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Initiating Authority
- The Office of General Counsel serves as the initiating authority for this policy.
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Purpose
- The University is committed to combating human trafficking and does not tolerate or condone human trafficking of any form or at any level within the University. University Employees, subcontractors, contractors, and vendors are prohibited from engaging in any human trafficking-related activities. This policy also serves to inform University Employees, subcontractors, contractors, and vendors of the federal government's zero tolerance policy for human trafficking, as outlined by the Applicable Laws.
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Policy
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General Rule
All University Employees must read and adhere to this policy. In addition, University Controlled Affiliated Organizations (as defined in University Policy 1.06 / Controlled Affiliated Organizations), subcontractors, contractors, and vendors are required to adhere to this policy to the extent required by contract or law.
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Prohibited Activities
Consistent with U.S. Government policy, the University prohibits any human trafficking-related activities. University Employees, subcontractors, contractors, and vendors, to the extent required by contract or law, shall not engage in any human trafficking-related activities as defined in the Applicable Laws, including but not limited to:
- Engaging in any form of trafficking in persons;
- Procuring commercial sex acts;
- Using forced labor;
- Destroying, concealing, confiscating, or otherwise denying access by an Employee to the Employee's identity or immigration documents, such as passports or drivers' 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 and fringe 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 or placement fees;
- Failing to provide return transportation or pay for the cost of return transportation upon the end of employment for an Employee brought into the country of employment specifically for work on a U.S. Government contract, subject to applicable conditions and exemptions, as more fully set forth in the Applicable Laws;
- Providing or arranging housing that fails to meet the host country housing and safety standards; or
- If required by law or contract, failing to provide an employment contract, recruitment agreement, or other required work document in writing.
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Investigations
The University requires all Employees, subcontractors, contractors, and vendors to cooperate fully in any investigation of any alleged violation of this policy.
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Compliance Plan
It is the policy of the University to implement a compliance plan if required by the Applicable Laws and to comply with all related certification obligations. 蹤獲扦 Employees, subcontractors, contractors, and vendors are expected to assist in the implementation of any compliance plan when informed that it is required.
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Applicable Laws
It is the policy of the University to include the substance of the Applicable Laws in any subcontract, to the extent required by the Applicable Laws.
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Policy Violations
- The University is required to and will take action for violation of the U.S. Government's
zero tolerance policy, which may include but is not limited to:
- Removing the violating Employee, subcontractor, contractor or vendor from working on any applicable contract;
- Termination of applicable contracts between the University and any violating contractor, subcontractor or vendor;
- Reducing benefits for the violating Employee; or
- Imposing actions related to employment, up to and including termination of employment with the University.
- The University is required to and will take action for violation of the U.S. Government's
zero tolerance policy, which may include but is not limited to:
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Definitions
- For the purpose of this policy only, the following definitions shall apply:
- Applicable Laws: Shall mean any applicable federal laws governing human trafficking, including but not limited to FAR 52.222-50 and 2 CFR 175.105.
- Employee: An individual who provides services to the University on a regular basis in exchange for compensation and receives a W-2 for such services. This includes temporary and part-time Employees.
- University: 蹤獲扦and Controlled Affiliated Organizations.
- For the purpose of this policy only, the following definitions shall apply:
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Administrative Procedure
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Reporting Noncompliance
- Employees may report, without fear of retaliation, activity inconsistent with the policy prohibiting trafficking by contacting the University's Employee Reporting hotline at 1-844-724-5631 or via the , or the Global Human Trafficking Hotline at 1-844-888-FREE or via email at help@befree.org. All hotlines allow anonymous reporting as permitted by Applicable Law.
- Additional information about trafficking in persons and examples of awareness programs can be found at the website for the U.S. . For questions related to this policy as it pertains to human trafficking, please contact the Office of the General Counsel for the University.
- If the University receives credible information regarding a violation of this policy, the University will comply with all reporting and notification requirements of the Applicable Laws and will fully cooperate with any federal investigation into such allegations.
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Applicable Laws And Additional Resources
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Revision Dates
- August 22, 2023 (maintenance updates only)
- December 16, 2024