Since 2006, federal contractors have been required to abide by the government’s zero tolerance policy for human trafficking, put policies and procedures in place, inform employees of the policy and consequences, and include the same “Combating Trafficking in Persons” clause in any subcontracts. Contracts can be terminated and contractors can be debarred.
Last summer, the U.S. Government launched mandated training for federal contracting officers responsible for oversight of individual contracts. The training’s objectives are that the contracting officers understand both human trafficking and the contractor requirements, how to conduct verification and assess compliance, and what to do in cases of violations.
Last fall’s Executive Order — Strengthening Protections Against Trafficking In Persons In Federal Contracts – prohibits federal contractors from engaging in fraudulent recruiting or misrepresenting the terms of the job or housing, charging recruitment fees, and confiscating identification documents including a passport. For all contracts of $500,000 or greater or to be performed abroad, contractors and subcontractors must submit a compliance plan and post it publicly on their website. The plan must detail recruitment, wages, housing, an employee awareness program of the corporate policies, and an employee reporting process. Additionally, federal contractors are required to comply with investigations and audits.
The alternate view of increased legal obligations is that of opportunity. One, to demonstrate the good labor practices that so many already have in place, something about which corporate stakeholders are increasingly concerned. And two, to use the required employee awareness program not only to roll out corporate policy, but also as a way to equip employees to identify human trafficking in their community.
Learn more at Kelly Heinrich’s and Kavitha Sreeharsha’s Huffington Post article: Opportunity for Federal Contractors to Lead on Human Trafficking.