COMBATTING TRAFFICKING IN PERSONS
DUE DILIGENCE QUESTIONNAIRE
INTRODUCTION
As a U.S. Government Contractor, IAP Worldwide Services, Inc. and its subsidiaries (“IAP”), its subcontractors,
and their subcontractors are subject to U.S. Government anti-human trafficking rules. In this procurement, the
following rules apply to IAP, your company, your employees, and your subcontractors, both while at work and
outside of work.
FAR 52.222-50 - Combating Trafficking in Persons
FAR 52.222-56 - Certification Regarding Trafficking in Persons Compliance Plan
In certain cases, the following additional clauses may apply:
DFARS 252.222-7007 - Representation Regarding Combating Trafficking in Persons
DFARS 22.225-7995 (Deviation 2015-00009) (Jan 2015) - Contractor Personnel Performing in the
United States Central Command Area of Responsibility
DFARS 5152.222-5900 (Mar 2014) - Prohibition Against Human Trafficking, Inhumane Living
Conditions and Withholding of Employee Passports
Included in these rules is a responsibility of your company, your employees, and your subcontractors to report
trafficking in persons violations. You must communicate this responsibility to your employees and your
subcontractors. All employees and subcontractors who report to you are protected under U.S. law from
reprisal for whistleblowing on trafficking in persons violations. You should also communicate this protection to
your employees and subcontractors.
QUESTIONNAIRE
1. Use of Subcontractors
1a. Will you use subcontractors to perform the work under this contract?
1b. If yes, provide full name and contact information for any subcontractors.
Name:
Email:
Phone
Address:
2. Employee Documentation
2a. Do you have a policy that prohibits 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 the issuing authority?
Yes
No
Yes
No
Yes
No
Yes
No
3b. Is a copy of the employment agreement, signed by the subcontractor and employee, provided
to the employee?
3c. Will the job performance be considered hazardous?
Yes
No
Yes
No
3d. Are the agreements in a language that the employee understands?
Yes
No
Yes
No
Yes
No
2b. Please confirm that your company shall only hold employee passports and other identification
documents for the shortest period of time reasonable for administrative processing purposes.
3. Employment Agreements
3a. Do you and your subcontractors provide employees with written employment agreements,
recruitment agreements, or other required work documents in writing?
Note: All employees must be provided with a signed copy of their employment contract in English
and the employee’s native language or a language that the employee understands, that define the
terms of their employment and compensation.
3e. If the employee must relocate to perform the work, is the work document provided to the
employee at least five (5) days prior to the employee relocating?
3f. Do the employment agreements include details about work descriptions, wages, prohibition on
charging recruitment fees, work location(s), living accommodations and associated costs, time off,
roundtrip transportation arrangements, grievance process, and the contents of applicable laws and
regulations that prohibit trafficking in persons?
Form # 1950-02
Page 1 of 4
25 Sep 15
This material contains proprietary information of IAP Worldwide Services, Inc. (IAP). Disclosure to others, use, or copying without the express written
authorization of IAP is strictly prohibited. Any authorized copying of this material, in whole or in part, must include this legend.
COMBATTING TRAFFICKING IN PERSONS
DUE DILIGENCE QUESTIONNAIRE
4. Housing
4a. Will the subcontractor employees be provided with housing that meets the host country
standards, including safety standards?
4b. Will the employee living space be at least 50 square feet per person?
Yes
No
Yes
No
Will the employee be charged for housing and food service?
Yes
No
5. Recruitment
5a.
Do you and your subcontractor use recruiters to obtain workers?
Yes
No
5a(i)
If yes, are the recruiters licensed in the country in which they will be recruiting?
Subcontractor, and its subcontractors, shall not utilize unlicensed recruiting firms.
Yes
No
5a(ii) If yes, do the recruiters comply with the local labor laws of the country in which the recruiting
takes place?
5b. Are your employees and/or the employees of your subcontractors charged recruitment fees?
Recruitment fees are prohibited.
5c. Do you and your subcontractors and agents, have policies that prohibit the use of misleading or
fraudulent 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 cost to be charged
to the employee, and, if applicable, the hazardous nature of the work?
Yes
No
Yes
No
Yes
No
Yes
No
Yes
No
Yes
No
4c.
6. Compliance Plan
6a. Do you and your subcontractors have a Trafficking in Persons compliance plan or awareness
program?
Please provide copies of such compliance plans. Note that these compliance plans shall be
provided to the Contracting Officer upon request.
6b.
Do the compliance plans provide the following at a minimum:
 Make employees and subcontractors aware of the Human Trafficking rules and
requirements;

Provide a process for employees to report, without fear of retaliation, including a
means to make available to all employees and subcontractors a worry free hotline
reporting mechanism and/or the hotline phone number of the Global Human
Trafficking Hotline at 1-844-888-FREE and its email address at help@befree.org;

A recruitment and wage plan that only permits the use of recruitment companies with
trained employees, prohibits charging recruitment fees to the employee, and ensures
that wages meet applicable host-country legal requirements or explains any variance;

A housing plan, if you or your subcontractors intend to provide or arrange housing,
that ensures that the housing meets host-country housing and safety standards;

Procedures to prevent your company, your subcontractors, and agents at any tier and
any dollar value from engaging in trafficking in persons and to monitor, detect, and
terminate any employees, agents, subcontracts, or subcontractor employees who
have engaged in such activities; and

Prohibit the use of forced labor in the performance of the subcontract?
6c. Do you and your subcontractors post the relevant contents of the compliance plan, no later
than the initiation of contract performance, at the workplace (unless the work is performed in the
Form # 1950-02
Page 2 of 4
25 Sep 15
This material contains proprietary information of IAP Worldwide Services, Inc. (IAP). Disclosure to others, use, or copying without the express written
authorization of IAP is strictly prohibited. Any authorized copying of this material, in whole or in part, must include this legend.
COMBATTING TRAFFICKING IN PERSONS
DUE DILIGENCE QUESTIONNAIRE
field, not in a fixed location, or at the offices of the local government) and on your and your
subcontractors’ web sites.
6c(i) If this is impracticable, do you and your subcontractors provide the relevant contents of the
compliance plan to each worker in writing?
Yes
No
Yes
No
Yes
No
Yes
No
Yes
No
7. Return Travel Costs
7a.
Do you and your subcontractors pay the return travel costs to the country of origin upon the
end of employment for employees who are not nationals of the country in which the work is taking
place and who were brought into that country for the purpose of working on a US Government
contract or subcontract?
7b.
Do you and your subcontractors provide 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 a witness in an enforcement action related to trafficking in persons?
7c.
Do you and your subcontractors pay for the return travel costs even if the employee is
terminated (including for cause) or wants to leave before one year of employment?
8. Commercial Sex Acts
8a.
Do you have a policy that prohibits employees from procuring commercial sex acts during
the term of the performance of the subcontract?
ACKNOWLEDGEMENT and AGREEMENT
The Subcontractor acknowledges and agrees that it will comply with U.S. and local laws and regulations regarding
transit/exit/entry procedures and the requirements for visas and work permits, and not engage in the illegal trafficking of
persons.
The Subcontractor acknowledges and agrees that it:
a) has been notified of the human trafficking rules that apply to this U.S. Government contract, that it will notify
its employees and subcontractors of such human trafficking rules, that the Contractor and Subcontractor may
be required to take appropriate action, up to and including termination against employees, agents, or
subcontractors that violate the policy.
b) has been informed that the Contractor is required to inform the Contracting Officer and the agency Inspector
General immediately of:
i. any credible information it receives from any source (including local law enforcement) that alleges a
subcontractor or subcontractor employee or their agent has engaged in conduct that violates the policy;
and
ii. any actions taken against a subcontractor, subcontractor employee, or their agent with respect to a
contractor informing the Contracting Officer and agency Inspector General of conduct that violates the
policy,
c) has been informed, and it shall inform its subcontractors, that failure to comply with the human trafficking
rules may result in:
i. Termination of the subcontract;
ii. Suspension of subcontract payments until the subcontractor has taken appropriate remedial action;
iii. Declining to exercise available option periods under the contract; and
iv. Suspension or debarment by the U.S. Government
d) shall, and it shall require, its subcontractors to:
i. provide timely and complete responses to Contractor and/or U.S. Government auditors’ and investigators’
requests for documents;
ii. cooperate fully in providing reasonable access to its facilities and staff to allow Contractor and/or the U.S.
Government to conduct audits, investigations, or other actions to ascertain compliance;
iii.
protect all employees suspected of being victims of or witnesses to prohibited activities.
Form # 1950-02
Page 3 of 4
25 Sep 15
This material contains proprietary information of IAP Worldwide Services, Inc. (IAP). Disclosure to others, use, or copying without the express written
authorization of IAP is strictly prohibited. Any authorized copying of this material, in whole or in part, must include this legend.
COMBATTING TRAFFICKING IN PERSONS
DUE DILIGENCE QUESTIONNAIRE
CERTIFICATION
As of the date of this questionnaire, Subcontractor certifies that:
a)
b)
c)
d)
e)
f)
it will flow down to its subcontractors contract clauses that confirm that they will not engage in the illegal
trafficking of persons;
it and its employees will not procure commercial sex acts during the period of performance of the
contract;
neither it nor its subcontractors will use forced labor in performance of its services;
it has implemented a compliance program to prevent any prohibited activities and to monitor, detect, and
terminate any agent, subcontract, or subcontractor employee engaging in prohibited activities; and
after having conducted due diligence, either:
i. 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
ii. if abuses relating to any of the prohibited activities identified have been found, it or its
subcontractor has taken the appropriate remedial and referral actions
Subcontractor agrees to make such certification annually after award of the subcontract.
_____________________________
Name
Title
Company name
_____________
Date
Form # 1950-02
Page 4 of 4
25 Sep 15
This material contains proprietary information of IAP Worldwide Services, Inc. (IAP). Disclosure to others, use, or copying without the express written
authorization of IAP is strictly prohibited. Any authorized copying of this material, in whole or in part, must include this legend.