The Department of State (“State”) recently announced the upcoming release of the model anti-human trafficking compliance plan. State and Verité, a global NGO, developed this highly-anticipated model compliance plan in response to the amendments to FAR 52.222-50, which require contractors to perform supply chain due diligence and implement a compliance plan for contracts exceeding $500,000 that are for the acquisition of services or non-COTS goods outside the United States.  Because the rule contains relatively little guidance regarding these requirements, the model could provide the contracting community much needed direction regarding supply chain due diligence and compliance plan obligations.

In addition to releasing the model compliance plan, State will also unveil a new resource to assist contractors in complying with the FAR’s anti-human trafficking rule. According to State and Verité, this internet-based resource (to be available at www.ResponsibleSourcingTool.org) incorporates input from “key stakeholders in the private sector, civil society, government, and contractor communities” gathered over the past year and a half.  The resource is said to contain “information, analysis, and practical guidance necessary to effectively address human trafficking,” as well as downloadable risk-management tools.

State and Verité will host the following sessions to debut the model compliance plan and ResponsibleSourcingTool.org:

  • May 16, 2016; 9:30 a.m. to 11:30 a.m.; Dupont Circle Hotel
  • May 17, 2016; 9:00 a.m. to 11:30 a.m.; Sheraton Tysons Hotel
  • May 17, 2016; 1:30 p.m. to 4:00 p.m.; Sheraton Tysons Hotel

Those interested in attending may RSVP to launch17@aspeninstitute.org by May 10, 2016. Following their release, we will provide an update on the model compliance plan and the ResponsibleSourcingTool.org resource.

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Photo of Jennifer Plitsch Jennifer Plitsch

Jennifer Plitsch is co-chair of the firm’s Government Contracts practice group. Her practice includes a wide range of contracting issues for large and small businesses in both defense and civilian contracting. Her practice involves advising clients on contract proposal, performance, and compliance questions…

Jennifer Plitsch is co-chair of the firm’s Government Contracts practice group. Her practice includes a wide range of contracting issues for large and small businesses in both defense and civilian contracting. Her practice involves advising clients on contract proposal, performance, and compliance questions as well as transactional and legislative issues. Her practice also includes bid protest and contract claims and appeals litigation before GAO, agency boards and the federal courts. Ms. Plitsch has particular expertise in advising clients in the pharmaceutical and biologics industry. She advises a range of pharmaceutical and biologics manufacturers on Federal Supply Schedule contracts, including the complex pricing requirements imposed on products under the Veterans Health Care Act, as well as research and development contracts and grants with various federal agencies. She also has significant experience advising on the requirements of various programs under which vaccine products and biodefense medical countermeasures are procured by the Government.

Photo of Alexander Hastings Alexander Hastings

Alex Hastings advises clients across a broad range of government contracting issues, including advising clients in transactional matters involving government contractors and assisting defense contractors and pharmaceutical companies in securing and performing government contracts.

Mr. Hastings also advises clients concerning best practices in…

Alex Hastings advises clients across a broad range of government contracting issues, including advising clients in transactional matters involving government contractors and assisting defense contractors and pharmaceutical companies in securing and performing government contracts.

Mr. Hastings also advises clients concerning best practices in e-discovery. He assists in investigations and litigations that involve complex e-discovery issues and has represented clients in matters involving the U.S. Department of Justice, Securities and Exchange Commission and the United States International Trade Commission.

Mr. Hastings’ government contracts experience includes advising clients regarding new developments in regulatory requirements, including the Federal Acquisition Regulation’s (FAR) anti-human trafficking requirements and the FAR and Bayh-Dole Act’s intellectual property provisions. Mr. Hastings also provides due diligence regulatory advice to clients contemplating the acquisition of government contracting entities or assets.

Mr. Hastings’ e-discovery experience includes advising a wide-array of clients on best practices in information governance and document collection and assisting clients develop effective mobile device and document management policies.

Mr. Hastings also maintains an active pro bono practice and routinely writes on issues related to government contracts and e-discovery.