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Prohibiting Trafficking Statement

Vegas License International LLC and subsidiaries


Trafficking in Persons, Statement

As stated in the Vegas Code of Conduct, lawful and ethical behavior is critical to our continued success and is required. You must comply with those laws and regulations relating to business conduct. In addition, you must avoid and report any activity that involves, or could lead to the involvement of Vegas in any potential unlawful practice.

Vegas is committed to protecting and advancing human rights in all our operations. Treating others with respect and dignity, encourage diversity and diverse opinions, provide safe working conditions and promote equal opportunity for all.

Vegas supports the policies adopted by the United States and International governments to combat the trafficking of persons for any purpose. As set forth in the following, Vegas prohibits trafficking-related activities and Vegas expects our suppliers and contractors to uphold these important principles, as well. Vegas encourages you to report any suspected violations. If you have reason to believe that a legal or ethical violation has occured, it is your duty to report to your manager, Company Contact or the legal or human resources department, or by using the Alert Line. Our policies forbid any form of retaliation against you for fulfilling this obligation.

Prohibited Activities

Vegas prohibits all activities relating to the trafficking of persons.

  • · I will not engage in severe forms of trafficking (using fraud or coercion) in persons
  • · I will not procure commerical sex acts;
  • · I will not use forced labor;
  • · I will not 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;
  • · I will not use recruiters that do not comply with local labor laws of the country in which the recruiting takes place;
  • · I will not charge employees recruitment fees;
  • · I will not fail to provide return transportation or pay for the cost of return transportation upon the end of employment for certain employees who were brought from one country to another (consult with your company's legal department to determine whether this situation applies).
  • · I will not provide or arrange housing that fails to meet the host country housing and safety standards.
  • · I will not if required by law or contract, fail to provide an employment contract, recruitment agreement, or other required work document in writing and 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.

Obligations of Employees

All Vegas employees and agents are expected to be familiar with the prohibited human trafficking activities described above and to avoid them. Failure to abide by this policy may result in severe disciplinary action up to and including termination.

If you become aware of an activity that you suspect is a violation of this Policy, you must report it through one of the channels noted below in the Reporting section.

If requested by the legal department, you must cooperate with any investigation into suspected prohibitied activities. Vegas is committed to cooperating fully with governemental authorities in investigating violations, including:

  • · providing timely and complete responses to government auditors' and investigators' requests for documents;
  • · providing reasonable access to its facilities and staff to allow governmental authorities to conduct audits, investigations, or other actions to ascertain compliance with the Trafficking Victims Protection Act of 2000 (22 U.S.C. chapter 78), E.O. 13627, or any other applicable law or regulation establishing restrictions on trafficking in persons, the procurement of commercial sex acts, or the use of forced labor; and
  • · protecting all employees suspected of being victims of or witnesses to prohibited activities, prior to returning to the country from which the employee was recruited, without preventing or hindering the ability of these employees from cooperating fully with governmental authorities.

Obligations of Agents

This Policy applies to those agents performing services on behalf of Vegas or operating under the firms' brand name to the extent set forth in their respective agreements with Vegas and permitted under applicable law. Failure to abide by this policy may result in the termination of the business relationship with Vegas.

Reporting

If you know of or suspect there is a violation of the law, regulation, the Code, this Policy or any other policy, any unethical behavior related to Vegas, or any questionable accounting, internal accounting controls, auditing matters or fraud related to Vegas, you must immediately report it to your manager, Company Contact or your company's legal or human resources department or use the complaint processes within your operating company. We encourage you to talk to managers, Company Contacts, members of your company's legal or human resources department or other appropriate personnel when in doubt about the best course of action in a particular situation. If you report a violation or suspected violation to your manager, Company Contact or a member of your company's human resources department and appropriate action is not taken, you must contact your company's legal department. The firm's policies prohibit any form of retailiation against a person who reports in good faith any known or suspected misconduct.

In addition to the people above, you may report suspected human trafficking activities to:

The Gobal Human Trafficking Hotline:
1-844-888-FREE (1-844-888-3733)
help@befree.org

Compliance Plan

Vegas maintains a compliance plan to ensure compliance with the principles and objectives of this Policy. The contents of the compliance plan include:

  • · An awareness program to inform employees about the U.S. and International government's policy prohibiting trafficking-related activities, the activities prohibited, and the actions that will be taken in response to violations;
  • · A process for employees to report, without fear of retaliation, activity inconsistent with this Policy;
  • · A recruitement and wage plan that only permits the use of recruitment companies with trained employees prohibits charging recruitment fees to the employee, and ensures that wages meet applicable host-country legal requirements or explains any variance;
  • · A housing plan that ensures that any provided housing meets host-country housing and safety standards; and
  • · Procedures to monitor the compliance of agents and subcontractors with the requirements of this Policy.

If you would like more information regarding the compliance plan, please contact your company's legal department.

For further information, phone 1 (702) 720-2300 or Toll Free in U.S. & Canada 1 (877) 800-VEGAS™.

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