Anti-Trafficking in Persons Compliance Policy 2019-09-06T09:44:10-04:00

Anti-Trafficking in Persons Compliance Policy

Anti-Trafficking in Persons Compliance Policy

American Panel Corporation (APC) has developed an Anti-Trafficking in Persons Compliance Plan (“Plan”) in accordance with the U.S. Government’s zero-tolerance policy regarding trafficking in persons by government contractors and award recipients, as set out in FAR Subpart 22.17 and 52.222-50.

The purpose of the Plan is to: (1) set out APC’s anti-trafficking in persons policies and procedures; (2) make APC employees aware of the conduct prohibited under APC policy and the Federal Anti-Trafficking in Persons Provisions and the actions that may be taken against employees for violations; (3) employ fair recruitment, wage and housing practices; (4) inform APC employees of processes available for them to report without fear of retaliation any activity inconsistent with APC’s anti-trafficking in persons policy; (5) prevent prohibited trafficking activity by agents of the Company, suppliers and sub-contractors, and monitor, detect and terminate those who engage in such activities; and (6) establish APC reporting requirements and remediation procedures.

  • APC strictly prohibits its employees, agents, and all subcontractors from:
  • engaging in trafficking in persons;
  • procuring commercial sex acts;
  • using forced labor;
  • destroying, concealing, confiscating, or otherwise denying an employee access to the employee’s identity or immigration documents;
  • soliciting a person for the purpose of employment, or offering employment, by means of materially false or fraudulent pretenses, representations or promises regarding that employment;
  • using recruiters that do not comply with local labor laws of the country in which the recruiting takes place;
  • charging employees recruitment fees;
  • failing to provide return transportation or pay for return transportation costs to an employee from a country outside the US to the country from which the employee was recruited upon the end of employment if requested by the employee; and
  • providing or arranging housing that fails to meet the host country housing and safety standards.

APC employees who engage in any of the prohibited acts will be disciplined, up to and including dismissal. APC will take appropriate action up to and including termination of its agreements with any agents of the Company, suppliers or subcontractors who engage in any of the prohibited acts.

All employees of APC, or its suppliers or subcontractors and agents of the Company are encouraged to report any activity or condition that may violate APC’s Anti-Trafficking in Persons Policy, confidentially and without retaliation, to the appropriate supervisor or Human Resources. This is also available for employees to report any workplace concern or potential violation of the terms and conditions of their employment contracts. Employees may also report their concerns directly to the Global Human Trafficking Hotline at 1-844-888- FREE or its email address at help@befree.org.

REVISION:-
EFFECTIVE DATE: 9/4/2019
DOCUMENT NUMBER: APC-08
WRITTEN BY: Marsha Rivard