Combating Trafficking in Persons Policy and Compliance Plan

Policy and Prohibited Activities

Evans General Contractors, LLC (Evans) believes that all individuals must be treated with dignity and respect. By fostering an environment that supports all aspects and dimensions of human rights, we can maintain our commitment to integrity and our core values to promote satisfied and productive employees and enhance the competitiveness of our businesses. We will not tolerate, nor do business with, any individual or company that uses child or forced labor or traffics in persons.

Human trafficking and related activities include harboring, transportation, provision, or obtaining of a person for labor or services, through the use of force, fraud, or coercion for the purpose of subjection to involuntary servitude, peonage, debt bondage, or slavery. Evans strictly prohibits all forms of trafficking and will take all necessary steps to ensure that trafficking does not occur in its business activities. Evans’s employees, managers, officers, and other business partners must adhere to all Evans policies and recruitment standards to combat trafficking in persons and trafficking-related activities.

As such, Evans supports the United States Government’s Policy of Combating Trafficking in Persons outlined in FAR 52.222-50. According to FAR 52.222-50(b), contractors, contractor employees, and their agents are prohibited from:

(1) Engaging in severe forms of trafficking in persons during the period of performance of the contract;
(2) Procuring a commercial sex act during the period of performance of the contract;
(3) Using forced labor in the performance of the contract;
(4) 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;
(5)
- (i) Using misleading or fraudulent practices during the recruitment of employees or offering of employment, such as failing to disclose, in a format and language understood by the employee or potential employee, 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 or potential employee, and, if applicable, the hazardous nature of the work;
- (ii) Using recruiters that do not comply with local labor laws of the country in which the recruiting takes place;
(6) Charging employees or potential employees recruitment fees;
(7)
- (i) Failing to provide return transportation or pay for the cost of return transportation upon the end of employment-
  - a. 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 contract or subcontract (for portions of contracts performed outside the United States); or
  - b. 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 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 performed inside the United States); except that-
- (ii) The requirements of paragraphs (7)(i) of this clause shall not apply to an employee who is-
  - (A) Legally permitted to remain in the country of employment and who chooses to do so; or
  - (B) Exempted by an authorized official of the contracting agency from the requirement to provide return transportation or pay for the cost of return transportation;
- (iii) The requirements of paragraph (7)(i) of this clause are modified for a victim of trafficking in persons who is seeking victim services or legal redress in the country of employment, or for a witness in an enforcement action related to trafficking in persons. The contractor shall provide the return transportation or pay the cost of return transportation in a way that does not obstruct the victim services, legal redress, or witness activity. For example, the contractor shall not only offer return transportation to a witness at a time when the witness is still needed to testify. This paragraph does not apply when the exemptions at paragraph (7)(ii) of this clause apply.
(8) Providing or arranging housing that fails to meet the host country housing and safety standards; or
(9) If required by law or contract, failing to provide an employment contract, recruitment agreement, or other required work document in writing. Such written work document shall be 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. The employee’s work document shall include, but is not limited to, details about work description, wages, prohibition on charging recruitment fees, work location(s), living accommodations and associated costs, time off, roundtrip transportation arrangements, grievance process, and the content of applicable laws and regulations that prohibit trafficking in persons.

Awareness Program

A copy of the Combating Trafficking in Persons Policy and Compliance Plan (Policy) is provided to all Evans employees at the start of their employment, and when they are assigned to work on a Federal Government Contract, to inform them the United States Government’s policy prohibiting trafficking-related activities as detailed in FAR 52-222.50, the activities prohibited, and the actions that will be taken against the employee for violation of FAR 52-222.50 and this Policy. In addition, the Policy is posted on Evans’s Intranet. Evans employees will also receive training regarding this Policy and FAR 52-222.50, and their responsibilities to ensure compliance with the Policy.

Reporting Violations

All Evans employees are expected to report, without fear of retaliation, any employee, supplier, contractor, or other business partners participating in any of human trafficking activities, including but not limited to the prohibited activities listed in this Policy.

If you suspect that anyone that does business for Evans or with Evans, including but not limited to Evans’ employees, vendors, suppliers, subcontractors and other business partners, violates this Policy, or if you believe FAR 52.222-50 has been violated, you must report it immediately to your supervisor, manager, Human Resources or to the Compliance Officer. You may also report violations by contacting the Global Human Trafficking Hotline at 1-844-888-FREE and its email address at help@befree.org.

Disciplinary Actions

Evans employees or agents that violate this policy are subject to disciplinary action including but not limited to removal from working in a Federal Government contract, reduction in benefits, or termination of employment. In addition, if any vendor, subcontractor, supplier or other business partner, violates this Policy, Evans will take prompt and appropriate action, which includes but is not limited to:

Requiring the removal of individuals violating this policy from working on the Federal Government contract or
Terminating the subcontract or contract according to the terms of the agreement between the Evans and the subcontractor, vendor or supplier.

Recruitment and Wage Plan

Evans’ recruitment procedures are managed and implemented by the Human Resources Department. Evans does not charge recruitment fees to candidates or potential candidates and is compliant with all local labor laws, including laws and regulations regarding wages. In addition, the Human Resources Department ensures that, any external recruitment agency that Evans works with (i) provides proper training to its employees; (ii) does not charge recruitment fees to candidate and/or employees or to potential candidates and/or employees; and (iii) ensures compliance with local labor laws, including wages that meet host-country legal requirements or explains any variance.

Members of the Human Resources Department are trained to ensure Evans’s compliance, and the compliance of the external recruitment agencies, with this Policy.

Housing Plan

If Evans will provide or arrange for housing, it will ensure that the housing meets or exceeds host-country and safety standards. Evans currently does not provide or arrange for housing outside of the United States. However, if in the future it becomes a requirement, the Human Resources Department will work, alongside with the employee, the employees’ manager, and Evans’ Compliance Officer, to identify the host-country requirements and safety standards and ensure the housing being arranged meets or exceeds them. Employees in the United States required to relocate arrange their own housing and are provided with a housing allowance according to their position. The housing allowance may be adjusted according to the cost of living of the location the employee will be working at, to ensure a safe and appropriate housing arrangement. For additional information, please see the Employee Handbook.

Monitoring of Agents and Subcontractors

For any Federal Government contract or subcontract, as indicated in FAR 52-222.50, the Evans will notify its subcontractors, regardless of tier, of their obligations to not engage in trafficking in persons, as indicated in FAR 52-222.50 and this Policy. Any subcontractors subject to this Policy will have a reference to FAR 52-222.50 added to their subcontract to ensure an understanding of their obligations. Subcontractors will be required to add the same clause to any subcontracts they issue to perform work on Evans’s Federal Government contract or subcontract.

Subcontractors, regardless of tier, are required to provide Evans with a copy of their policy to prohibit human trafficking. In addition, they are required to report to Evans’ Compliance Officer any violations or suspected violations to FAR 52-222.50.

Evans’ employees will monitor the office and jobsite activities of subcontractors, regardless of tier, to identify potential activities that are in violation of FAR 52-222.50 and this Policy and report them according to the Reporting Violations section of this Policy.