relations LLC monitors the U.S. Government’s System for Award Management (SAM) Exclusions database and other restricted parties lists and complies with applicable limitations on award to debarred, suspended, proposed for debarment, or otherwise restricted subcontractors.

 

Flowdowns

All subcontracts include mandatory flow down clauses necessary to ensure compliance with this Plan and the requirements of prime contracts. This includes the following:

  • FAR 52.222-50 Combating Trafficking in Persons (applies to all subcontracts and contracts with agents).

  • DFARS 252.203-7004 Display of Hotline Posters (applies to subcontracts under Department of Defense prime contracts that exceed $5 million, except when the subcontract is for the acquisition of a commercial item). 252.225-7040 Contractor Personnel Supporting U.S. Armed Forces Deployed Outside the United States (applies to subcontracts under Department of Defense prime contracts that require subcontractor personnel to be available to deploy with or otherwise provide support in the theater of operations to U.S. military forces deployed outside the United States in (1) contingency operations; (2) humanitarian or peacekeeping operations; or (3) other military operations or exercises designated by the Combatant Commander)).

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Contractual Requirements for Compliance with Applicable Laws

Venone Public Relations LLC subcontract terms and conditions require subcontractors to comply with applicable laws and regulations. A typical provision reads as follows: SELLER, in the performance of this Contract, shall comply with all applicable local, state, andfederal laws, orders, rules, regulations, and ordinances. SELLER shall procure all licenses/permits, pay all fees, and other required charges and shall comply with all applicable guidelines and directives of any local, state and/or federal governmental authority.

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CERTIFICATIONS

Venone Public Relations LLC will obtain trafficking in persons certifications from subcontractors required to certify under FAR 52.222-50. Certificates will be required before award of subcontracts and annually thereafter when performance extends beyond one year.

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Obtaining and Reviewing Supplier Compliance Plans

Venone Public Relations LLC will require subcontractors to provide copies of their trafficking in persons compliance plan upon request of either the contracting officer or Venone Public Relations LLC. Plans may also be required when needed in conducting due diligence of supplier compliance.

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REGISTRY AS A VENONE PUBLIC RELATIONS LLC SUPPLIER

Prospective international subcontractors are required to disclose certain contractor integrity and anticorruption information prior to being eligible for receipt of subcontracts. Among the disclosures required is whether the subcontractor has been convicted of, indicted or otherwise charged by any governmental entity for the commission of among other things, violation of human trafficking or child labor laws. Subcontractors are required to inform Venone Public Relations LLC if their status changes. If a supplier discloses a violation, the matter will be investigated and appropriate action taken.

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SUPPLIER CODE OF CONDUCT

Venone Public Relations LLC maintains a Supplier Code of Conduct which is published available to suppliers and referenced on all purchase orders. It includes the following:

We expect our suppliers to not engage in the use of forced, bonded (including debt bondage) or indentured labor, involuntary prison labor, slavery, or trafficking of persons. This includes transporting, harboring, recruiting, transferring, or receiving vulnerable persons by means of threat, force, coercion, abduction, or fraud for the purpose of exploitation.

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Monitoring of Contracts Performed Outside the United States

When Venone Public Relations LLC’s personnel are present in international areas where subcontractors are performing work, the activities of the subcontractors will be monitored for potential trafficking problem or issues. If issues are suspected or found, the matter will be investigated and appropriate action taken.

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Monitoring Third Party Sources of Information

Venone Public Relations LLC monitors multiple sources of third party information including international news sources. If adverse information concerning a Venone Public Relations LLC supplier is discovered, the matter will be investigated and appropriate action taken.

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Investigations

Venone Public Relations LLC will investigate evidence or allegations that subcontractors have violated human trafficking prohibitions. Subcontractors are required by Venone Public Relations LLC’s terms and conditions of purchase to “provide reasonable cooperation to Venone Public Relations LLC in conducting any investigation regarding the nature and scope of any failure by [the subcontractor] or its personnel to comply with applicable local, state, and federal laws, orders, rules, regulations, and ordinances that may affect the performance of [the subcontractor’s] obligations under this Contract.”

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Venone Public Relations LLC will make appropriate disclosures to the U.S. Government of violations by subcontractors and cooperate with any Government investigation.

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Remedies

Venone Public Relations LLC will take appropriate action when subcontractors are found to engage in prohibited conduct, including the remedies specified in FAR 52.222.50. Where appropriate or required, Venone Public Relations LLC will coordinate with the U.S. Government prior to the implementation of remedies against subcontractors.

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Eligibility for Future Contracts

The record of a subcontractor’s compliance with human trafficking requirements will be

considered in making future subcontractor source selections. Subcontractors that have engaged in prohibited conduct may be excluded from eligibility of future awards.

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TRAINING AND OTHER ASSISTANCE

Venone Public Relations LLC will make training materials available to subcontractors and provide other assistance to suppliers upon request. Suppliers needing assistance with developing compliance plans will be provided with copies of Venone Public Relations LLC Compliance Plan, its Code of Conduct, and Supplier Code of Conduct as needed.

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PERIODIC REASSESSMENT OF THE PLAN

Venone Public Relations LLC will periodically review this Plan. Additional or different controls and measures will be implemented as required.

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