1- Overview
Moonline and its employees are committed to maintaining business practice standards that honor and protect
the dignity and integrity of everyone with whom the Company conducts business, employs, and serves. This
includes opposition to persons trafficking and forced labor in any form. To this end, Moonline has adopted
a policy combating trafficking in persons (CTIP) in all aspects of its business.
Moonline will comply with all local and/or national trafficking regulations “including (FAR Clause 52.222-50)
and UN Protocol to Prevent, Suppress and Punish Trafficking in Persons, Especially Women and Children,
supplementing the United Nations Convention against Transnational Organized Crime
and the Iraqi Law Anti-Human Trafficking Law No. 28 of the year 2012” that apply to our business operations in
all locations.
2- Policy
All Moonline employees are required to comply with Moonline’s CTIP policy. Each employee is required to sign
an attendance form stating they have been informed about and understand Moonline’s CTIP policy. This
policy is posted on the Moonline Quality Management System (Skytrust).
By way of this policy, all Moonline staff is informed that the following are prohibited activities:
- Engaging in forms of TIP during the period of performance of the contract
- Procuring commercial sex acts during the period of performance of the contract
- Using forced labor in the performance of the contract
- Destroying, concealing, confiscating, or otherwise denying access by an employee to the employee’s
identity or immigration documents, such as passports or driver’s licenses, regardless of issuing
authority - Using misleading or fraudulent practices during the recruitment of employees or offering of
employment, such as failing to disclose, in a format and language accessible to the worker, basic
information or making material misrepresentations during the recruitment of employees regarding
the key terms and conditions of employment, including wages benefits, the location of work, the living
conditions, housing, and associated costs (if employer or agent provided or arranged), any significant
cost to be charged to the employee, 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 employees recruitment fees
- Failing to provide return transportation or pay for the cost of return transportation upon the end of
employment
o For an employee who is not a national of the country in which the work is taking place and
who was brought into that country for the purpose of working with the company
o For an employee who is not an Iraqi national and who was brought into Iraq for the purpose of
working on a U.S. Government contract or subcontract, if the payment of such costs is
required under existing temporary worker programs or pursuant to a written agreement with
the employee (for portions of contracts performed inside Iraq or any other place that
Moonline is existing)
✓ These mentioned 2 points will not be applicable to the employee in the case of:
1- (A) Legally permitted to remain in the country of employment and who chooses to do so; or
2- Exempted by an authorized official of the contracting agency from the
the requirement to provide return transportation or pay for the cost of the return
transportation;
- Provide or arrange housing that fails to meet the host country’s housing and safety standards
- If required by law or contract, fail to provide an employment contract, recruitment agreement, or
other required work documents in writing. Such written work document shall be 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
All Moonline employees are required to report any possible non-compliance immediately to their AHRQ Dept.
or call the Hotline at +9647506000123.
The Moonline Code of Conduct provides protections for employees against retaliation for disclosing
information that the employee reasonably believes is evidence of a violation of a law, rule or regulation
related to a contract.
Failure to comply with this policy could result in disciplinary action up to and including termination of
employment. For corporate and agent employees, non-compliance could result in remediation up to and
including immediate termination of the contract. For contractor’s agents, failure to comply will include termination
of the contractual agreement.
Reporting Requirements and Procedure
All Moonline’s personnel are required to report any suspected trafficking-related activity or violation of this
policy to the AHRQ Dept.
At this Phone Number: +9647506000123
Email: Hr@moonlinetravel.com
Or send it to Management through the below channels:
- CEO (Chief Executive Officer): Brwa Saeed Qader
Mobile No. (Iraq): 009647501335959
Email: braw@moonlinetravel.com - COO (Chief Operating Officer): Bland Saeed Qader
Mobile No. (Iraq): 009647501145055
Email: blend@moonlinetravel.com
Moonline’s personnel who believe they or others have been subjected to prohibited trafficking-related
activities may report the activity as outlined above or may contact Moonline Hotline at 009647506000123 or send
email to Hr@moonlinetravel.com.
Moonline Cooperation:
Moonline will:
(i) Disclose to the agency Inspector General information sufficient to identify the nature and extent of any
offense and the individuals responsible for the conduct;
(ii) Provide timely and complete responses to Government auditors’ and investigators’ requests for documents;
(iii) Cooperate fully in providing reasonable access to its facilities and staff in all its branches to allow
contracting agencies and other responsible Federal agencies to conduct audits, investigations, or other actions
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
(iv) Protect all employees suspected of being victims of or witnesses to prohibited activities, prior to returning
to the country from which the employee was recruited, and shall not prevent or hinder the ability of these
employees from cooperating fully with Government authorities.
Investigations
- “Administrative & HRQ department – AHRQ” will investigate all reports of prohibited trafficking-related
activity or violations of this policy and take appropriate action. The AHRQ will make all required
notifications to government agencies, as more fully set out in the Compliance Plan. - If Moonline receives credible information from an employee report or any other source alleging prohibited
trafficking-related activity, Moonline AHRQ will conduct an investigation and report its findings and
determine what, if any, remedial action is appropriate. - Moonline strictly prohibits retaliation against any Moonline employee who reports prohibited trafficking-related activity or other violations of this policy, or who cooperates with any internal or government
investigations of such reports. - Employees may do so without fear of reprisal.
- Moonline personnel who engage in any form of retaliation against those who report prohibited
trafficking-related activities or other violations of this policy are subject to disciplinary action, up to and
including termination of employment with Moonline. - AHRQ will be responsible for immediately notifying the contracting officer of the information received and any
resulting in remedial action being taken. - Moonline will cooperate fully with the local government authority and any US Government agencies
responsible for any investigations, audits, or corrective actions relating to trafficking in persons, including, but
not limited to, providing timely and complete responses to document requests, and providing reasonable
access to Moonline facilities and staff. - Moonline will protect all employees suspected of being victims of or witnesses to prohibited activities, prior to
returning to the country from which the employee was recruited and will not prevent or hinder these
employees from cooperating fully with the local governmental authority or US government authorities.
References:
1- The Iraqi Law Anti-Human Trafficking Law No. 28 of the year 2012” that apply to our business operations in all locations.
2- US Federal Acquisition Regulation 52.222-50 (“FAR 52.222-50”).
3- UN Protocol to Prevent, Suppress and Punish Trafficking in Persons, Especially Women, and Children,supplementing the United Nations Convention against Transnational Organized Crime
4- All Applicable laws where Moonline has offices worldwide.
