Trafficking in Persons Compliance

APCO/ArCon Construction and Services has a zero tolerance policy regarding trafficking in persons (TIP) and has devoted sufficient resources to ensure compliance.

TIP policy prohibits individuals from:

Engaging in trafficking in persons

  1. Trafficking in persons (as defined in the Protocol to Prevent, Suppress, and Punish Trafficking in Persons, especially Women and Children, supplementing the UN Convention against Transnational Organized Crime) during the period of this award;
  2. Procurement of a commercial sex act during the period of this award;
  3. Use of forced labor in the performance of this award;
  4. Acts that directly support or advance trafficking in persons, including the following acts:
    1. Destroying, concealing, confiscating, or otherwise denying an employee access to that employee's identity or immigration documents;
    2. Failing to provide return transportation or pay for return transportation costs to an employee from a country outside the United States to the country from which the employee was recruited upon the end of employment if requested by the employee, unless:
      1. exempted from the requirement to provide or pay for such return transportation by USAID under this award; or
      2. the employee is a victim of human trafficking seeking victim services or legal redress in the country of employment or a witness in a human trafficking enforcement action;
    3. Soliciting a person for the purpose of employment, or offering employment, by means of materially false or fraudulent pretenses, representations, or promises regarding that employment;
    4. Charging employees recruitment fees; or
    5. Providing or arranging housing that fails to meet the host country housing and safety standards.


APCO/ArCon TIP policy applies to all employees, including direct employees, consultants. It also applies to subrecipients whose contracts are valued at over $500,000. Where applicable, APCO/ArCon includes the relevant TIP clause in the subcontracts/sub-agreements.

Trafficking in Persons Compliance Plan

Awareness – All APCO/ArCon employees will be required to attend an online presentation introducing the policy and promoting awareness of trafficking activities.
Prevention – APCO/ArCon already has several standards and controls in place to ensure compliance with the TIP policy. The Human Resources has recruitment policies that prohibit the use of any fraudulent or misleading recruitment practices. APCO/ArCon does not charge recruitment fees to any candidate. Employees are paid per established salary ranges that meet or exceed local labor law.
Reporting – It is a priority of APCO/ArcON that the organization and its employees act ethically and legally. It is therefore very important that any illegal activity or violations of the Trafficking in Persons Policy be promptly brought to the organization’s attention. All APCO/ArCon employees, consultants and suppliers are required to report suspected trafficking-related activity to APCO/ArCon.

Reporting may be made in one of several ways:
(1) Any supervisor in his/her reporting line;
(2) A member of the Senior Management Team;
(3) The General Manager/ Co-Owners;
(4) Global Trafficking hotline 1-844-888-FREE or email address at This email address is being protected from spambots. You need JavaScript enabled to view it..

An employee who has any questions regarding this Code or its application to a particular situation should discuss these concerns with any of the persons listed above. APCO/ArCon employees may report illegal acts or a violation of this policy anonymously. However, anonymous reports must contain enough detailed information to permit the organization to investigate.

No disciplinary action will be taken or permitted against employees or subcontractors for good faith reporting or cooperating in the investigation of illegal acts or violations of this policy. Employees who violate the policy or commit illegal acts are subject to disciplinary action up to and including termination.

FAR 52.222-50 – Combating Trafficking in Persons (March 2015)