Human Trafficking

Dow Aero, LLC (“Company”) has developed this policy to provide awareness on the types of human trafficking and the repercussions for those violating, not only the Company’s policy, but the laws maintained by the government of the United States of America (“USA”) and other governments worldwide. The Company and all of it’s employees, along with our suppliers and other agents we do business with are expressly prohibited in contributing, aiding, or concealing acts of human trafficking. These acts can include:

  • Engagement of any severe form of trafficking against a person or entity.

  • Providing or engaging in a commercial sex act, in exchange for anything of value.

  • Use of forced labor, through providing or obtaining the labor or services of a person via force, fraud, or coercion and for the purpose of subjecting the person to involuntary servitude, debt bondage, or slavery.

  • Destroying, concealing, confiscating, or otherwise denying access by an employee or entity to view the employee's identity and/or immigration documents, including:

    • Passports, visas, or other licenses, regardless of issuing authority.

  • Using misleading or fraudulent practices during the recruitment of an employee or upon an offer of employment.

    • This can include failing to disclose details of the job in a format and language accessible to the worker and/or providing information that misrepresents the job and work to be performed:

      • Wages and fringe benefits;

      • Location of work;

      • Living conditions;

      • Housing and associated costs (if employer or other authorized agent provided or arranged);

      • Hazardous nature of the work;

      • Any significant cost to be charged to the employee or charging the prospective employee recruitment fees; and

      • Use of recruiters that do not comply with local labor laws of the country in which the recruiting takes place.

  • Failing to provide or pay for returning transportation upon the end of employment.

    • 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 USA Government contract or subcontract (for portions of contracts performed outside the USA); or

    • For an employee who is not a USA national and who was brought into the USA for the purpose of working on a USA 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 USA).

    • These requirements shall not apply if the employee is:

      • Legally permitted to remain in the country of where the work was performed and whom has chosen to remain; or

      • When an authorized official of the contracting agency provides an exemption from this requirement.

  • Victims of trafficking for 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.

  • Provide or arrange housing that fails to meet the host country housing and safety standards; or

  • If required by law or contract, fail 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:

      • 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 of any persons.

Violation of This Policy

Any violation of this policy is an illegal act, as determined by the USA government. Acts of confirmed human trafficking shall be dealt swiftly, and result in serious measures as appropriate to the severity of the violation.

For employees this may include, but is not limited to:

  • Removal from job functions that relate to the government contract;

  • Informal or formal warning;

  • Adjustment in compensation;

  • Change in employment classification and/or status;

  • Suspension;

  • Termination of employment; and/or

  • Notification of law enforcement.

For other organizations or entities this may include, but is not limited to:

  • Suspension of contract;

  • Termination of contract; or

  • Notification of law enforcement.

Contacts

All employees shall report suspicious behavior of potential Human Trafficking violations, regardless of who is involved and without fear of retaliation.

  • In the event a supplier may be violating Human Trafficking laws please notify Quality Assurance immediately.

  • In the event anyone else may be violating Human Trafficking laws please notify Human Resources immediately.

  • You may also report your concerns via the Global Human Trafficking Hotline:

  • Additionally, you may contact the National Human Trafficking Hotline:

Regulatory

This policy has been developed in an effort for the Company to maintain compliance with the laws maintained by the USA government and other governments worldwide. If discrepancies exist between this policy and applicable law, applicable law shall govern and Human Resources personnel shall be notified immediately.

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