Anti-Trafficking Compliance Plan

Background and Purpose

It is the policy of Key Lime International (Keylime) to comply fully with the U.S. Government’s zero-tolerance policy regarding trafficking in persons by government contractors and award recipients, as set out in FAR 52.222-50 Combatting Trafficking in Persons, FAR 52.222-56 Certification Regarding Trafficking in Persons Compliance Plan, and USAID Standard Provision M20 (“Anti-Trafficking Provisions”).

The compliance plan must be appropriate to the size and complexity of the contract or award, and the nature and scope of the activities to be performed, including the number of non-U.S. citizens expected to be employed and the risk that the contract or award will involve services that are susceptible to trafficking in persons.

Keylime has developed this Anti-Trafficking Compliance Plan (”Compliance Plan”) to establish baseline standards for anti-trafficking compliance.

Scope

This Compliance Plan sets out Keylime’s minimum anti-trafficking compliance requirements under the Anti-Trafficking Provisions. The minimum requirements in this Compliance Plan apply to all Keylime projects that are required to maintain written compliance plans. Certain projects that are larger, more complex, or involve a greater risk of trafficking activity may need to implement measures in addition to those set out in this Compliance Plan to ensure that their anti-trafficking compliance plans are appropriate to the size and complexity of the project, and the nature and scope of the activities to be performed. Those additional measures should be documented in a Supplemental Compliance Plan for Higher Risk Projects ("Supplemental Plan").

Activities Prohibited by Keylime’s Policy on Combating Trafficking In Persons

Keylime strictly prohibits its employees, consultants, vendors, contractors, subcontractors, and subrecipients from:

• Engaging in trafficking in persons
• Procuring commercial sex acts
• Using forced labor in the performance of a U.S. government contract or award
• Destroying, concealing, confiscating, or otherwise denying an employee access to identity or immigration documents like passports or drivers' licenses
• Using misleading or fraudulent recruitment practices, such as failing to disclose in a format or language accessible to the employee or materially misrepresenting key terms and conditions of employment, such as wages and benefits, work location, living conditions, housing or associated costs (if provided or arranged by Keylime or by a vendor, contractor, subcontractor, or subrecipient), any significant costs to be charged to the employee, and, if applicable, the hazardous nature of the work
• Working with recruiters that do not comply with local labor laws of the country in which recruiting takes place
• Charging employees recruitment fees
• Failing to provide or pay return transportation costs at the end of employment for certain employees who are not nationals of the country in which the work takes place (subject to certain exclusions and conditions)
• Providing or arranging housing that does not meet the host country housing and safety standards
• If required by law or contract, failing to provide an employment contract, recruitment agreement, or other legally required work document in writing in a language the employee understands containing a detailed description of the terms and conditions of employment, at least five days before an employee relocates to perform work.

Employee Awareness Program

Keylime’s Combating Trafficking in Persons Policy (”Policy”) is posted on its internal Keylime Wiki, where it can be accessed by all Keylime personnel at any time, and incorporated by reference in the Keylime Employee Handbook. The Policy is also reflected in Keylime’s Code of Conduct (the “Code”), which is posted on the Keylime Wiki and can be accessed by all Keylime personnel at any time. A verbal explanation of the contents is given upon request to individuals unable to read the printed information.

Employees were informed of the Policy upon its adoption via a company-wide email that linked to the Policy and instructed them to access, read, and acknowledge it. All new Keylime employees are required to acknowledge that they have familiarized themselves with the Policy and Code upon hire. Onboarding and refresher trainings on ethics policies, including the Combating Trafficking in Persons Policy, are provided as-needed and on an ongoing basis. Finally, Keylime conducts country- and project-specific anti-trafficking training as needed.

Recruitment and Wage Plan

Keylime prohibits the use of any misleading or fraudulent recruitment practices during the recruitment of employees or offering of employment to employees. Keylime personnel must fully and accurately disclose, in a format and language accessible to the employee, all key terms and conditions of employment, including wages and benefits, work location, living conditions, housing and associated costs (where provided or arranged by Keylime), significant costs to be charged to the employee, and, if applicable, the hazardous nature of the work.

Keylime prohibits charging recruitment fees to any employee.

Keylime will pay to all employees wages that meet applicable host-country legal requirements, or will explain any variance.

Where required by law or contract, Keylime will provide to every employee an employment contract, recruitment agreement or other required work document, written in a language the employee understands, containing all required information about the terms of conditions of employment, which may include, by way of example, the work description, wages, work location, living accommodations and associated costs, time off, transportation arrangements, grievance process, the content of applicable laws and regulations prohibiting trafficking in persons, and the prohibition on recruitment fees. If the employee must relocate to perform the work, Keylime will provide the required work document at least five (5) days prior to relocation.

Keylime prohibits destroying, concealing, confiscating, or otherwise denying any employee access to his or her identity or immigration documents.

Keylime will provide or pay the cost of return transportation at the end of employment for any employee who is not a national of the country where the work took place and was brought into that country by Keylime for purposes of working on a covered U.S. Government contract or award.

Keylime will provide or pay the cost of return transportation at the end of employment for any employee who is not a U.S. national and was brought into the U.S. for purposes of working on a covered U.S. Government contract or award, if payment of such costs is required under existing temporary work programs or pursuant to a written agreement with the Worker for portions of contracts and awards performed outside the U.S.

Keylime will only use recruiting firms that have trained employees, comply with all labor laws of the country where the recruitment takes place, and comply with the prohibitions on misleading or fraudulent recruitment practices outlined above.

Housing Plan

In situations where Keylime provides or arranges housing for employees, the housing will at minimum meet host country housing and safety standards.

Supplier Compliance

Keylime requires ALL contractors, consultants, vendors, subcontractors, and subrecipients ("Suppliers") and their employees, consultants, interns, volunteers, and agents ("Supplier Personnel") to:

• Refrain from engaging in prohibited trafficking or trafficking-related activity, or other conduct that violates Keylime's Policy;
• Take steps to prevent trafficking or trafficking-related activity by Supplier Personnel; and
• Cooperate fully with all investigations of trafficking violations and provide truthful information to investigators.

Additional requirements apply to Suppliers with FAR-governed contracts and subcontracts that: (a) are for acquisition of supplies (other than commercially available off-the-shelf items) or performance of services outside the U.S., and (b) have an estimated value that exceeds $500,000. These Suppliers must maintain a written anti-trafficking compliance plan, and must submit pre-award, annual, and any other required certifications to Keylime that:

• The Supplier has implemented a compliance plan and has complied with its plan; and
• After conducting due diligence, to the best of the Supplier’s knowledge and belief, neither it nor any of its employees, or its contractors, consultants, suppliers, subcontractors, subrecipients or their employees, have engaged in any prohibited trafficking-related activities, or, if any abuses relating to prohibited trafficking-related activities have been found, Supplier has taken appropriate remedial and referral actions.

Keylime will include appropriate language reflecting the applicable requirements in Supplier contracts, subcontracts, and subawards.

If any Supplier fails to comply with applicable requirements, Keylime will take appropriate action to remediate the violation and prevent future violations, including, but not limited to:

• Requiring the Supplier to remove an employee or agent from a project
• Requiring the Supplier to terminate its relationship with any Supplier contractor, consultant, supplier, subcontractor or subrecipient
• Suspending payments to Supplier until violation is remedied
• Immediately terminating the Supplier contract, subcontract, or award

Reporting Requirements and Procedure

All Keylime Personnel, Suppliers and Supplier Personnel who observe, suspect, or receive allegations of trafficking-related activity, or any other conduct prohibited by this policy, are required to report the conduct immediately, either orally or in writing, by contacting one of the following:

• Their immediate supervisor, or, if the conduct involves the immediate supervisor, any other supervisor within their department;
• Keylime Director Sarah Steller: sarah@joinkeylime.com
• Keylime’s reporting website either with your name or anonymously

Anonymous reports are generally more difficult to investigate due to limited information. Keylime Personnel are urged to provide as much detailed information as possible about the conduct, including, if possible, identifying people who were involved or who witnessed the conduct, so long as this will not put the persons identified at risk of immediate harm.

Keylime Personnel who are supervisors or hold a position at director level or above are required to promptly, within 24 hours, notify Keylime Director Sarah Steller, of any actual or suspected Trafficking in Persons or other violation of this policy that is reported to them, or that they observe or otherwise become aware of. Failure to do so is a violation of this policy and could lead to disciplinary action, up to and including immediate separation of employment.

Keylime Personnel and Supplier Personnel who believe they or others have been subjected to prohibited trafficking-related activities may report the activity as outlined above, or may contact:

• The Global Human Trafficking Hotline at 1-844-888-FREE or help@befree.org, or
• The National Human Trafficking Hotline
• In the U.S. - 1-888-373-7888 or by texting HELP to 233733 (BEFREE)
• Outside the U.S. - +001-202-745-0190 or by text 202-657-4006

Keylime Director Sarah Steller will initiate an investigation all reports of prohibited trafficking-related activity or violations of this policy, take appropriate action, and make any required notifications to government agencies.

Keylime strictly prohibits retaliation against any Keylime employee who reports prohibited trafficking-related activity or other violations of this Policy, or who cooperates with any internal or government investigations of such reports. Employees may do so without fear of reprisal. Keylime personnel who engage in any form of retaliation against those who report prohibited trafficking-related activities or other violations of this policy are subject to disciplinary action, up to and including termination of employment with Keylime.

Posting

Keylime will post this Compliance Plan and all Supplemental Plans on the Keylime Wiki and on its external website, https://joinkeylime.com. Hard copies of this Compliance Plan will be posted at all Keylime workplaces worldwide. Each project with a Supplemental Plan will post a hard copy of the Supplemental Plan at all project workplaces, except where the project's work is being performed in the field or not otherwise at a fixed location.

Revised March 1, 2024