Combating Trafficking in Persons Policy & Compliance Plan

NovAtel Inc. (“NovAtel”), a part of Hexagon’s Autonomy & Positioning division, does not tolerate forced or involuntary labour in any form. Further, as a supplier of goods and services to the US government, NovAtel has developed and maintains this compliance policy and plan for combating trafficking in persons in accordance with US Federal Acquisition Regulation 52.222-50 (“FAR 52.222-50”). Together with Hexagon’s Code of Business Conduct and Ethics (“Code”), this Plan is intended to address NovAtel’s obligations in contracts and subcontracts for the supply of goods and/or services to the US government that incorporate FAR 52.222-50 and require a compliance plan (“Contracts”).

Combating Trafficking in Persons Policy

The US government has adopted a policy, documented in FAR 52.222-50, prohibiting trafficking in persons including trafficking-related activities set forth below (“Policy”). NovAtel complies, and requires its employees, directors, officers, independent contractors and other individuals performing services on NovAtel’s behalf (for ease of reference throughout this Plan referred to as “personnel”) to comply, with the Policy.

Prohibited Conduct

Specifically, personnel shall not:

(1) Engage in severe forms of trafficking in persons during the period of performance of any Contract;

(2) Procure commercial sex acts during the period of performance of any Contract;

(3) Use forced labour in the performance of any Contract;

(4) Destroy, conceal, confiscate, or otherwise deny access by an employee who is directly engaged in the performance of work under a Contract and who has other than a minimal impact or involvement in the performance of a Contract (“Employee”) to the Employee’s identity or immigration documents, such as passports or drivers' licenses, regardless of issuing authority;

(5) (i) Use misleading or fraudulent practices during the recruitment of or offering of employment to Employees, such as failing to disclose basic information, in a format and language understood by the Employee or potential Employee, 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 provided or arranged by NovAtel or its personnel), any significant costs to be charged to the Employee or potential Employee, and, if applicable, the hazardous nature of the work;

(ii) Use recruiters that do not comply with local labour laws of the country in which the recruiting takes place;

(6) Charge Employees or potential Employees recruitment fees;

(7) (i) Fail 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 Contract (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 Contract, 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) Paragraph (7)(i) above won’t apply to an Employee who is: (A) legally permitted to remain in the country of employment and 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) 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, NovAtel 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, NovAtel shall not only offer return transportation to a witness at a time when the witness is still needed to testify. This paragraph (iii) does not apply when the exemptions in paragraph (7)(ii) apply.

(8) Provide or arrange housing that fails to meet the host country housing and safety standards; or

(9) 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, 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.

Violations

NovAtel will take appropriate action, up to and including termination, against personnel that violate the Policy.

Reporting

All Employees are required to report any activity inconsistent with this Policy, with the assurance that there will be no retaliation or other negative consequences for persons acting in good faith.  Any credible information received from any source that any NovAtel personnel has violated FAR 52.222-50 must be reported immediately to:

Cecille Martin
Director, Legal and Compliance
Divisional Compliance Officer
Hexagon Autonomy & Positioning
Phone: +1.309.291.0966 x 134
Mobile: +1.773.490.8827
legal.ap@hexagon.com

 Alternatively, Employees may also report a violation as set forth in the Code or by contacting one of the following hotlines:

• The hotline phone number of the Global Human Trafficking Hotline at 1-844-888-FREE and its email address at help@befree.org.
• The Canadian Human Trafficking Hotline at 1-833-900-1010 and its email address hotline@ccteht.ca.
• The US National Human Trafficking Hotline at 1-888-373-7888 or text 233733.

Combating Trafficking in Persons Compliance Plan

Awareness

NovAtel will inform Employees about the Policy, including prohibited conduct, consequences of violations, and mechanisms to report suspected violations by posting relevant contents of this Plan, no later than the initiation of Contract performance, at its workplace, on its website, and/or on an internal Sharepoint site. Additional information about Trafficking in Persons and examples of awareness programs can be found at the website for the US Department of State’s Office to Monitor and Combat Trafficking in Persons at https://www.state.gov/bureaus-offices/under-secretary-for-civilian-security-democracy-and-human-rights/office-to-monitor-and-combat-trafficking-in-persons/, and Public Safety Canada at https://www.publicsafety.gc.ca/cnt/cntrng-crm/hmn-trffckng/index-en.aspx. NovAtel will provide a copy of this Plan to an applicable contracting officer upon request.

Reporting

All Employees are required to report any activity inconsistent with this Policy, with the assurance that there will be no retaliation or other negative consequences for persons acting in good faith.  Any credible information received from any source that any NovAtel personnel has violated FAR 52.222-50 must be reported immediately to NovAtel’s Director, Legal and Compliance, or alternatively by contacting one of the following hotlines: 

• The hotline phone number of the Global Human Trafficking Hotline at 1-844-888-FREE and its email address at help@befree.org.
• The Canadian Human Trafficking Hotline at 1-833-900-1010 and its email address hotline@ccteht.ca.
• The US National Human Trafficking Hotline at 1-888-373-7888 or text 233733.

If the Director of Legal and Compliance anticipates that the event may require reporting under FAR 52.222-50, he or she shall immediately notify Hexagon’s Assistant Chief Compliance Officer and undertake steps to ensure NovAtel’s compliance with its reporting obligations under FAR 52.222-50.

If a violation of FAR 52.222-50 is substantiated, the following actions shall be taken in consultation with the Director of Legal and Compliance:

• Violations by NovAtel employees: NovAtel’s management, in conjunction with Human Resources, will ensure that the appropriate disciplinary action is taken up to and including dismissal or termination.  The appropriate discipline depends on the nature of the violation and the circumstances surrounding the violation, among others.
• Violations by contractors or other third parties: NovAtel management will impose suitable remedies, up to and including termination, on subcontractors, agents, and external recruitment agencies who fail to comply with FAR 52.222-50.

NovAtel will inform Employees about the process to report activity inconsistent with the Policy as described in the “Awareness” section of this Plan.

Recruitment and Wage Plan

To the extent NovAtel uses recruitment companies, it will use only recruitment companies with trained employees;  it will prohibit charging recruitment fees to the Employees or potential Employees; and, it will ensure that all wages meet applicable legal requirements.

Housing Plan

Whenever NovAtel will provide or arrange housing, NovAtel will ensure that the housing meets applicable housing and safety standards.

Supplier and Subcontractor Compliance

Hexagon’s Autonomy & Positioning division of which NovAtel is a part has implemented Hexagon’s Supplier Code of Conduct which requires its suppliers and subcontractors to comply with all applicable laws, regulations and standards in every country in which they operate, and to conduct business in a manner that respects human rights and complies with applicable laws and internationally recognized human rights standards including not engaging in human trafficking, or using forced, involuntary or child labour in any form. NovAtel expects its suppliers and subcontractors to promptly notify it of any violation or suspected violation of the Supplier Code of Conduct by reporting the matter to the supplier’s business contact at NovAtel, compliance@hexagon.com, or Hexagon’s Chief Compliance Officer. 

To the extent applicable, NovAtel will include the substance of FAR 52.222-50 in all subcontracts and in all contracts with agents. If any subcontractor is required by FAR 52.222050 to submit a certification, NovAtel will require submission of the required certification prior to the award of the subcontract and annually thereafter.

Plan Assessments

NovAtel will periodically review and assess this Plan. Modifications will be implemented as required.