Combatting Trafficking in Persons

Overview

Meggitt strictly forbids human trafficking and forced labor in any form which is an underlying principle of the Meggitt Code of Conduct.
As a supplier to the United States Government and U.S. Government prime contractors, Meggitt fully supports the U.S. Government’s zero tolerance policy prohibiting trafficking in persons as set out in FAR 52.222-50: Combatting Trafficking in Persons (Jan 2019) and Meggitt’s Standards of Business Conduct for the United States Government Marketplace.

Application

This Compliance Plan establishes mandatory procedures to detect trafficking in persons during Meggitt’s performance of any U.S. Government contract, subcontract, or order, to monitor for any such prohibited actions, to manage our supply chain, and to pursue remedial actions where violations may be encountered, pursuant to Federal Acquisition Regulation (FAR) 52.222-50, hereinafter the ‘Regulations’.

This Compliance Plan will be disclosed to all relevant employees, suppliers and all agents acting on our behalf, including any agencies or personnel involved in recruiting or arranging housing requirements for Meggitt employees. This Compliance Plan is to be used to support Meggitt employee conduct their jobs in compliance with the Meggitt Code of Conduct and the Regulations. This document will be updated from time to time and will be supported by compliance training.

Prohibited Actions Under The Regulations

Meggitt employees must be vigilant to avoid and detect any form of trafficking and forced labor. Prohibited trafficking and forced labor conduct under the Regulations includes any of the following activities undertaken during performance of a U.S. Government Contract, subcontract, or order:

• Engaging in any form of force, fraud or coercion to induce action from any individual;
• Paying for or coercing sex acts;
• Using forced labor / involuntary servitude i.e. using threats of serious harm, physical restraint or abuse of the law to obtain labor;
• Destroying, concealing, confiscating or otherwise denying access to an employee’s identity or immigration documents, such as passports or drivers’ licenses, regardless of issuing authority;
• Using misleading or fraudulent recruiting practices during the recruitment of employees or offering of employment. See appendix 2 for examples and more detail;
• Using recruiters that do not comply with the local labor laws of the country in which the recruiting takes place;
• Charging employees or potential employees any recruitment fees. See appendix 2 for more detail;
• Failing to provide return transportation or pay for the cost of return transportation upon the end of employment. See appendix 2 for examples and more detail;
• Provide or arrange housing that fails to meet host country housing and safety standards; and
• If required by law or contract, fail to provide an employment contract, recruitment agreement or other required work document in writing, in a language that the employee understands. See appendix 2 for more detail.

Applicability

Responsibilities and Awareness

All Meggitt employees, supply chain and those that work on behalf of Meggitt will be made aware of and support Meggitt’s commitment to identify, prevent and report modern slavery and trafficking in Persons.
All Meggitt suppliers, subcontractors, recruiters, translators, agents and those who act on Meggitt’s behalf are expected to have in place similar awareness and related procedures to prevent trafficking in persons and to also monitor, detect and take remedial actions if any of their employees, suppliers or agents have engaged in such activities.
All employees should also review the applicable appendices as set out below to understand responsibilities:

• Appendix 1 – Procurement function employee, Supplier, Subcontractor and Agent Obligations
• Appendix 2 – Human Resources (Recruitment, Wage and Housings Plans) and Recruiter Obligations

Periodic Reassessment

This Compliance Plan will be reviewed and updated annually to be responsive to FAR 52.222-50 obligations in effect and as amended from time to time.
If there are any questions regarding this Compliance Plan or its application, contact Meggitt Legal Counsel or Corporate Compliance function.

Employee Training

In addition to annual mandatory compliance training on Modern Slavery, all Meggitt employees are required to undergo Meggitt’s standard FAR 52.222-50 Human Trafficking on boarding training and acknowledge in writing that they have reviewed and agreed to adhere to this Compliance Plan during the on-boarding process.
In addition, employees at all levels must participate in periodic training on compliance with the Regulations and, where appropriate, re-certify to its requirements.

Reporting

Certifications

Where appropriate under a U.S. Government contract or customer order, Meggitt will provide pre-award and annual written certifications verifying Meggitt’s 1) implementation of this Compliance Plan, 2) the results of Meggitt’s due diligence assessments under this Compliance Plan, and 3) notice of any remedial or referral actions arising from due diligence. Meggitt will perform these activities through its Commercial function in conjunction with the Corporate Compliance function.

Notification and Cooperation

If Meggitt receives credible information from any source that there has been a breach of the Regulations, Meggitt Legal Counsel will disclose the appropriate information and any actions taken to required U.S. Government agencies and/or customers. Meggitt will also provide reasonable access to appropriate facilities and employees to investigate as determined under the Regulations.

Employee Reporting Obligations

Any employee who has credible information about conduct which violates the Regulations must report their concern immediately Meggitt Legal Counsel; or independently ran Meggitt Speak Up Line: www.meggitt.ethicspoint.eu; or the U.S. Government’s Global Human Trafficking Hotline at 1-844-888-FREE or help@befree.org.

All forms of retaliation against employees who provide credible information to Meggitt Legal or the U.S. Government is expressly prohibited and will not be tolerated. Meggitt employees who fail to abide by the Regulations, the Meggitt Code of Conduct or fail to support this Compliance Plan will be subject to appropriate disciplinary action, up to and including termination of employment.

Posting

Meggitt will provide this Compliance Plan to all relevant employees upon commencement of their employment and as necessary. This Compliance Plan will be posted at www.meggitt.com
Copies of this plan will also be provided upon customer request through the Meggitt Corporate Compliance function and each business unit’s Human Resources office.

Appendix 1 – Procurement function employee, Supplier, Subcontractor and Agent Obligations

In addition to the obligations set out above, all suppliers, subcontractors and agents will comply with the obligations set out in this Appendix 1 in relation to the Regulations and this Compliance Plan.

Additional Obligations:

1. All suppliers, subcontractors and agents authorized to act on behalf of Meggitt, along with their employees, which are engaged in Meggitt U.S. Government work, are also required to be aware of and support FAR 52.222-50 policies to identify, prevent and report prohibited trafficking in persons;
2. This begins with the requirement for suppliers and subcontractors to accept compliance with FAR 52.222-50 in all subcontracts, purchase orders and agent agreements and where required and requested, to provide certifications;
3. Suppliers and subcontractors are required to have in place procedures to prevent trafficking in persons and to likewise monitor, remediate and terminate any employees, suppliers or agents that have engaged in such activities during the performance of orders and/or subcontracts. Suppliers and subcontractors shall report any such activities immediately as required by the Regulations and contemporaneously to Meggitt Legal Counsel as advised from time to time;
4. Suppliers, subcontractors and agents are also required to cooperate with Meggitt and its customers in any investigations arising from reports alleging violation of the Regulations. This includes access to supplier, subcontractor and agents facilities, employees;
5. Failure to comply with this Compliance Plan and specifically the obligations set out in Appendix 1 will subject the supplier, subcontractor or agent to Meggitt’s remedial action, to include termination for default, eligibility determinations for future awards, and referral to the U.S. Government and other appropriate government agencies;
6. Suppliers and subcontractors performing services or providing products outside the United States with value above $550,000 (or local currency equivalent) must also have a written Compliance Plan meeting the requirements set out in FAR 52.222-50 subparagraph (h);
7. This aforementioned written plan must be available for inspection upon Meggitt’s request, including prior to award of any contract or order. Further, Meggitt will require suppliers and subcontractors to provide annual certification of their compliance under FAR 52.222-50(h)(5); and
8. All suppliers, subcontractors and agents will support Meggitt Procurement Compliance function to undertake an assessment of its suppliers both during initial on-boarding and periodic reassessments, with monitoring for compliance to the Regulations review of supplier questionnaires and written compliance plans, along with evaluation of any reports and areas of high risk.

Appendix 2 – Human Resources (Recruitment, Wage and Housings Plans) and Recruiter Obligations

In addition to the obligations set out above, the Human Resources function and recruiters working on behalf of Meggitt will comply with the obligations set out in this Appendix 2 in relation to the Regulations and this Compliance Plan.

Additional Obligations:

1. Meggitt and suppliers of recruitment services will ensure that employee wages and benefits meet host-country legal requirements;
2. Meggitt will provide focused training for its employees involved in the recruiting and oversight of recruiting agents/suppliers;
3. Meggitt will require that any agents or suppliers providing recruitment services for Meggitt comply with the Regulations and this Compliance Plan;
4. In accordance with paragraph 3 of this appendix, all agents and suppliers will make their employees aware of the Regulations and ensure that they are trained in these obligations prior to acting on Meggitt’s behalf;
5. Meggitt and any suppliers of recruitment services and agents must not use misleading or fraudulent recruiting practices during the recruitment of employees or offering of employment. Examples include failing to disclose (in a format and language known to the worker) basic information; making material misrepresentations during recruitment on key terms and conditions of employment, including on wages and fringe benefits, the location of work, the living conditions, housing and associated costs (if the employer or agent provided or arranged such), any significant costs to be charged to the employee or potential employee, and, if applicable, the hazardous nature of the work;
6. Meggitt and any suppliers of recruitment services and agents must not charge employees or potential employees any recruitment fees. Recruitment fees mean fees of any type, including charges, costs, assessments or other financial obligations that are associated with the recruiting process, regardless of the time, manner or location of the imposition or collection of the fee. These include fees for interviewing, referring, selecting, training, or providing orientation or skills testing to recommend or place potential employees. Prohibited recruitment fees can also include fees for labor certification; processing applications; acquiring visas and associated fees; acquiring photographs or identity/immigration documents or passports; medical examinations or immunizations; background or security clearance checks; recruiter, notary or legal fees; translation or language interpretation fees; government mandated fees, such as border crossing fees; transportation and subsistence costs; or equipment charges. Fees are not made permissible by deducting such fees from future wages or by calling such fees ‘voluntarily paid’;
7. Meggitt and any suppliers of recruitment services and agents must not fail to provide return transportation or pay for the cost of return transportation upon the end of employment:
   i. For an employee who is not a national of the country in which the work is taking place and who was brought into that country for the purpose of working on a U.S. Government or subcontract/order (for portions of contracts performed outside the United States);
   ii. For an employee who is not a United States national and who was brought into the United States for the purpose of working on a U.S. Government contract, subcontract or order, if the payment of return transportation costs is required under existing temporary worker programs or pursuant to a written agreement with the employee (for portions of contracts performed inside the United States);
   iii. This return requirement must be met without obstructing any victim services, legal redress or witness activity;
8. Meggitt and any suppliers of recruitment services and agents must not (if required by law or contract) fail to provide an employment contract, recruitment agreement or other required work document in writing, in a language that the employee understands.
9. Agreements with recruiters, suppliers of recruitment services and similar agents will include prohibitions on charging employees or potential employee’s recruitment fees and will require appropriate written contracts/recruitment agreements and work documents with potential employees and such agreements must ensure that employee wages and housing offered meet the applicable host-country legal requirements and housing/safety standards.

REVISION RECORD SHEET