The University of Alabama (UA) is opposed to human trafficking and forced labor in any form. Human trafficking violates UA’s core values and commitment to equity and inclusion, in addition to being illegal under Alabama and U.S. Law.

The U.S. Government has a zero-tolerance policy regarding Government employees, contractor personnel or their agents engaging in any form of trafficking in persons.

UA complies with all applicable regulations regarding Combating Trafficking in Persons, including FAR 52.222-50 Combating Trafficking in Persons for Federally funded contracts and 2 CFR Part 175 Trafficking in Persons, for Federally funded Grants and Cooperative Agreements.

What is Human Trafficking?

Human trafficking is the recruitment, harboring, transportation, provision or obtaining of a person for labor or services through the use of force, fraud, or coercion for the purpose of subjection to involuntary servitude, peonage, debt bondage or slavery, and sex trafficking. (Adapted from FAR 52.222-50(a))

How is this relevant to UA?

Under federal regulations, UA is required to notify its employees and agents of the United States government’s policy prohibiting trafficking in persons, as described above.  In the context of a federally sponsored research project, examples of trafficking can include:

  • Engaging in severe forms of trafficking in persons during the period of performance of the award.
  • Procuring a commercial sex act during the period of performance of the award.
  • Using forced labor in the performance of the award or sub-awards.
  • Destroying, concealing, confiscating, or otherwise denying access by an employee to his or her identity or immigration documents in the performance of the award or sub-award.
  • Using misleading or fraudulent practices during the recruitment of employees, such as failing to disclose key terms and conditions of employment (e.g., wages and fringe benefits, location of work, living conditions, housing and associated costs)

Who is responsible for compliance?

According to FAR 52.222-50(c), the Principal Investigator:

  1. Must notify all employees and volunteers working under the award of the U.S. Government’s zero tolerance policy regarding trafficking in persons and the actions that will be taken against its employees or subrecipients for violation of this policy. Such actions may include but are not limited to: removal from the contract, reduction in benefits, or termination of employment.
  2. Immediately report any information they received from any source that alleges an employee or subcontractor employee has violated the policy.
  3. Work with UA administration to take any appropriate actions up to and including termination of employees or subrecipients that violate the policy.
  4. Certain government funded research projects that include supplies to be acquired outside the United States or services to be performed outside the United States and have an estimated value over $550,000 may require implementation of a Compliance Plan. UA maintains the Compliance Plan template and can assist in putting a specific plan in place.

Office of Sponsored Programs (OSP) will notify subrecipients by flowing down the clause, as required, in subrecipient agreements.

Procurement will notify any vendors by including the clause in purchase orders as needed.

UA is required to report any violations of the clause to the sponsoring federal agency, which may result in sanctions by the agency.

Reporting Violations

UA employees are expected to report any credible information regarding human trafficking incidents to The University of Alabama System Hotline.

UA employees can also call the Global Human Trafficking Resource Center Hotline at 1-888-373-7888.  Additional options for contact via chat, text or to make a report online are available at the National Human Trafficking Hotline.

Resources

Further information regarding laws and policies, including how to recognize the potential signs of human trafficking, can be found at the following: