Revision Date:

Field Manual
13/01/2022
Procedure 3.6: TIP Compliance Plan Customization &
Revision Number:3.0
Implementation

1. Purpose and Scope:

1.1. This procedure provides detailed instructions supporting the execution of
Policy 3: Governing Policy on Project Compliance and the Governing Policy on
Anti-Human Trafficking in the U .S Business Operations Manual.
Policy 8.0a Governing Policy on Anti-Human Trafficking
1.2. The primary purpose of this procedure is to describe the actions that must be
taken in the field to comply with DAI US policy on Anti -Human Trafficking.
QRG: Trafficking In Persons
1.3. This procedure implements FAR 52.222-50 and mandatory provision M20 of
Standard Provisions for U .S. Nongovernmental Organizations , which require
implementers of U .S. Government contracts and cooperative agreements to
administer policies and procedures to prevent human trafficking .

2. Roles and Responsibilities:

2.1. All project staff are responsible for understanding and complying with DAI ’s
Anti-Human Trafficking policy.
2.2. The Chief of Party (COP) is responsible for ensuring customization ,
implementation and monitoring of the Trafficking in Persons (TIP) compliance
plan. The COP is also responsible for certifying the TIP compliance plan on an
annual basis on the contract /agreement anniversary date .

3. Instructions:

Responsibility Customize and Communicate the TIP Compliance Plan

COP (COP) 1. In coordination with the DAI US Project Delivery Team assign the task of
customizing the Trafficking in Persons (TIP) compliance plan with a
completion deadline within three months of the project start date .
1.1. Depending upon the risk -level of the project ’s environment, the
Associate, Project Manager (PM), Start-up Manager, Deputy Chief of
Party (DCOP), or a technical specialist could customize the TIP
compliance plan and components .
Assigned Staff 2. Collect information regarding the trafficking -in-persons risk level for
the project .
2.1. Read the latest State Department TIP Report (Link).
2.2. Identify the State Department TIP tier ranking for the country of
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 operation (Low, Medium, or High). See the Guidance section below
for additional information on the TIP tier rankings in the TIP
Report.
2.3. Identify which economic sector (s), geographic region (s), or ethnic
population(s) are at greatest risk , and which types of human
trafficking are most prevalent and determine the extent to which
the project will work with these sectors , regions, or populations.
2.4. As needed, collect information on trafficking in persons from other
credible sources, partners within the country or using notes
gathered during reconnaissance assignments in the country . See
the Guidance section below for additional TIP resources .
3. Determine the trafficking -in-persons risk level for the project (Low,
Medium, or High)
3.1. Note, if the project is identified as a Tier 1 (low risk) country by the
State Department TIP report but interacts with a high -risk sector,
region, or population the risk level must be adjusted accordingly .
4. Share the risk -level assessment with the DAI US Regional Finance and
Operations Manager (RFOM) who will evaluate the assigned risk -level
and gather expertise as appropriate .
5. Customize only the text /sections highlighted in yellow of the
compliance plan template based upon assigned risk level .
Form 3.14: Anti-Human Trafficking Compliance Plan
5.1. If the risk level for the project is Medium or High , include more
robust awareness activities and detailed information on the risks in
the project ’s environment.
5.2. If the risk level for the project is High , consult with the DAI US
Project Delivery Team regarding the need to engage a TIP expert to
assist with customization of the compliance plan .
6. Seek approval of the compliance plan by the COP .
7. Submit the final compliance plan to the project ’s FOM Administrator.
Field 8. Replace the template TIP compliance plan template in the FOM with the
Operations project’s customized version by following the change request process .
Manual (FOM)
Administrator Procedure 6.1: Change Requests and Revision Control of the Field Manual
Form 3.14: Anti-Human Trafficking Compliance Plan
Chief of Party 9. Create a plan for communicating the project ’s TIP compliance plan.
(COP)
9.1. The communication should involve a meeting with all project staff ,
including subcontractor staff , to make them aware of the
compliance plan and any actions they should take to comply with
the plan.
9.2. Template presentations and posters can be used to communicate
the compliance plan .

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The electronic version of the manual on a project's TAMIS is the official version and takes precedence over any other copy.
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 Form 3.17: TIP Presentations
Form 3.16: Anti-Human Trafficking Poster

Responsibility Certify the Compliance Plan

Chief of Party 1. Each year, on the anniversary of the contract /agreement date , take any
(COP) action required as per the project ’s compliance plan to ensure due
diligence is conducted .
2. Certify the compliance plan using the certification form on the final
page of the TIP compliance plan .
Form 3.14: Anti-Human Trafficking Compliance Plan
2.1.This certification acknowledges through due diligence efforts that :
• To the best of his /her knowledge and or belief , the project 's
employees and agents, as well as its subcontractors ,
sub-awardees and their employees and agents are not engaged
in prohibited activities ; and
• If prohibited abuses are found , DAI and/or its subcontractor and
sub-awardees will take the appropriate remedial and referral
actions.
2.2.See the Guidance section below for a description of adequate due
diligence.
3. Upload the completed ce rtification in the TIP certification section of the
Corporate module in TAMIS. The system will prompt you to also email
the certification to the RFOM and the DAI US Contracts Administrator /
Contracts Manager , who will submit the annual certification to the
Contracting Officer (CO)/Agreement Officer (AO).

4. Recordkeeping:
The following records must be maintained in the course of executing this work
instruction. Requirements for the management of these records are provided in the
Project Record Map.
• Customized TIP Compliance Plan
• Annual TIP Compliance Plan certifications

5. Guidance:
This section describes guidance to aid in the understanding and implementation of
this procedure and does not include mandatory requirements .
5.1. In the State Department TIP Report , each country is categorized as Tier 1
(low risk), Tier 2 (high risk), or Tier 3 (extremely high risk). The TIP tiers
measure the severity of human trafficking in that country and how well its
government complies with the Trafficking Victim ’s Prevention Act. If the
project operates in a Tier 2 or Tier 3 country, it is operating in a country with
individuals who are at high risk for human trafficking and a government that

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The electronic version of the manual on a project's TAMIS is the official version and takes precedence over any other copy.
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 is not adequately enforcing anti -trafficking laws.
5.2. Other sources of TIP information include :
• U.S. Department of Homeland Security Indicators of Human Trafficking
• Verite Toolkit for Fair Hiring Worldwide
5.3. Due-diligence efforts will vary by project risk level , sector, and operating
environment and at a minimum include :
• For project staff , ensuring training is completed , awareness materials
are posted, and any prohibited activities are reported as per the
Compliance Plan constitutes sufficient due diligence .
• For subcontractors , subawardees, agents and their employees , during
site visits or visits to vendors , project staff should be cognizant of
human trafficking warning signs , and report potential violations as per
the "Reporting" section of the Compliance Plan .
• For vendors with agreements over $550,000, and Grantees with
agreements over $500,000, a Compliance Plan and a certification is
collected annually and kept in their folder

6. Tools, References, and Forms:

The following tools and references (work instructions, guides, templates, DAI US Ops
Manual documents, etc.) are referenced throughout this procedure :

UID for this form: FE006C250B

Associated Change orderCO-0082
Inherited UID From the draft: 9D004FD73B
Section Name: Project Compliance

Proprietary and confidential information for use by DAI and project staff only. Not for outside distribution.
The electronic version of the manual on a project's TAMIS is the official version and takes precedence over any other copy.
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