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).
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.
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 firstname.lastname@example.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.
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.
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
• 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).
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