Cadmus Anti-Human Trafficking Corporate Compliance Policy and Plan
In compliance with U.S. government laws and regulations regarding human and sex trafficking, The Cadmus Group LLC (Cadmus) implements the Cadmus Anti-Human Trafficking Corporate Compliance Policy and Plan (“Compliance Plan” or “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 Compliance Plan addresses Human Trafficking as defined in 48 CFR / FAR 52.222-50(h).
This Plan applies to all of Cadmus and establishes Cadmus’s corporate compliance standards related to human trafficking policy defined by the FAR and the firm’s policies. The 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. Where exceptional location or performance requirements require additional compliance measures, Cadmus will define a supplementary contract-specific compliance plan.
The U.S. government and Cadmus have a zero-tolerance policy prohibiting human trafficking-related activities. Pursuant to U.S. and Cadmus 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, Cadmus, 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.
I. AWARENESS PROGRAM:
- Cadmus informs its employees, agents, and subcontractors of this Compliance Plan and the firm’s Anti-Trafficking Policy. As codified by 22 USC 7104(g), 48 CFR Subpart 22.17 and associated clauses at 48 CFR 52.222-50 and 48 CFR 52.222-56, Cadmus 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 firm 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.
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 firm’s Plan or the policy of 48 CFR / FAR 52.222-50(b) are required to immediately report such violations using any of several avenues, including Cadmus’ Ethics Officer, Human Resources, Contracts department, as well as external avenues such as the Cadmus’ anonymous reporting ethics hotline and the Global Human Trafficking Hotline at 1–844–888–FREE, or email@example.com.
III. RECRUITMENT AND WAGE PLAN
- Cadmus’ direct recruiting efforts will comply with the 48 CFR / FAR 52.222-50.
- Neither Cadmus nor any agents or subcontractors of Cadmus 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 Cadmus employs the services of agents in relation to a contract that is subject to the requirement at 48 CFR/FAR 52.222-50(h), the firm will contract with entities that are appropriately trained and fully comply with local labor laws.
- The firm will not employ an agent that charges recruitment fees to the employees they recruit.
- Cadmus will ensure that wages meet applicable host-country legal requirements or explain any variance.
IV. HOUSING AND TRANSPORTATION
- If Cadmus intends to provide or arrange housing, the firm will only provide housing that meets relevant standards, including host-country housing and safety standards.
- For employees transported to a country for the purpose of working on a U.S. government contract or subcontract, the firm will provide or pay for return transportation upon the end of employment.
V. EMPLOYMENT DOCUMENTATION
- If required by contract or local law, Cadmus will provide an appropriate work document in writing to employees.
- Cadmus will not take any action to destroy, conceal, confiscate, or otherwise deny access by an employee to the employee’s identity or immigration documents.
VI. DUE DILIGENCE AND COMPLIANCE OF RELEVANT THIRD PARTIES
- Cadmus 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 Cadmus’ policy.
- As part of the standard terms and conditions for Cadmus’ subcontracting and purchasing, Cadmus requires its subcontractors and agents to certify compliance with all applicable US Government anti-trafficking laws and regulations.
- Cadmus includes FAR 52.222-50 and FAR 52.222-56 in supplier agreements where applicable.
VII. CADMUS CERTIFICATIONS UNDER 48 CFR / FAR 52.222-56
This Compliance Plan is currently in place and actively adhered to at all times and will be leveraged to implement appropriate contract-level Plans where required.
Based on the implementation of appropriate corporate and contract level compliance standards related to Countering Trafficking In Persons, when required, Cadmus will certify as follows:
- Cadmus has implemented appropriate corporate and contract-level Countering Trafficking in Persons (CTIP) to monitor, detect, notify and terminate violative behavior by employees, agents, and subcontractors or their agents.
- To the best of our knowledge and belief, Cadmus has not identified instances of representatives of Cadmus 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 performance. No abuses have been identified to date; however, if any are reported in the future, Cadmus will take appropriate notification, remediation, and mitigation action(s).