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.

Approved by the Board of Directors December 2021.


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