In compliance with the laws and regulations of the United States (U.S.) and the United Kingdom (U.K.) regarding modern slavery and human trafficking, The Cadmus Group LLC (Cadmus) implements this Anti-Modern Slavery and Human Trafficking Compliance Policy (“Policy”) to assess, prevent and mitigate the risk of and work to influence and remedy modern slavery including human trafficking, in our supply chains and organization. Cadmus is committed to the prompt reporting to the appropriate corporate and government authorities of any instances of slavery and/or human trafficking in any aspect of its business operations, as well as those of its subcontractors, suppliers, vendors, and agents.
This Policy addresses modern slavery and human trafficking as per the scope defined in the 48 CFR / FAR 52.222-50 (FAR) and the U.K.’s Modern Slavery Act (MSA) and in alignment with applicable international standards and conventions. It encompasses conduct that constitutes any of the following:
Slavery: behavior on the part of the offender as if they owned the person, which deprives the victim of their freedom.
Servitude: the obligation to provide services that are imposed using coercion.
Forced or compulsory labor: work or service exacted from any person under the menace of any penalty and for which the person has not offered themself voluntarily.
Human trafficking for exploitation, including sexual exploitation: the act of recruiting, transporting, transferring, harboring, or receiving individuals through force, coercion, deception, or abuse of power for the purpose of exploiting them.
Child labor: defined by international labor standards (ILO) as children below 12 years working in any economic activities, those aged 12 – 14 engaged in more than light work, and all children engaged in the worst forms of child labor as defined by article 3 of ILO Convention No.182. Child labor is often defined as work that deprives children of their childhood, their potential and their dignity, and that is harmful to physical and mental development. Whether or not particular forms of “work” can be called “child labor” depends on the child’s age, the type and hours of work performed, the conditions under which it is performed and the objectives pursued by individual countries. Children can be particularly vulnerable to exploitation, but child labor will not always constitute modern slavery.
This Policy applies to Cadmus’ global operations and establishes Cadmus’ corporate compliance standards related to modern slavery and human trafficking.
Cadmus will take a proportionate approach in assessing and mitigating modern slavery and human trafficking risks, ensuring compliance with applicable laws and regulations and the relevant contractual terms and conditions on commercial and government contracts. Cadmus requires that its employees, consultants, subcontractors, suppliers, vendors and agents conduct business on behalf of Cadmus in a lawful and ethical manner, which includes the adoption of business practices as required by this Policy and any applicable division level and/or contract-specific compliance procedure or plan.
It is Cadmus’ policy to include the substance of this Policy in relevant subcontracts and contracts with suppliers, vendors, and agents to ensure compliance with relevant laws and regulations including FAR Clause 52.222-50 “Combatting Trafficking in Persons”.
Cadmus has a zero-tolerance policy towards conduct that violates modern slavery and human trafficking laws and regulations in the jurisdictions in which Cadmus does business. Where local laws and regulations are less strict than Cadmus’ policies, individuals shall follow the stricter guidance; compliance with local laws and policies is not a shield from noncompliance with Cadmus’ policy.
As codified by 22 USC 7104(g), 48 CFR Subpart 22.17 and associated clauses at 48 CFR 52.222-50 “Combatting Trafficking in Persons” and 48 CFR 52.222-56 “Certification Regarding Trafficking in Persons Compliance Plan”, Cadmus strictly prohibits any human or sex trafficking-related activities by its employees, agents, subcontractors, or subcontractor employees or agents. This includes conduct that constitutes slavery, servitude, forced, bonded (including debt bondage or peonage) or indentured labor, child labor, procurement of commercial sex acts, involuntary prison labor, or trafficking of persons, including for sexual or criminal exploitation. Human trafficking includes transporting, harboring, recruiting, transferring, or receiving persons by means of threat, force, coercion, abduction, or fraud for labor or services.
In addition to the foregoing, Cadmus, its employees, its vendors, suppliers, subcontractors, and its agents shall not, in the course of their work for Cadmus:
The Policy and associated documents are available on Cadmus’ intranet and website and incorporated into the Cadmus Employee Handbook. Cadmus will inform relevant employees, and subcontractors, agents, suppliers, and vendors of this Policy at the outset of the business relationship and thereafter at regular intervals.
Training on modern slavery and human trafficking forms part of the induction process for all relevant employees and subcontractors and is repeated annually thereafter. Relevance is determined based on the inherent risk of an employee or contractor in the course of their day-to-day work being linked to, able to influence, cause or contribute to modern slavery practices in Cadmus’ operations or its supply chain.
In compliance with the requirement of the MSA, Cadmus shall prepare and publish on the Cadmus website a “Slavery and Human Trafficking Statement” for each fiscal year that it supplies goods or services within the United Kingdom and has a total turnover of £36 million or greater. Total turnover includes the turnover of Cadmus and its subsidiaries and affiliates, including those that operate outside of the United Kingdom. The statement shall be approved by the board and posted in a prominent place on Cadmus’ website. The statement shall include:
Employees, subcontractors, suppliers, vendors, and agents that believe or suspect that an employee, agent, subcontractor, or subcontractor employee or agent has violated this policy or any applicable laws and regulations concerning modern slavery and anti-human trafficking (including pertaining to 48 CFR / FAR 52.222-50(b)) are required to immediately report such violations to one (or more) of the following:
Concerns may also be reported anonymously 24 hours, seven days a week, via Cadmus’ global hotline:
Cadmus encourages the reporting of modern slavery and human trafficking violations to relevant external services in the U.S., the U.K. and any other country where the case is identified or suspected.
Cadmus will not retaliate in any way against any individuals who make a report in good faith.
Cadmus will record all concerns that are reported and ensure that appropriate authorities and Customers including Contracting Officers are informed where a case may constitute a criminal offence. If it is suspected that any Cadmus employee, subcontractor, supplier, vendor, or agent has engaged in modern slavery, human trafficking or other human rights abuses, their contract may be suspended while an investigation takes place. Employees, suppliers, vendors, agents, subcontractors, and subcontractor employees which are confirmed to have violated this policy or applicable laws or regulations related to modern slavery and human and sex trafficking will be subject to appropriate disciplinary action, up to and including removal from Cadmus’ contracts and/or termination of their contract or employment with Cadmus.
Cadmus has implemented this Policy to prevent any prohibited activities set forth in 48 CFR / FAR 52.222-50 “Combating Trafficking in Persons” and the MSA, and shall monitor, detect, and take appropriate action, up to and including termination of contracts or employment for any employee, agent, vendor, supplier, subcontractor or their agents that is found engaging in prohibited activities. These procedures should be reviewed on a regular basis to ensure continued relevance and applicability.
Contract-level compliance policies, where applicable, will be appropriate to the size and complexity of each contract and to the nature and scope of the activities to be performed for Cadmus’ client, including the number of foreign citizens expected to be employed and the risk that the contract or subcontract will involve services or supplies susceptible to modern slavery or trafficking in persons.
Based on the implementation of appropriate corporate and contract level compliance standards related to Countering Trafficking in Persons (CTIP), when required, Cadmus will certify as follows:
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