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. Governmentâs zero tolerance policy prohibiting trafficking in persons as set out in FAR 52.222-50: Combatting Trafficking in Persons (Jan 2019) and Meggittâs Standards of Business Conduct for the United States Government Marketplace.
This Compliance Plan establishes mandatory procedures to detect trafficking in persons during Meggittâs 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 âRegulationsâ.
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.Â 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.Â This document will be updated from time to time and will be supported by compliance training.
Meggitt employees must be vigilant to avoid and detect any form of trafficking and forced labor.Â 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:
Responsibilities and Awareness
All Meggitt employees, supply chain and those that work on behalf of Meggitt will be made aware of and support Meggittâs commitment to identify, prevent and report modern slavery and trafficking in Persons.
All Meggitt suppliers, subcontractors, recruiters, translators, agents and those who act on Meggittâs 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:
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.
In addition to annual mandatory compliance training on Modern Slavery, all Meggitt employees are required to undergo Meggittâs 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.
Where appropriate under a U.S. Government contract or customer order, Meggitt will provide pre-award and annual written certifications verifying Meggittâs 1) implementation of this Compliance Plan, 2) the results of Meggittâs due diligence assessments under this Compliance Plan, and 3) notice of any remedial or referral actions arising from due diligence.Â 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. Â 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. Governmentâs Global Human Trafficking Hotline at 1-844-888-FREE or firstname.lastname@example.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.Â 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.
Meggitt will provide this Compliance Plan to all relevant employees upon commencement of their employment and as necessary.Â 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 unitâs Human Resources office.
Approved by the Board of Directors December 2021.