Human Trafficking Policy
Modern Slavery and Human Trafficking Policy
Purpose
ICAT Logistics(“ICAT”) is committed to ethical and lawful practices in all aspects of our business, including a work environment that is free from modern slavery and human trafficking and compliance with the United States Trafficking Victims Protection Act (2000), Executive Order 13627 (Strengthening Protections Against Trafficking in Persons in Federal Contracts), and other applicable national and international regulations regarding modern slavery and human trafficking. We maintain a zero-tolerance policy toward modern slavery and human trafficking, which for the purpose of this policy includes slavery, servitude, forced or compulsory labor, child labor, and human-trafficking related activities. This policy affirms our dedication to respecting human rights and ensuring our operations, global supply chain, and partnerships reflect our commitment to dignity, respect, and compliance with applicable laws.
Scope
This policy applies to all ICAT employees, officers, contractors, subcontractors, partners, agents, subsidiaries, vendors, suppliers, and any other third parties doing business with or on behalf of ICAT globally (collectively, “employees and third parties”).
Policy Statement
ICAT prohibits all forms of modern slavery and human trafficking. ICAT employees and third parties must not engage in any practice that constitutes modern slavery or human trafficking, including, but not limited to:
- Slavery;
- Servitude;
- Forced or compulsory labor;
- Child labor; and
- Human-trafficking.
ICAT requires that third parties that might act for or on behalf of ICAT, including, contractors, subcontractors, partners, agents, suppliers, vendors, and any other third parties acting on behalf of ICAT, along with each of its subsidiaries, affiliates, and subcontractors, embrace ICAT’s commitment to integrity in carrying out work in relation to ICAT.
Prohibited Practices
In furtherance of this policy, ICAT employees and third parties are strictly prohibited from engaging in, without limitation, the following activities:
- Destroying or withholding identity documents (e.g., passports or IDs);
- Charging recruitment fees;
- Using misleading or fraudulent recruitment practices;
- Failing to provide return transportation for individuals recruited from abroad (where legally required);
- Allowing or encouraging any form of coercion or involuntary service; or
- Engaging in or supporting commercial sex acts in connection with business activity.
Responsibilities
- Employees, officers, contractors, subcontractors, partners, agents, and subsidiaries must immediately report any suspected violations to Human Resources or the Compliance Department.
- Vendors, suppliers, and third parties must certify compliance with this policy and agree to allow ICAT to conduct audits regarding compliance with this policy should ICAT determine such an audit necessary.
- Managers and leadership are responsible for promoting awareness and ensuring that this policy is implemented effectively.
Training and Awareness
ICAT will provide relevant training to employees, especially those involved in recruiting, procurement, or operations in higher-risk regions. Training will include how to identify signs of modern slavery and human trafficking and the proper channels for reporting concerns.
Reporting and Non-Retaliation
ICAT requires all employees and third parties to report violations of this policy or associated concerns. Employees and third parties are also required to fully participate in any investigations or audits related to this policy. Employees or third parties who fail to report violations of this policy or fully cooperate with an investigation into suspected violations may be found to be in violation of this policy and may be subject to disciplinary action, including termination.
ICAT strictly prohibits retaliation against any individual who reports suspected modern slavery or human trafficking in good faith or participates in an associated investigation or audit.
Policy Review
This policy will be reviewed annually and updated as needed to ensure compliance with evolving legal requirements and best practices.
