Anti-Trafficking (III.C.3)

Volume III: Ethics
Chapter C: Equal Opportunity
Responsible Executive: Vice President for Ethics and Compliance
Responsible Office: Sponsored Program Services
Date Issued: February 1, 2019
Date Last Revised: N/A

TABLE OF CONTENTS

Contacts
Statement of Policy 
Reason for This Policy
Individuals and Entities Affected by This Policy
Exclusions
Responsibilities 
Definitions (defined terms are capitalized throughout the document)
Related Documents, Forms and Tools
Website Address for This Policy
History and Updates
Appendix

CONTACTS

STATEMENT OF POLICY

Purdue University prohibits Human Trafficking (see Definitions). All faculty; staff; students; subawardees at any tier, their employers, labor recruiters, brokers, or other agents; consultants; vendors; contractors; and subcontractors are covered by this zero tolerance policy.

The following types of Human Trafficking-related activities are prohibited:

1. The procurement of a commercial sex act during the period of time that a grant contract or cooperative agreement is in effect.
2. The use of forced labor in the performance of a grant, contract or cooperative agreement.
3. Recruitment of a person for employment by means of materially false or fraudulent pretenses, representations or promises.
4. Destroying, concealing, removing, confiscating or otherwise denying an employee access to the employee’s identity and/or immigration documents.
5. Charging recruited employees placement or recruitment fees, or other fees that violate the laws of the country from which the employee is recruited.
6. For work performed outside the United States, failure to provide or pay for return transportation, if requested by an employee, upon the end of employment for an employee who is not a national of the country in which the work is being performed and who was brought to that country for the purpose of the contract or subcontract.
7. Providing or arranging housing that fails to meet the host country housing and safety standards.
8. Any other act that directly supports or advances Human Trafficking.

The University has in place a compliance program to prevent the activities described above for all contracts and subcontracts where the estimated value of supplies or services acquired or performed outside the United States exceeds $500,000.

All individuals and entities subject to this policy are expected to report suspected Human Trafficking activities in accordance with this policy and applicable laws and regulations. Purdue prohibits any retaliatory action against individuals who make a good faith disclosure of suspected Human Trafficking activities. Reports of potential and actual Human Trafficking situations involving funding also will involve coordination with the Office of the Executive Vice President for Research and Partnerships to ensure compliance with grant and contract requirements.

Violations of this policy may result in disciplinary action, including but not limited to removal from the contract or grant, other disciplinary actions, termination of employment, and other remedies imposed pursuant to federal contracting regulations.

REASON FOR THIS POLICY

The practice of Human Trafficking infringes on individual rights and is contrary to the values of the University. This policy defines Human Trafficking and the types of activities that are prohibited. It also ensures that federal requirements under the Federal Acquisition Regulation (FAR) Subpart 22.1703, Combating Trafficking in Persons, are met.

INDIVIDUALS AND ENTITIES AFFECTED BY THIS POLICY

1. All faculty, staff, and students and all campuses, colleges, schools, departments, offices and other units of the University.
2. All individuals and entities doing business with or on behalf of the University.

EXCLUSIONS

Payment or provision of transportation for an employee to return to the United States at the end of their employment under a contract or subcontract is not required if the employee is:

1. legally permitted to remain in the country of employment and chooses to do so, or
2. exempted from the transportation requirement by an authorized official of the contracting agency.

RESPONSIBILITIES

VPEC

• Provide oversight for this policy.

SPS

• Maintain and administer a compliance program that meets the requirements of the FAR Subpart 22.1703 for contracts and subcontracts where the estimated value of supplies or services acquired or performed outside the United States exceeds $500,000.
• Upon receipt of a report of Human Trafficking involving a funded project, report violations and actions taken to the funding agency to ensure compliance with grant and contract requirements.

Contractors and Subcontractors

• Develop compliance plans to ensure the requirements of this policy, related University procedures, and funding agencies are met.
• Verify all applicable staff have completed training outlined and identified as required in compliance plans.

All Faculty, Staff, and Students of the University and All Other Individuals and Entities Covered by this Policy

• Cooperate fully in providing reasonable access to contracting agencies and other responsible enforcement agencies to conduct audits, investigations or other actions to ascertain compliance with applicable anti-trafficking laws and regulations.
• Notify the University via the Purdue Hotline of any activities they suspect are related to or fit the definition of Human Trafficking.
• Contact local law enforcement or Child Protective Services if they suspect a minor is a victim of Human Trafficking.
• Complete training outlined and identified as required in applicable compliance plans.

DEFINITIONS

All defined terms are capitalized throughout the document. Additional defined terms may be found in the central Policy Glossary.

Human Trafficking
The act of recruiting, harboring, transporting, providing or obtaining a person for labor services 1) through force, fraud or coercion and 2) for the purpose of exploitation, involuntary servitude, peonage, debt bondage, slavery or commercial sex acts. Human Trafficking includes any commercial sex act involving a minor.

RELATED DOCUMENTS, FORMS AND TOOLS

FAR Subpart 22.1703, Combating Trafficking in Persons

Office of the Indiana Attorney General Human Trafficking webpage

Department of Homeland Security Blue Campaign: Human Trafficking 101 (PDF)

U.S. Department of State Human Trafficking Awareness Training: “Tip 101”

WEBSITE ADDRESS FOR THIS POLICY

www.purdue.edu/policies/ethics/iiic3.html  

HISTORY AND UPDATES

February 1, 2019: This is the first policy to address this issue. It incorporates guidance that was previously published on the SPS website.

APPENDIX

There are no appendices to this policy.