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COMBATING TRAFFICKING IN PERSONS

Supplier Training Guide

DUTY CALLED. WE ANSWERED.
Please note that this training does not constitute the providing of legal advice. Suppliers should consult with their own legal counsel to ensure that they are in compliance with the requirements of the applicable laws and regulations.
Navistar® is a registered trademark of , Inc.

Navistar® is a registered trademark of .222-50 and related regulations Navistar’s Policy Suppliers’ Obligations Please note that this training does not constitute the providing of legal advice. Suppliers should consult with their own legal counsel to ensure that they are in compliance with the requirements of the applicable laws and regulations.AGENDA • • • • Definition of human trafficking/statistics FAR 52. Inc. .

• Buying or selling human beings. . Navistar® is a registered trademark of . transfer. By means of threat. coercion. Inc. transportation. harboring or receipt of persons . Please note that this training does not constitute the providing of legal advice. Suppliers should consult with their own legal counsel to ensure that they are in compliance with the requirements of the applicable laws and regulations. • Forcing people into servitude through violence and/or deception. fraud. . deception. use of force. abuse or exploitation. • Supporting trafficking by hiring forced prostitutes or patronizing forced labor establishments. .What is Human Trafficking? • Recruitment. • Holding and/or transporting people against their will. abduction.

Map of Human Trafficking Source: Globalization101.org Please note that this training does not constitute the providing of legal advice. Navistar® is a registered trademark of . . Suppliers should consult with their own legal counsel to ensure that they are in compliance with the requirements of the applicable laws and regulations. Inc.

Suppliers should consult with their own legal counsel to ensure that they are in compliance with the requirements of the applicable laws and regulations.Human Trafficking Statistics Please note that this training does not constitute the providing of legal advice. Navistar® is a registered trademark of . . Inc.

000. Inc.000 industry worldwide Please note that this training does not constitute the providing of legal advice. .Human Trafficking Statistics • 2nd largest criminal industry in the U. Suppliers should consult with their own legal counsel to ensure that they are in compliance with the requirements of the applicable laws and regulations.S.S. behind drug and arms trafficking • 1in 1.565 people in the U. Navistar® is a registered trademark of .000. is trafficked every year • $34.

222-50 • Employees directly engaged in the performance of work on a government contract (any contract entered into from February 17. or – Using forced labor in the performance of the contract. fraud or coercion) of trafficking in persons during the period of performance of the contract. Suppliers should consult with their own legal counsel to ensure that they are in compliance with the requirements of the applicable laws and regulations.e. Navistar® is a registered trademark of . using force. . – Procuring commercial sex acts during the period of performance of the contract.FAR 52. Please note that this training does not constitute the providing of legal advice.. Inc. 2009 on) who have “other than a minimal impact or involvement in contract performance” are prohibited from: – Engaging in severe forms (i.

Suppliers should consult with their own legal counsel to ensure that they are in compliance with the requirements of the applicable laws and regulations. Please note that this training does not constitute the providing of legal advice. – Prohibits failing to pay return transportation costs for certain employees who have finished employment outside that employee’s nation of residence. – Prohibits charging employees recruitment fees. . Navistar® is a registered trademark of . concealing.Proposed Changes to the FAR – Prohibits using misleading or fraudulent recruiting practices. – Prohibits destroying. Inc. confiscating or otherwise denying access to employee identity or immigration documents.

Please note that this training does not constitute the providing of legal advice. Suppliers should consult with their own legal counsel to ensure that they are in compliance with the requirements of the applicable laws and regulations. must provide an employment contract. Inc.Proposed Changes to the FAR • Prohibits providing or arranging housing that fails to meet the host country housing and safety requirements. Navistar® is a registered trademark of . recruitment agreement or similar work document in writing in the employee’s native language and prior to the employee departing from his or her country of origin. and • If required. .

Please note that this training does not constitute the providing of legal advice. Inc. Suppliers should consult with their own legal counsel to ensure that they are in compliance with the requirements of the applicable laws and regulations. • Navistar’s Policy prohibits any violation of FAR 52. Navistar® is a registered trademark of . Executive Order 13627 issued 9/25/2012 and the proposed FAR amendments strengthening protections against trafficking in humans. . • Navistar Defense is committed to working to mitigate the risk of human trafficking and forced labor in all aspects of our business.222-50.Navistar Defense’s Policy • Navistar Defense is opposed to human trafficking and forced labor in any form.

reduction in benefits or termination of employment. . Please note that this training does not constitute the providing of legal advice.Navistar Defense’s Policy • Any violations of the FAR. an employee’s removal from the contract. Navistar® is a registered trademark of . the Executive Order and the proposed FAR amendments and this Policy could result in disciplinary action which may include but are not limited to. Inc. Suppliers should consult with their own legal counsel to ensure that they are in compliance with the requirements of the applicable laws and regulations.

. prior to returning to their country of origin. – Using misleading or fraudulent recruiting practices during the recruitment of employees. and – Failing to provide in writing an employment contract. even those within performed within the US. Inc. recruitment agreement or similar work paper in employee’s native language prior to their departing from their country of origin. confiscating or otherwise denying access to employee identity or immigration documents. • Please note that this training does not constitute the providing of legal advice. will prohibit: – Destroying. Suppliers should consult with their own legal counsel to ensure that they are in compliance with the requirements of the applicable laws and regulations. Navistar® is a registered trademark of .Suppliers’ Obligations • All contracts with the US government. – Failing to pay return transportation costs for certain employees who have finished employment outside that employee’s nation of residence. Furthermore. – Charging employees recruitment fees. and contractors must not prevent or hinder employees from cooperating fully with government authorities. concealing. contractors must protect and interview all employees suspected of being victims of or witnesses to prohibited activities. providing or arranging housing that fails to meet host country housing and safety standards.

. Navistar® is a registered trademark of . detect.Suppliers’ Obligations • For contracts where portion to be performed outside the United States exceeds $500. subcontractors or subcontractor employees that have engaged in such activities. and • Procedures to prevent agents and subcontractors at any tier from engaging in trafficking in persons and to monitor. suppliers must have and post a compliance plan that includes the following (see proposed rules for more detail): • An awareness program. Please note that this training does not constitute the providing of legal advice. and terminate any agents.000 (except for solely COTS contracts). • A recruitment and wage plan. • A housing plan (if applicable). Suppliers should consult with their own legal counsel to ensure that they are in compliance with the requirements of the applicable laws and regulations. • A reporting process for employees. Inc.

Suppliers’ Obligations • Contractor must certify that it has implemented the compliance plan to prevent prohibited activities and monitor. Navistar® is a registered trademark of . (2) if abuses have been found. the contractor or subcontractor has taken the appropriate referral and remediation actions. Inc. subcontractors. after having conducted due diligence. detect. and terminate any subcontract engaging in prohibited activities. . Please note that this training does not constitute the providing of legal advice. or their agents is engaged in any trafficking in persons activities or. Suppliers should consult with their own legal counsel to ensure that they are in compliance with the requirements of the applicable laws and regulations. (1) neither it nor any of its agents. • Contractor must also certify that. to the best of the contractor’s knowledge and belief.

Inc. and including. immediate termination of that supplier’s contract with Navistar Defense. the proposed amendments to the FAR and/or the Executive Order is grounds for Navistar Defense to take any and all appropriate actions up to.FAILURE TO COMPLY Any failure by any supplier to comply with the requirements of the FAR. . Suppliers should consult with their own legal counsel to ensure that they are in compliance with the requirements of the applicable laws and regulations. Please note that this training does not constitute the providing of legal advice. Navistar® is a registered trademark of .

Contact us at: HTlawscompliance@navistar. Inc. .com Navistar® is a registered trademark of .