Policy for Combatting Trafficking in Persons

This statement of policy (the “Policy” or the “Anti-Trafficking Policy”) for combatting trafficking in persons sets forth, delineates, and describes the policy of Sterling Medical Corporation, and all of its subsidiary corporations, which are referred to, together and separately, as the “Company” in this Policy.

1. It is the policy of Sterling Medical to prohibit and support the prohibition against trafficking in persons, including but not limited to the trafficking and trafficking-related activities specified below.
   1. The severe form of trafficking in support of business, commercial, or contractual operations.
   2. The procurement of commercial sex acts during the period of business performance.
   3. The use of forced labor in business performs ance.
   4. The concealment, confiscation, or denial of access to an individual’s identity or immigration documents, including passports or drivers licenses.
   5. Any and all other practices that can aide or abet, or support trafficking in persons in any location. 
2. It is the policy of the Company to not charge any recruitment fees for their recruitment to employees.
3. It is the policy of the Company to ensure that the location of work, any related living conditions, the nature of costs to be charged to the employees, and, where hazardous, the hazardous nature of work be disclosed in an accessible format and language.
4. If an individual were to travel to another country on behalf of the Company, the Company’s policy is not to fail to provide return transportation or payment to support return transportation at termination of employment. Such return transportation shall be provided in a way that does not obstruct any legal redress or related activity in the country where such services are provided.
5. It is the policy of the Company to pay costs reasonably required to be paid  for travel to the United States and for return travel to the employees’ original country, for employees of the Company that would travel to the United States for work on behalf of any contract or subcontract performed by the Company. 
6. It is the policy of the Company, in the event that housing is furnished on behalf of the Company’s employees, to ensure that such housing meets applicable health standards in the United States, if such housing is furnished in the United States, and to ensure that such housing meets applicable health standards in any host nation (“Host Nation”) where services are performed.
7. It is the policy of the Company, wherever required by law or by contract, to provide an employment contract, recruitment agreement, or other necessary work document in writing.  Such written work will be in a language that the employee that is a party to such document can understand—eg. agreement in English will only be provided to employees that understand English.
8. In cases where an employee relocates to perform work on behalf of the Company, the written document described above will be provided to the employee at least 5 days prior to the relocation of such employee.  The work document will include details describing the required work, wages to be furnished, work location(s), living accommodations if those are to be furnished, a description of time off, a description of transportation arrangements, and other elements required to combat and assist in the combatting of trafficking in persons.  The Company will never charge a recruitment fee for employees in order for the employee to perform work on behalf of the Company.
9. The Company also affirms that it is the policy of the United States and its Government to prohibit trafficking in persons or to retaliate against employees or agents who violate the policy against trafficking in persons, including actions such as reduction in salary, denial of salary, termination of employment, or the like.  Moreover, the Company will take appropriate action against any agents, subcontractors, or employees that violate the policy described above in this paragraph.
10. It is the policy of the Company to perform recruitment for overseas assignments using its own staff to the greatest degree possible.  In the event that recruitment companies were to be utilized, it is the policy of the Company to ensure that such recruitment companies, if utilized, prohibit charging recruitment fees to recruited employees. If housing is provided, the Company will ensure that such housing meets housing and safety standards in the location where such housing is furnished.
11. The Company will deploy appropriate procedures to verify that any agents of the company or subcontractors are not engaged in activities prohibited by this Anti-Trafficking Policy.
12. It is the policy of the Company, in all circumstances, to ensure that neither the Company, subcontractors of the Company, agents of the Company, or employees of the Company, countenance, support, encourage, facilitate or engage, in any way, in the pursuit of or support of, or facilitation in any form, practices of debt bondage, forced labor, threats of serious harm to or physical restraint against, a person, or any form of involuntary servitude.
13. Sterling Medical, as part of its Anti Trafficking Policy, encourages employees as well as agents or subcontractors of the Company to report activity facilitating trafficking or activity inconsistent with the Policy Against Trafficking in Persons, with such trafficking to be reported whenever appropriate to the Global Human Trafficking Hotline, at 1-844-888-FREE, and to the relevant email address of [email protected]. 
14. The Company is strongly committed to preventing, prohibiting, avoiding, and combatting trafficking in persons, whether that occurs in the US or any other nation.
15. The Company is dedicated to combatting any form of “severe trafficking in persons” with such severe forms of trafficking in persons including recruitment, harboring, transportation, or obtaining of a person for labor or for services through the use of force, or coercion, or subjecting any person to involuntary servitude, peonage, debt bondage, or slavery, or for the inducement of commercial sex acts, or such acts by force, fraud, or coercion, or any such acts that might be induced with respect to a person that has not yet attained 18 years of age.