COMBATING TRAFFICKING IN PERSONS

Supplier Training Guide

DUTY CALLED. WE ANSWERED.

Please note that this training does not constitute the providing of legal advice. Suppliers should consult with their own legal counsel to ensure that they are in compliance with the requirements of the applicable laws and regulations.
Navistar is a registered trademark of , Inc.

AGENDA
Definition of human trafficking/statistics FAR 52.222-50 and related regulations Navistars Policy Suppliers Obligations

Please note that this training does not constitute the providing of legal advice. Suppliers should consult with their own legal counsel to ensure that they are in compliance with the requirements of the applicable laws and regulations.

Navistar is a registered trademark of

, Inc.

What is Human Trafficking?

Recruitment, transportation, transfer, harboring or receipt of persons . . . By means of threat, use of force, coercion, abduction, fraud, deception, abuse or exploitation. Holding and/or transporting people against their will. Forcing people into servitude through violence and/or deception. Buying or selling human beings.

Supporting trafficking by hiring forced prostitutes or patronizing forced labor establishments.

Please note that this training does not constitute the providing of legal advice. Suppliers should consult with their own legal counsel to ensure that they are in compliance with the requirements of the applicable laws and regulations.

Navistar is a registered trademark of

, Inc.

Map of Human Trafficking

Source: Globalization101.org
Please note that this training does not constitute the providing of legal advice. Suppliers should consult with their own legal counsel to ensure that they are in compliance with the requirements of the applicable laws and regulations.

Navistar is a registered trademark of

, Inc.

Human Trafficking Statistics

Please note that this training does not constitute the providing of legal advice. Suppliers should consult with their own legal counsel to ensure that they are in compliance with the requirements of the applicable laws and regulations.

Navistar is a registered trademark of

, Inc.

Human Trafficking Statistics

2nd largest criminal industry in the U.S. behind drug and arms trafficking 1in 1,565 people in the U.S. is trafficked every year $34,000,000,000 industry worldwide

Please note that this training does not constitute the providing of legal advice. Suppliers should consult with their own legal counsel to ensure that they are in compliance with the requirements of the applicable laws and regulations.

Navistar is a registered trademark of

, Inc.

FAR 52.222-50
Employees directly engaged in the performance of work on a government contract (any contract entered into from February 17, 2009 on) who have other than a minimal impact or involvement in contract performance are prohibited from:
Engaging in severe forms (i.e., using force, fraud or coercion) of trafficking in persons during the period of performance of the contract; Procuring commercial sex acts during the period of performance of the contract; or Using forced labor in the performance of the contract.
Please note that this training does not constitute the providing of legal advice. Suppliers should consult with their own legal counsel to ensure that they are in compliance with the requirements of the applicable laws and regulations.

Navistar is a registered trademark of

, Inc.

Proposed Changes to the FAR

Prohibits using misleading or fraudulent recruiting practices; Prohibits charging employees recruitment fees; Prohibits destroying, concealing, confiscating or otherwise denying access to employee identity or immigration documents; Prohibits failing to pay return transportation costs for certain employees who have finished employment outside that employees nation of residence;
Please note that this training does not constitute the providing of legal advice. Suppliers should consult with their own legal counsel to ensure that they are in compliance with the requirements of the applicable laws and regulations.

Navistar is a registered trademark of

, Inc.

Proposed Changes to the FAR

Prohibits providing or arranging housing that fails to meet the host country housing and safety requirements; and If required, must provide an employment contract, recruitment agreement or similar work document in writing in the employees native language and prior to the employee departing from his or her country of origin.

Please note that this training does not constitute the providing of legal advice. Suppliers should consult with their own legal counsel to ensure that they are in compliance with the requirements of the applicable laws and regulations.

Navistar is a registered trademark of

, Inc.

Navistar Defenses Policy

Navistar Defense is opposed to human trafficking and forced labor in any form. Navistar Defense is committed to working to mitigate the risk of human trafficking and forced labor in all aspects of our business. Navistars Policy prohibits any violation of FAR 52.222-50, Executive Order 13627 issued 9/25/2012 and the proposed FAR amendments strengthening protections against trafficking in humans.
Please note that this training does not constitute the providing of legal advice. Suppliers should consult with their own legal counsel to ensure that they are in compliance with the requirements of the applicable laws and regulations.

Navistar is a registered trademark of

, Inc.

Navistar Defenses Policy

Any violations of the FAR, the Executive Order and the proposed FAR amendments and this Policy could result in disciplinary action which may include but are not limited to, an employees removal from the contract, reduction in benefits or termination of employment.

Please note that this training does not constitute the providing of legal advice. Suppliers should consult with their own legal counsel to ensure that they are in compliance with the requirements of the applicable laws and regulations.

Navistar is a registered trademark of

, Inc.

Suppliers Obligations
All contracts with the US government, even those within performed within the US, will prohibit: Destroying, concealing, confiscating or otherwise denying access to employee identity or immigration documents; Using misleading or fraudulent recruiting practices during the recruitment of employees; Charging employees recruitment fees, providing or arranging housing that fails to meet host country housing and safety standards; Failing to pay return transportation costs for certain employees who have finished employment outside that employees nation of residence; and Failing to provide in writing an employment contract, recruitment agreement or similar work paper in employees native language prior to their departing from their country of origin. Furthermore, contractors must protect and interview all employees suspected of being victims of or witnesses to prohibited activities, prior to returning to their country of origin, and contractors must not prevent or hinder employees from cooperating fully with government authorities.

Please note that this training does not constitute the providing of legal advice. Suppliers should consult with their own legal counsel to ensure that they are in compliance with the requirements of the applicable laws and regulations.

Navistar is a registered trademark of

, Inc.

Suppliers Obligations
For contracts where portion to be performed outside the United States exceeds $500,000 (except for solely COTS contracts), suppliers must have and post a compliance plan that includes the following (see proposed rules for more detail):
An awareness program; A reporting process for employees; A recruitment and wage plan; A housing plan (if applicable); and Procedures to prevent agents and subcontractors at any tier from engaging in trafficking in persons and to monitor, detect, and terminate any agents, subcontractors or subcontractor employees that have engaged in such activities.
Please note that this training does not constitute the providing of legal advice. Suppliers should consult with their own legal counsel to ensure that they are in compliance with the requirements of the applicable laws and regulations.

Navistar is a registered trademark of

, Inc.

Suppliers Obligations
Contractor must certify that it has implemented the compliance plan to prevent prohibited activities and monitor, detect, and terminate any subcontract engaging in prohibited activities. Contractor must also certify that, after having conducted due diligence, to the best of the contractors knowledge and belief, (1) neither it nor any of its agents, subcontractors, or their agents is engaged in any trafficking in persons activities or, (2) if abuses have been found, the contractor or subcontractor has taken the appropriate referral and remediation actions.
Please note that this training does not constitute the providing of legal advice. Suppliers should consult with their own legal counsel to ensure that they are in compliance with the requirements of the applicable laws and regulations.

Navistar is a registered trademark of

, Inc.

FAILURE TO COMPLY

Any failure by any supplier to comply with the requirements of the FAR, the proposed amendments to the FAR and/or the Executive Order is grounds for Navistar Defense to take any and all appropriate actions up to, and including, immediate termination of that suppliers contract with Navistar Defense.
Please note that this training does not constitute the providing of legal advice. Suppliers should consult with their own legal counsel to ensure that they are in compliance with the requirements of the applicable laws and regulations.
Navistar is a registered trademark of , Inc.

Contact us at: HTlawscompliance@navistar.com

Navistar is a registered trademark of

, Inc.