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Designatronics Policy Regarding Trafficking in Persons and Procurement of Commercial Sex Acts

DESIGNATRONICS, INC. Code of Conduct Policy 
Updated:  June 26, 2018

PURPOSE:

The United States (“U.S.”) Government has a zero-tolerance policy relating to Trafficking in Persons and procuring Commercial Sex Acts, commercial related behavior. Designatronics, Inc. (“COMPANY”) intends to comply to the fullest extent possible with the US policy relating to Trafficking in Persons and Procuring Commercial Sex Acts and the purpose of this Policy is to implement such U. S. Government policy.

SCOPE:

This policy applies to all employees, subcontractors, agents and all employees of subcontractors and agents of COMPANY, its subsidiaries and affiliated companies worldwide.

POLICY:

Background

Trafficking in persons, forced labor, and commercial sex are contrary to traditional values of dignity and respect and are illegal in many countries where COMPANY conducts its business. If an employee or representative of the company engages in said illegal behavior, such actions are contrary to COMPANY's Code of Business Conduct.

COMPANY has adopted a zero-tolerance policy regarding COMPANY employees, COMPANY Subcontractors and Subcontractor's employees that engage in or support Severe Forms of Trafficking in Persons, procurement of Commercial Sex Acts, or use of forced labor.

Failure to comply with this policy will result in disciplinary action up to or including removal from the host country assignment location or termination of employment. In addition, conduct that involves Trafficking in Persons may also violate (a) host country Government laws and regulations relating to Severe Forms of Trafficking in Persons, procurement of Commercial Sex Acts, and use of forced labor, and (b) United States laws and regulations on Severe Forms of Trafficking in Persons, procurement of Commercial Sex Acts, and use of forced labor which may apply to its employees' conduct in the host nation, including those laws for which jurisdiction is established by the Military Extraterritorial Jurisdiction Act of 2000 (18 U.S.C. 3261-3267 and 18 U.S.C. 3271 Trafficking in Persons Offenses Committed by Persons Employed by or Accompanying the Federal Government Outside the United States).

ROLES AND RESPONSIBILITIES:

COMPANY employees, COMPANY subcontractors or agents or subcontractors’ employees or agent’s employees within the scope of their employment or contract relationship with COMPANY or in connection with or during the performance of a U.S. Government contract will not:
  • Engage in or promote Severe Forms of Trafficking, which means (i) Sex Trafficking in which a Commercial Sex Act is induced by force, fraud, or Coercion, or in which the person induced to perform such act has not attained 18 years of age, or (ii) the recruitment, harboring, transportation, provision, or obtaining of a person for labor or services, through the use of force, fraud, or Coercion for the purpose of subjection to Involuntary Servitude, peonage, Debt Bondage, or slavery.

  • Engage in Commercial Sex Acts, which means any sex act where anything of value is given to or received by any person.

  • Use, engage in, or promote forced labor, which includes the use of Coercion:

    • 1. Threats of serious harm to or physical restraint against any person;

      2. Any scheme, plan, or pattern intended to cause a person to believe that failure to perform an act would result in serious harm to or physical restraint against any person;

      3. The abuse or threatened abuse of the legal process; or

      4. Debt bondage, which is the status or condition of a debtor arising from a pledge by the debtor of his or her personal services or of those of a person under his or her control as a security for a debt, if the value of those services as reasonably assessed is not applied toward the liquidation of the debt or the length and nature of those services are not respectively limited and defined.
When informed of or witness to a violation of this policy, or when in doubt about the propriety of a particular course of action, employees are encouraged to contact their supervisor or, if contact with their supervisor is not feasible, contact the President of the COMPANY. Communications can be made to the COMPANY President every day, 24 hours a day by email at RKufner@designatronics.com.

COMPANY agents and subcontractors and the agents and subcontractor's employees will not engage in or support severe forms of trafficking in persons, procure commercial sex acts, or use forced labor during the performance of all contracts. Subcontractors and agents will communicate the Company’s zero-tolerance policy to its employees as well as the Company’s intent to enforce same. Failure to comply with this policy will constitute a material breach of the agreement being performed on behalf of Company and will subject the violating party to termination of the contract as well as damages relating to the breach.

DEFINITIONS:

Coercion means (i) threats or serious harm to or physical restraint against any person, (ii) any scheme, plan, or pattern intended to cause a person to believe that failure to perform an act would result in serious harm to or physical restraint against any person, or (iii) the abuse or threatened abuse of the legal process.

Commercial Sex Act means any sex act where anything of value is given to or received by any person.

Debt Bondage means the status or condition of a debtor arising from a pledge by the debtor of his or her personal services or of those of a person under his or her control as a security for debit, if the value of those services as reasonably assessed is not applied toward the liquidation of the debt or the length and nature of those services are not respectively limited and defined.

Involuntary Servitude means a condition of servitude induced by means of (i) any scheme, plan, or pattern intended to cause a person to believe that, if the person did not enter into or continue in such conditions, that person or another person would suffer serious harm or physical restraint, or (ii) the abuse or threatened abuse of the legal process.

Severe Forms of Trafficking means (i) sex trafficking in which a commercial sex act is induced by force, fraud, or coercion, or in which the person induced to perform such act has not attained 18 years of age, or (ii) the recruitment, harboring, transportation, provision, or obtaining of a person for labor or services, through the use of force, fraud, or Coercion for the purpose of subjection to Involuntary Servitude, peonage, Debt Bondage, or slavery.

Sex Trafficking means the recruitment, harboring, transportation, provision, or obtaining of a person for the purpose of a commercial sex act.

REFERENCES:

Code of Federal Regulations, 48 CFR 52.222-50 Combating Trafficking in Persons