Anti-Human-Trafficking Policy

Purpose

Our company and the United States Government prohibit trafficking in persons. The U.S. Government’s policy prohibiting trafficking in persons is available at 48 CFR § 52.222-50 and is summarized below under the heading: “Summary of U.S. Government Policy of Prohibiting Trafficking in Persons.”

Our company is committed to providing its legitimate users an environment that is free from human trafficking, sex trafficking and slavery, which for purposes of this policy includes forced labor and unlawful child labor. Online Connections Inc. will not tolerate or condone human trafficking, sex trafficking or slavery in any part of our global organization.

Our company’s employees, subsidiaries, contractors, subcontractors, vendors, suppliers, partners and others through whom our company conducts business must avoid complicity in any practice that constitutes trafficking in persons or slavery.

Scope

This policy applies to all visitors and customers of our company’s websites and mobile applications. Every visitor and customer is responsible for reading, understanding and complying with this policy. If you have any questions or concerns relating to this policy, consult the our company’s customer service department for more information.

Procedures

Report any conduct that you believe to be a violation of this policy to our company’s customer service team, for forwarding to our legal department and possible escalation to the appropriate law enforcement agency.

Visitors and customers who fail to report actual or suspected misconduct may be deemed in violation of this policy.

Summary of U.S. Government Policy of Prohibiting Trafficking in Persons

Visitors and customers of our company’s website and mobile applications must not engage in any practice that constitutes trafficking in persons or slavery. This includes, but is not limited to, the following activities:

• Engaging in any form of trafficking in persons.
• Procuring commercial sex acts.
• Using forced labor in the performance of any work.
• 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 issuing authority.
• Using misleading or fraudulent practices during the recruitment of employees or offering of employment/contract positions, such as failing to disclose, in a format and language understood by the employee or applicant, 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 provided by the employer or agent), any significant cost to be charged to the employee or applicant, and, if applicable, the hazardous nature of the work.
• Using recruiters that do not comply with local labor laws of the country in which the recruiting takes place.
• Charging applicants recruitment fees.
• If required by law or contract, failing to provide return transportation or failing to pay for the cost of return transportation upon the end of employment.
• If required by law or contract, failing to provide or arrange housing that meets the host country housing and safety standards.
• If required by law or contract, failing to provide an employment contract, recruitment agreement, or other required work document in writing with legally required information and in a language the employee understands.