The Dark Side of Military Logistics: Human Trafficking

Walk through any forward deployed operating base and - if you’re paying attention - you’ll see people from around the world.  Not just coalition partners in uniform, but base support personnel.  There are always contractors from the US, from the host nation, from the Philippines, from Pakistan; from just about anywhere who are key contributors to activities like life support.

Life support is a military logistics activity, but are we always paying attention?  Are we really seeing?  Or are we guilty of looking the other way sometimes, pretending that we don’t see the human trafficking issues that can creep into the mix?

Clearly the Federal Government thinks we can do better.

At the beginning of this month changes to some Federal Regulations went into effect, adding additional requirements to existing human trafficking-related prohibitions in FAR 22.1700 and FAR 52.222-50. 

The US Government has a zero tolerance policy on human trafficking.  The government’s explicit goal is to prevent any trafficking in persons and to monitor, detect and terminate contractors and subcontractors who engage in prohibited activities.  The human trafficking requirements must be flowed down to all subcontractors. 

Contracts performed outside the United States worth more than $500,000 need a compliance plan and annual certifications of compliance.  The contractor must submit an annual certification - after conducting due diligence - that to the best of its knowledge none of its agents, subcontractors or their agents have engaged in any prohibited activities.  If any violations are found during the due diligence process, the contractor must take “appropriate” action.

Violations can have some pretty nasty implications, including removal of employees, termination of subcontracts, suspension of payments until corrective action is taken, loss of award fee, declination to exercise options, default termination of the contract, suspension or debarment.

Sometimes it takes a threat to the bottom line for some people to decide to do the right thing, so perhaps the threat of enforcement coupled with the potential of a nasty headline above the fold in the Washington Post will bring some focus.

I prefer to think that we are better than that, so the next time you are in a forward man camp, pay attention and really see.  It’s up to all of us to fight human trafficking, and it happens in our world.

You can make a difference.