Combating Trafficking in Persons (CTIP) Compliance Plan

1.0 Executive Summary

Continuity Global Solutions (CGS) is committed to conducting business ethically and in full compliance with all applicable U.S. laws, regulations, contractual requirements, and internationally recognized human rights standards. CGS maintains a zero-tolerance policy regarding trafficking in persons, forced labor, involuntary servitude, debt bondage, commercial sex acts, and all other forms of human exploitation. Every employee, manager, subcontractor, joint venture partner, supplier, and agent acting on behalf of CGS shares the responsibility to prevent, detect, report, and eliminate trafficking in persons in connection with the performance of U.S. Government contracts.

This Combating Trafficking in Persons (CTIP) Compliance Plan is established in accordance with FAR Subpart 22.17, FAR 52.222-50, Combating Trafficking in Persons, Executive Order 13627, Strengthening Protections Against Trafficking in Persons in Federal Contracts, the Trafficking Victims Protection Act of 2000 (TVPA), as amended (22 U.S.C. Chapter 78), and other applicable federal statutes and regulations. Where incorporated into a specific contract, CGS shall also comply with any applicable Defense Federal Acquisition Regulation Supplement (DFARS) trafficking-in-persons requirements.

This compliance plan satisfies the requirements of FAR 52.222-50(h) for contracts performed outside the United States that exceed the applicable monetary threshold and require a contractor compliance plan. The Plan establishes the policies, procedures, internal controls, and management oversight necessary to prevent prohibited trafficking-related activities; educates employees and subcontractors; provides confidential reporting mechanisms; investigates allegations; implements corrective actions; monitors compliance; and ensures timely reporting to the U.S. Government when required.

CGS recruits and employs personnel through ethical and transparent employment practices that comply with applicable host-country labor laws and contractual requirements. The company prohibits charging employees recruitment fees, confiscating identity or immigration documents, engaging in fraudulent recruitment practices, or using coercion, intimidation, or other unlawful practices to obtain or retain employment. CGS also requires subcontractors, suppliers, joint venture partners, and agents to comply with these same standards through contractual flow-down requirements, annual certifications, and periodic compliance reviews.

Executive Management has designated the Senior Vice President of Operations as the Corporate CTIP Compliance Officer responsible for overseeing implementation of this compliance plan, ensuring annual employee training, conducting compliance monitoring and internal audits, overseeing investigations, coordinating government notifications, maintaining required records, and continuously improving the company’s CTIP program.

CGS is committed to fostering a culture of integrity, accountability, transparency, and respect for human rights. Through comprehensive training, effective internal controls, due diligence, continuous monitoring, and strong executive oversight, CGS will maintain full compliance with applicable Federal Acquisition Regulations and contractual requirements while supporting the United States Government’s zero-tolerance policy on trafficking in persons.

For additional information regarding trafficking in persons, employees may consult the U.S. Department of State Office to Monitor and Combat Trafficking in Persons at

https://www.state.gov/trafficking-in-persons-report/ or contact the National Human Trafficking Hotline at 1-888-373-7888 or https://humantraffickinghotline.org

This compliance plan is implemented pursuant to FAR 52.222-50(h) and satisfies the compliance plan requirements applicable to contracts performed outside the United States exceeding $550,000 for supplies (other than commercially available off-the-shelf items) or services.

2.0 Awareness Program and CGS Policy

Pursuant to the FARs FAR 52.222-50 Combating Trafficking in Persons, it is U.S. Government and CGS policy that contractors, contractor employees, our agents, subcontractors and subcontractor employees are prohibited from:

  • Engaging in severe forms (i.e., using force, fraud or coercion) of trafficking in persons during the period of performance of a contract.
  • Procuring commercial sex acts during the period of performance of a contract.
  • Using forced labor in the performance of a contract.
  • Destroying, concealing, confiscating, or otherwise denying access by an employee to the 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, 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 costs to be charged to the employee, and, if applicable, the hazardous nature of the work.
  • Using recruiters that do not comply with the local labor laws of the country in which the recruiting takes place.
  • Charging employees recruitment fees.
  • Failing to provide return transportation or pay for the cost of return transportation upon the end of employment, for an employee who was not a national of the country in which the work is taking place and who was brought into that country for the purposes of working on a U.S. Government contract, subcontract or portion(s) of contracts or subcontracts performed outside the United States.
  • Failing to provide return transportation or pay for the costs of return transportation upon the end of employment, for an employee who is not a U.S. national and who was brought into the U.S. for the purpose of working on a U.S. Government contract or subcontract, if the payment of such costs is required under existing temporary worker programs or pursuant to a written agreement with the employee for portions of contracts and subcontracts performed inside the United States.
  • Providing or arranging housing that fails to meet the host country’s housing and safety standards.
  • If required by law or contract, failing to provide an employment contract, recruitment agreement or other required work document in writing in a language the employee understands. If the employee must relocate to perform the work, the work document shall be provided to the employee at least five days prior to the employee relocating.

Any violation of the FARs, the DFARS, the Executive Order and/or the CGS CTIP policy could result in disciplinary action which may include but is not limited to, an employee’s removal from a contract, reduction in benefits, or termination of employment.

3.0 Employees

On an annual basis, CGS requires all employees to complete compliance training (online or in-person) and to certify that they have read, are aware of, understand, and agree to comply with the policies, procedures and principles of the CGS CTIP Policy and report any violations of which they are aware. The CGS CTIP Policy is publicly posted on the CGS website:

CGS conducts compliance training approximately annually and as needed throughout the year. Additionally, CGS provides a CTIP Quick Reference Guide to all employees.

Signed copies of all acknowledgement forms and training records are retained for contract duration, plus retention period.

4.0 Subcontractors/Suppliers

Applicable FAR and DFARS clauses such as FAR 52.222-50, Executive Order 13627 and applicable host nation laws are flowed down to our subcontractors. Subcontractors shall be provided with the CGS CTIP policy and asked to certify that they have read and understand the policy.

5.0 Questions

Questions regarding CGS policy and actions to combat trafficking in person may be directed to any CGS manager or supervisory personnel.

6.0 Reporting Process

CGS is committed to maintaining a workplace in which employees, subcontractors, joint venture partners, and agents can report suspected violations of the CTIP policy without fear of intimidation, reprisal, or retaliation.

Any employee who has credible information regarding an actual, suspected, or potential violation of this Compliance Plan, FAR 52.222-50, Combating Trafficking in Persons, applicable laws, or the

The CGS CTIP policy shall immediately report the information through one or more of the reporting channels identified below. Failure to report known or suspected trafficking-related violations or other prohibited activities may result in disciplinary action, up to and including removal from the contract and termination of employment consistent with applicable labor laws.

Internal Reporting

Employees are encouraged to report concerns promptly to any of the following:

  • Immediate Supervisor
  • Project Manager
  • Human Resources Manager
  • Corporate CTIP Compliance Officer (Senior Vice President of Operations)
  • Corporate, Director of Human Resource
  • Any member of CGS Executive Management

Employees may also submit reports anonymously were permitted by applicable law.

Non-Retaliation

CGS strictly prohibits retaliation against any individual who, in good faith:

  • Report a suspected violation of this Compliance Plan;
  • Participate in an investigation;
  • Cooperate with Government officials or law enforcement; or
  • Refuse to participate in conduct are believed to violate applicable laws or regulations.

Any act of retaliation itself will constitute a violation of this policy and may result in disciplinary action up to and including termination of employment or subcontract.

Government Reporting

In accordance with FAR 52.222-50(d), if CGS receives credible information that an employee, subcontractor, subcontractor employee, agent, or joint venture partner has engaged in conduct prohibited by FAR 52.222-50, CGS shall immediately notify the contracting officer and the appropriate agency inspector general and cooperate fully with any government investigation.

Investigation Process

Upon receipt of a report, CGS shall:

  1. Document the allegation.
  2. Conduct a preliminary assessment.
  3. Initiate a formal investigation, when warranted.
  4. Protect affected individuals from retaliation.
  5. Implement appropriate corrective actions.
  6. Notify the Government when required by contract or regulation.
  7. Maintain investigation records in accordance with the CGS records retention policy.

Questions and Guidance

Employees who are uncertain whether a particular action may violate this Compliance Plan or applicable Federal regulations are encouraged to seek guidance from their supervisor, Human Resources, the Project Manager, or the Corporate CTIP Compliance Officer before taking action.

External Reporting Resources

Employees may also report suspected trafficking-related violations directly through Government reporting channels, including:

Nothing in this policy limits an individual’s right to report suspected violations directly to the U.S. Government or other appropriate authorities

7.0 Recruitment and Wage Plan

Continuity Global Solutions (CGS), including its joint venture (JV) partners, do not utilize third-party recruitment agencies, labor brokers, or labor providers to recruit personnel for performance under this contract. All employees are recruited, screened, interviewed, hired, and managed directly by CGS or its authorized JV partner in accordance with applicable host-country labor laws, contractual requirements, and the CGS Combating Trafficking in Persons (CTIP) policy. CGS is committed to ethical recruitment and employment practices and strictly prohibits any activity that could contribute to trafficking in persons, forced labor, debt bondage, or involuntary servitude. All recruitment and hiring activities shall comply with FAR 52.222-50, applicable host-country labor laws, and the CGS CTIP Policy.

CGS shall ensure that:

  • No applicant or employee is charged recruitment, placement, hiring, or employment fees as a condition of employment.
  • All employment opportunities are advertised and filled through fair, transparent, and non-discriminatory hiring practices.
  • Applicants receive accurate information regarding the position, duties, work location, wages, benefits, work schedule, and conditions of employment before accepting an offer of employment.
  • Where required by applicable law or contract, employees receive a written employment agreement in a language they understand prior to commencing employment.
  • Employee wages, overtime, and benefits comply with all applicable host-country labor laws, and approved compensation plans.
  • Employees are paid accurately and on time in accordance with established payroll procedures.
  • No unauthorized deductions are made from employee wages.
  • Employees retain unrestricted possession and control of their passports, national identification cards, driver’s licenses, or any other personal identity or immigration documents.

Employees are free to terminate their employment in accordance with applicable labor laws and the terms of their employment agreement without coercion, intimidation, or retaliation. CGS supervisors, managers, and human resources personnel receive training on ethical hiring practices and the requirements of the CGS CTIP policy to ensure all employment activities are conducted in a lawful and ethical manner.

As part of its annual CTIP Compliance Program, CGS will review recruitment records, personnel files, payroll records, and employment practices to verify continued compliance with this policy and identify opportunities for continuous improvement. Should CGS determine that future contract requirements necessitate the use of a third-party recruitment agency or labor provider, CGS will conduct appropriate due diligence prior to engagement and require the recruiter to comply fully with FAR 52.222-50, applicable labor laws, and the CGS CTIP policy. Such recruiters would be prohibited from charging recruitment fees, using deceptive recruitment practices, or engaging in any activity prohibited by Federal law or this policy.

8.0 Housing Plan

Continuity Global Solutions (CGS), including its joint venture (JV) partners, does not provide, arrange, subsidize, or require employee housing unless required by the contract. All local national personnel employed in performance of any contract are host country local nationals who are responsible for obtaining and maintaining their own housing and transportation. Accordingly, the housing requirements contained in FAR 52.222-50(h)(3), Combating Trafficking in Persons, pertaining to contractor-provided or contractor-arranged housing, are not applicable. CGS prohibits coercive housing practices, mandatory housing, wage deductions for employer-selected housing, and investigates any allegation involving housing-related exploitation. Should future contracts require employer-provided housing, CGS will implement a compliant Housing Management Program before occupancy.

9.0 Procedures to Prevent Agents and Subcontractors from Engaging in Trafficking in Persons and to Monitor, Detect and Terminate

9.1 Agents and Subcontractors

All agents and subcontractors, as a part of the CGS set-up process to allow payments, are screened against US Government and international denied and debarred party watchlists.

Not less than annually, CGS will require each of its subcontractors to certify:

  1. Its policies and practices prohibit engaging in the trafficking of persons, the use of forced labor, or the procuring of commercial sex acts in the country or countries in which it conducts business; and
  2. If applicable, it has implemented a compliance plan to prevent any prohibited activities identified at FAR 52.222-50 (b) and to monitor, detect, and terminate any agent, subcontract or subcontractor employee engaging in prohibited activities; and
  3. After having conducted due diligence, either
    1. to the best of its knowledge and belief, neither it nor any of its agents, subcontractors, or their agents is engaged in any such activities; or
    2. if abuses relating to any of the prohibited activities identified in FAR 52.222-50(b) have been found, the subcontractor has taken the appropriate remedial and referral actions.
  4. Has reviewed and understands the CGS CTIP policy as referenced herein.

As required by the FARs, CGS shall flow down all applicable clauses to its subcontractors and agents. Failure to comply with the requirements of the FARs is grounds for CGS to take any and all appropriate action, up to and including immediate termination of that subcontractor’s or agent’s contract with CGS.

Prior to contract award, if applicable CGS will evaluate each subcontractor for:

  • Labor violations
  • Suspension/Debarment
  • SAM Registration
  • Foreign Labor Practices
  • Previous Contract Performance
  • Recruitment methods
  • Labor Brokers utilized

9.2 Suppliers

CGS has made written information on combating human trafficking available to its suppliers. In addition, CGS training for internal personnel includes information on recognizing the signs of human trafficking and the appropriate action to take if human trafficking is suspected and monitors suppliers whenever possible while on supplier premises.

10.0 Notification

CGS shall immediately inform the Contracting Officer and the agency Inspector General upon receipt of credible information alleging a violation of FAR 52.222-50; and any actions taken against a CGS employee, subcontractor, subcontractor employee, or their agent pursuant to FAR 52.222-50. As described above, employees may, in good faith, report, (without fear of retaliation and with employee protection, as implemented in DFARS subpart 203.9), any activity that violates the FARs, the DFARS, the Executive Order or CGS CTIP policy to their management or to the Global Human Trafficking Hotline or at help@befree.org. Anyone else, including subcontractors, agents, and contingent workers, may also use the hotlines or websites to report any issues relating to human trafficking.

11.0 Posting

CGS CTIP Compliance Plan and Policy shall be posted at the CGS office and on CGS intranet website. CGS shall provide its compliance plan to the contracting officer upon request. A copy of the CGS policy will also be posted in the breakrooms and training rooms and provided during new employee orientation.

12.0 Certifications

Annually after receiving an award, CGS will provide certifications to the contracting officer as required by the FAR 52.222-50 Combating Trafficking in Persons. Annually after receiving an award, CGS will submit a certification to the Contracting Officer that:

a. CGS has implemented a compliance plan to prevent any prohibited activities identified in paragraph 2 above and to monitor, detect and terminate any agent, subcontract or subcontractor employee engaging in prohibited activities: and

b. After having conducted due diligence, either-

  1. To the best of the contractor’s knowledge and belief, neither it nor its agents, subcontractors, or their agents is engaged in any such activities; or
  2. if abuses relating to any of the prohibited activities identified in FAR 52.222- 50(b) have been found, the contractor has taken the appropriate remedial and referral actions.

13.0 Compliance Monitoring and Audits

CGS is committed to maintaining an effective and proactive Combating Trafficking in Persons (CTIP) compliance program through continuous monitoring, periodic assessments, and internal audits. The Corporate CTIP Compliance Officer, in coordination with human resources, project management, and executive management shall conduct periodic reviews of the company’s policies, procedures, and operational practices to verify compliance with FAR 52.222-50, Executive Order 13627, applicable host-country labor laws, and the CGS CTIP policy. These reviews shall include, as appropriate, examinations of recruitment and hiring records, employee personnel files, payroll records, employment agreements, training records, subcontractor certifications, supplier due diligence documentation, and any contractor-provided housing where applicable.

CGS shall also periodically evaluate subcontractors, joint venture partners, agents, and suppliers to ensure continued compliance with all contractual and regulatory CTIP requirements. Compliance monitoring may include site visits, interviews with employees, management discussions, document reviews, and assessments of recruitment and employment practices. The Company will verify that employees maintain possession of their personal identity documents, that no prohibited recruitment fees or unauthorized payroll deductions have been imposed, and wages and benefits are paid in accordance with applicable host nation labor laws.

Any deficiencies, nonconformities, or indicators of potential trafficking-related activities identified during monitoring activities shall be documented, investigated, and addressed through the CGS corrective action process. Audit results shall be reported to executive management, and appropriate corrective and preventive measures shall be implemented to ensure continued compliance. Records of all compliance monitoring activities, audits, investigations, and corrective actions shall be maintained in accordance with the CGS records retention policy and made available to the U.S. Government upon request, as permitted by law and contract.

14.0 Corrective Actions

CGS maintains a zero-tolerance policy toward trafficking in persons and is committed to taking immediate and appropriate corrective action whenever a violation of this Compliance Plan, FAR 52.222-50, applicable labor laws, or the CGS CTIP policy is identified or reasonably suspected. Upon receipt of credible information regarding a potential violation, CGS shall promptly document the allegation, conduct an initial assessment, and initiate a formal investigation when warranted. Investigations shall be conducted in a timely, impartial, and confidential manner to the maximum extent practicable while protecting the rights of all individuals involved and safeguarding employees from retaliation for making good-faith reports.

When an investigation substantiates a violation, CGS shall implement corrective actions appropriate to the nature and severity of the misconduct. Such actions may include employee counseling, mandatory retraining, disciplinary action up to and including termination of employment, removal of personnel from government contracts, termination of subcontractors or agents, reimbursement of improperly charged recruitment fees or other prohibited costs, notification to the contracting officer and the appropriate agency inspector general when required by FAR 52.222-50, and full cooperation with any government investigation. Corrective actions should also include iden

root cause of the violation and implementing preventive measures designed to reduce the likelihood of recurrence. Following completion of each investigation, the Corporate CTIP Compliance Officer shall review the effectiveness of the corrective actions implemented and determine whether additional policy revisions, enhanced training, increased monitoring, or other compliance improvements are necessary. Lessons learned from investigations, internal audits, Government reviews, and industry best practices shall be incorporated into the CGS CTIP Compliance Program to promote continuous improvement and ensure ongoing compliance with all applicable Federal Acquisition Regulations, Executive Orders, contractual requirements, and ethical business practices. CGS executive management shall periodically review the overall effectiveness of the CTIP Compliance Program and allocate appropriate resources to maintain a culture of integrity, accountability, and respect for human rights throughout all Company operations.

15.0 Compliance Officer Responsibilities

The Compliance Officer is responsible for the following:

  • Oversight of the CTIP Program
  • Oversight of investigations
  • Ensuring annual CTIP Training is completed
  • Subcontractor oversight
  • Policy Updates
  • Executive Reporting

16.0 Records Retention

CGS will retain all documents listed below for the period required by the contract and applicable FAR record retention requirements.

  • Training records
  • Employee acknowledgment forms
  • Investigations
  • Corrective Action Plans
  • Subcontractor certifications (if applicable)
  • Audit Reports

Prior to awarding a subcontract annually during performance of the contract, CGS shall obtain from each subcontractor a certification as required by FAR 52.222-50 Combating Trafficking in Persons.