Compulink Anti-Trafficking Policy

Anti-Trafficking Compliance Plan

Background and Purpose

In Compliance with United States laws and regulations regarding human trafficking, kSARIA Corporation (“kSARIA” or the “Company”) implements the kSARIA Anti-Human Trafficking Corporate Compliance Policy and Plan (the “Plan”) to prevent, identify and promptly notify the appropriate corporate and government authorities of any prohibited human and sex trafficking in any aspect of its business operations, as well as those of its subcontractors and agents. This Plan addresses Human Trafficking as defined in 48 CFR 52.222-50(h).

Applicability

This Plan applies to and will be implemented under, all U.S. federal contracts or subcontracts for supplies, other than commercially available off-the-shelf items, acquired outside the United States, or services to be performed outside the United States with an estimated value that exceeds $500,000. However, the Plan may be adapted with respect to the size and complexity of the project and to the nature and scope of the activities to be performed for the Government, including the number of non-United States citizens expected to be employed and the risk that the contract or subcontract will involve services or supplies susceptible to trafficking in persons.

Policy

The U.S. government and kSARIA have a zero-tolerance policy prohibiting human trafficking-related activities. Pursuant to U.S. and Company policy, forced, bonded (including debt bondage) or indentured labor, commercial sex, involuntary prison labor, slavery, or trafficking of persons shall not be used. This includes transporting, harboring, recruiting, transferring, or receiving persons by means of threat, force, coercion, abduction, or fraud for labor or services.

Furthermore, as required by law, kSARIA, its employees, its subcontractors, and its agents shall not:

• Destroy, conceal, confiscate, or otherwise deny access by an employee to the employee’s identity or immigration documents, such as passports or drivers’ licenses, regardless of issuing authority.
• Use misleading or 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.
• Use recruiters that do not comply with local labor laws of the country in which the recruiting takes place.
• Charge employees recruitment fees.
• Where employees are recruited from another country, fail to provide return transportation or pay for the cost of return transportation upon the end of employment.
• If required by law, fail to provide an employment contract, recruitment agreement, or other required work document in writing.

Employee Awareness Program

kSARIA informs its employees of this Plan and strictly prohibits any human or sex trafficking-related activities by its employees, agents, subcontractors, or subcontractor employees or agents. Employees, agents, subcontractors, and subcontractor employees violating any applicable U.S. government law or regulation related to human and sex trafficking or Company policy will be subject to appropriate disciplinary action, up to and including removal from U.S. government contracts and/or termination of contract or employment.

Reporting Requirements and Procedure

Employees with credible information from any source that an employee, agent, subcontractor, or subcontractor employee or agent has engaged in human trafficking activities that violate the Company’s Plan or federal law are required to immediately report, without fear of retaliation, such violations using any of several avenues, including kSARIA’s human resources department, as well as external avenues such as the Global Human Trafficking Hotline at 1–844–888–FREE, or help@befree.org.

Recruitment and Wage Plan

As required by law, kSARIA will recruit employees and pay wages within the following parameters:

• kSARIA’s direct recruiting efforts will comply with 48 CFR 52.222-50(h).
• Neither kSARIA nor any agents or subcontractors of kSARIA shall engage in misleading or fraudulent practices in the recruitment of employees for performance of U.S. Government contracts. Key terms of each employee’s condition of employment will be provided in writing.
• Whenever kSARIA employs the services of agents in relation to a contract that is subject to the requirements of 48 CFR 52.222-50(h), the Company will contract with entities that are appropriately trained and fully comply with local labor laws.
• The Company will not employ an agent that charges recruitment fees to the employees they recruit.
• kSARIA will ensure that wages meet applicable host-country legal requirements or explain any variance.

Housing Plan

kSARIA does not often arrange or provide housing. However, in situations where kSARIA provides housing to employees, the housing will meet host country housing and safety standards.

Due Diligence and Compliance of Third Parties

kSARIA has procedures in place to prevent agents and subcontractors at any tier or dollar value from violations and to monitor, detect, and terminate any agents, subcontractors, or subcontractor employees that have violated this Plan. kSARIA agents and subcontractors must agree to comply with this Plan and all applicable anti-trafficking laws and regulations. kSARIA has included 48 CFR 52.222-50 and 48 CFR 52.222-56 in supplier agreements where applicable.

Required Certification

This Plan is currently in place and actively adhered to at all times and will be leveraged to implement appropriate contract-level Plans where required.

When required by 48 CFR 52.222-56, kSARIA will certify as follows:

• kSARIA has implemented a Plan and will monitor, detect, notify and terminate violative behavior by employees, agents, and subcontractors or their agents.
• To the best of our knowledge and belief, kSARIA has not identified instances of representatives of kSARIA engaged in any trafficking-related activities, including severe forms of human trafficking, the use of forced labor, or the procurement of commercial sex acts during contract performance.
• No abuses have been identified to date; however, if any are reported in the future, kSARIA will take appropriate notification, remediation, and mitigation action(s).

Posting

kSARIA will post this Plan at all workplaces, except where the work is being performed in the field or not otherwise at a fixed location.