Veru Inc. (the “Company”) is committed to a work environment that is free from human trafficking and slavery which for purposes of this policy includes forced labor and unlawful child labor. The Company will not tolerate or condone human trafficking or slavery in any part of our global organization. The Company has developed this Anti-Trafficking Policy (the “Policy”) in accordance with the U.S. Government’s zero-tolerance policy regarding trafficking in persons by government contractors and award recipients as set out in, and to implement the Company’s obligations, as applicable, under FAR Subpart 52.222-50, Combatting Trafficking in Persons.
This Policy applies to all Company operations worldwide, including its subsidiaries or affiliated companies, employees, directors, and officers. This Policy also applies to third parties working on the Company’s behalf, including consultants, agents, joint venture partners who perform services or work on our behalf (collectively “Covered Persons”). All Company directors, officers, and employees are individually responsible for understanding and ensuring compliance with this Policy.
In early 2015, the Federal Acquisition Regulation (“FAR”) and DFARS Councils published final rules which significantly increased existing anti-human trafficking related prohibitions on Federal contractors and subcontractors. The Company hereby notifies its employees of the U.S. Government policy toward human trafficking (the “U.S. Policy”) and provides a means for employees to report concerns or issues related to the U.S. Policy without fear of retaliation. The Company is committed to compliance with the U.S. Government’s policy on human trafficking.
U.S. Government Policy:
U.S. Government contractors, contractor employees, and their agents shall not:
(1) Engage in severe forms of trafficking in persons during the period of performance of the contract;
(2) Procure commercial sex acts during the period of performance of the contract;
(3) Use forced labor in the performance of the contract;
(4) Destroy, conceal, confiscate, or otherwise deny access by an 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 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;
(ii) Use recruiters that do not comply with local labor laws of the country in which the recruiting takes place;
(6) Charge 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 U.S. Government contract or subcontract (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 U.S. 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 United States); except that–
(ii) The requirements of paragraphs (7)(i) above shall not apply to an employee who is–
(A) Legally permitted to remain in the country of employment and who 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) The requirements of paragraph (7)(i) are modified 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. 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. This paragraph does not apply when the exemptions at 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.
Covered Persons who violate the Policy may be subject to discipline, including but not limited to, being removed from the U.S. Government contract involved; reduction in benefits; or termination of employment, as appropriate.
For More Information: Additional information about trafficking in persons may be found at the website for the 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/. The full text of the FAR provision may be viewed at https://www.acquisition.gov/content/part-52-solicitation-provisions-and-contract-clauses#i1056535.
Reporting Concerns: Company has a responsibility to report trafficking in persons violations committed by the Company, its employees or its subcontractor employees. Any concerns or issues relating to this Policy should be reported to:
Mitchell S. Steiner, MD, Chairman, President & Chief Executive Officer at
Philip R. Greenberg, Executive Vice President–Legal & Secretary at email@example.com or firstname.lastname@example.org, managed by the Company’s Legal Department
Jesus Socorro, Chair of the Company’s Audit Committee at email@example.com
The Company does not tolerate retaliation and will not discharge, demote, suspend, threaten, harass or in any manner retaliate against any employee who raises a good faith concern, complaint or compliance issue.
In addition, 10 U.S.C. § 2409 provides additional employee protections from reprisal for whistleblowing on trafficking in persons violations.