See UVM’s Combatting Human Trafficking Compliance Alert.

The United States Government has adopted a zero-tolerance policy regarding human trafficking. It is also illegal and subject to prosecution under both federal law and Vermont law.

This guidance has been developed to comply with applicable federal and state laws, regulations, and policies regarding combating human trafficking in research.

Human trafficking is defined as the act of recruiting, harboring, transporting, providing or obtaining a person for labor services or commercial sex acts through force, fraud, or coercion (including any commercial sex act involving a minor), for the purpose of exploitation, involuntary servitude, peonage, debt bondage or slavery.

In the context of a federally sponsored research, examples of human trafficking include:

• engaging in trafficking in persons during the performance of the award;
• procuring a commercial sex act during the performance of the award;
• using forced labor during the performance of the award;
• destroying or denying access by an employee to his, her or their identity or immigration documents;
• using misleading or fraudulent practices during the recruitment of employees, such as failing to disclose key terms or conditions of employment (e.g., wages and benefits, the location of work, any costs to be charged to the employee or, if applicable, the hazardous nature of the work);
• using recruiters that do not comply with the local labor laws of the country in which the recruiting takes place; and
• charging employees recruiting fees.

Federal Contracting:

• Federal Acquisition Regulations 52.222-50, Combating Trafficking in Persons
• Federal Acquisition Regulations 52.222-56, Certification Regarding Trafficking in Persons Compliance Plan

Federal Grants:

• Code of Federal Regulations Title 2, Subtitle A, Chapter I, Part 175: Award Term for Trafficking in Persons

Vermont Law:

• Vermont Statutes, Title 13, Chapter 60 

Additional Regulations:

• U.S. State Department Office to Monitor and Combat Trafficking in Persons website
• National Human Trafficking Resource Center website 

Combatting human trafficking in research applies to all University researchers, employees, students, volunteers, contractors, subcontractors, and sub-recipients who participate in federally funded research projects.

Principal Investigators (PIs) have several key responsibilities to ensure compliance with combating human trafficking under federally funded projects.

1. Notify Award Personnel of the Zero Tolerance Policy

• PIs should notify all individuals working on a federal funded research project, including volunteers, contractors, subcontractors, and sub-recipients of the U.S. Government’s zero-tolerance policy regarding human trafficking.
• PIs must also explain the consequences of violations, including but not limited to reporting  to authorities, removal from award activities, suspension or termination of employment.

2. Develop and Implement a Compliance Plan

• For federal grants. Prior to receiving a grant or cooperative agreement, if the estimated value of services required to be performed under the grant or cooperative agreement outside the U.S. exceeds $500,000, a recipient must certify that a compliance plan has been implemented to prevent human trafficking. For details see CFR Title 2, Subtitle A, Chapter I, Part 175.
• For federal contracts involving supplies to be acquired or services to be performed outside the U.S. exceeds $550,000, the contractor must certify that a compliance plan has been implemented to prevent human trafficking. For details see FAR 52.222-56.
• PIs at the time of a proposal preparation for a federal research project that requires a compliance plan should contact Research Integrity.
• A draft compliance plan template can be found on the SPA Forms Library.

• PIs must assist the University in certifying to the federal Grants and Contracting Officers that a compliance plan is implemented.
• Annual certifications may be required.
• Copies of the Compliance Plan must be made available upon request.

PIs and University employees who suspect violations, wrongdoing or have information or concerns with non-compliance with federal or state policies on human trafficking must report using any of the following:

• Immediate Danger: If you believe a crime is in progress or that someone is in immediate danger, call 9-1-1 or use UVM’s CATSafe app.
• Non-Emergency Situations: Report suspected cases of human trafficking to the Office of Compliance & Privacy Services via the HelpLine or see the website for Compliance Reporting.
• Vermont Human Trafficking Victim Services: State Resources

National Human Trafficking Hotline: 

• Email: help@humantraffickinghotline.org
• Phone: 1-888-373-7888
• Text: text HELP to 233733 (BEFREE)
• Online chat: www.humantraffickinghotline.org

Federal Contracting Notifications

Where federally funded projects are involved in any suspected violations or any credible information is received by the PI from any source that alleges violations of the U.S. Government’s zero tolerance policy, PIs must notify Research Integrity.

Research Integrity will notify the federal Grant or Contracting Officer and the agency Inspector General immediately.