Bravo 9

Legal

Bravo 9 LLC: Combatting Trafficking in Persons (CTIP) Policy

Effective Date: 3 February 2026 Applicability: All Bravo 9 LLC employees, subcontractors, vendors, and agents.

1.Policy Statement

Bravo 9 LLC maintains a zero-tolerance policy regarding human trafficking. We are committed to conducting business ethically and in full compliance with all applicable laws and regulations, including the U.S. Government’s policy prohibiting trafficking in persons as outlined in FAR 52.222-50.

Bravo 9 LLC strictly prohibits its employees, subcontractors, and agents from engaging in any form of trafficking in persons, including the use of forced labor, sex trafficking, or the procurement of commercial sex acts during the performance of any contract.

2.Prohibited Activities

To ensure compliance, Bravo 9 LLC personnel and partners are strictly prohibited from engaging in the following activities:

  • Sex Trafficking & Commercial Sex Acts: Procuring commercial sex acts during the period of performance of a contract.
  • Forced Labor: Using forced, bonded, or indentured labor, or involuntary prison labor.
  • Document Destruction: Destroying, concealing, confiscating, or otherwise denying access to an employee’s identity or immigration documents (e.g., passports, driver's licenses).
  • Misleading Recruitment: Using misleading or fraudulent practices during recruitment, such as misrepresenting wages, benefits, location of work, or living conditions.
  • Recruitment Fees: Charging employees or potential employees recruitment fees.
  • Return Transportation: Failing to provide return transportation or pay for the cost of return transportation for employees who are not nationals of the country where the work is taking place (upon the end of employment).
  • Substandard Housing: Providing or arranging housing that fails to meet host country housing and safety standards.

3.Reporting and Notification

Bravo 9 LLC encourages all employees to report any suspected violations of this policy immediately. We strictly prohibit retaliation against any individual who reports a violation in good faith.

How to Report:

A worker may use either route. The internal addresses above are operated by Bravo 9 LLC; the Global and National Human Trafficking Hotlines are independent of the company, and a report may be made to them directly without telling Bravo 9 LLC first.

Bravo 9 LLC will immediately inform the Contracting Officer and the agency Inspector General of any credible information alleging a violation of this policy.

4.Employee Awareness & Training

Bravo 9 LLC implements an awareness program to ensure all employees understand their responsibilities. This includes:

  • Mandatory CTIP training during onboarding and annually thereafter.
  • Posting of "Know Your Rights" materials in workspaces (both physical and digital).
  • Clear communication of reporting mechanisms.

5.Recruitment and Wage Plan

Bravo 9 LLC certifies that:

  • We only use recruitment companies with trained employees.
  • We prohibit charging recruitment fees to the employee.
  • Wages meet applicable host-country legal requirements or vary only to the benefit of the employee.

6.Subcontractor Compliance

Bravo 9 LLC requires all subcontractors and agents to comply with this CTIP policy. We flow down the requirements of FAR 52.222-50 to all subcontracts. Subcontractors found to be in violation of this policy will be subject to immediate termination of their contract.

7.Disciplinary Actions

Any Bravo 9 LLC employee found to have violated this policy will be subject to disciplinary action, up to and including termination of employment. Violations may also result in removal from the contract, suspension, debarment, or referral to law enforcement agencies for criminal prosecution.