Combating Human Trafficking in Global Research Policy

University Policy

Title

University of North Carolina at Chapel Hill Policy on Combating Human Trafficking in Global Research

Introduction

Purpose

The University of North Carolina at Chapel Hill ("University" or "UNC-Chapel Hill") is committed to combating Human Trafficking. Federal law mandates that federal contractors and subcontractors maintain an anti-trafficking compliance program to qualify for certain federal funds and grants. This policy establishes a compliance plan and reporting requirements that meet federal standards. This policy does not supersede the Equal Opportunity and Compliance Office's Policy on Prohibited Discrimination, Harassment and Related Misconduct Including Sex-Based Harassment, Sexual Assault, Interpersonal Violence and Stalking, which applies to all campus activities, but rather applies federal research requirements as applicable.

This policy reflects the University's mission to advance a safe and ethical environment.

Scope

This policy applies to every person who completes work on behalf of UNC-Chapel Hill, including all:

  • employees,
  • students,
  • affiliates,
  • subcontractors,
  • subrecipients,
  • and vendors'
    • employees,
    • labor recruiters,
    • brokers, and
    • other agents.

Policy

Policy Statement

The University prohibits Human Trafficking in any form, reports allegations of Human Trafficking, and maintains a compliance plan to prevent the use of Forced Labor in operations and ensure compliance with federal contracts and awards.

Requirements for Federal Contracts and Awards

Federal Acquisition Regulations (FAR) and other grant or award terms may require additional safeguards against Human Trafficking.

FAR 52.222-50 expressly prohibits:

  • Forced Labor and Human Trafficking
  • Procurement of commercial sex
  • Obstruction of identity of immigration documents
  • Illegal recruiting fees, failure to provide return transportation, and providing unsafe housing.

Reporting Requirements

The University reports all credible allegations of violations of anti-trafficking requirements to the relevant sponsoring federal agency, with timely and complete information. The University is committed to full cooperation with federal agencies to combat Human Trafficking.

Any person who completes work on behalf of UNC-Chapel Hill must report credible violations of this policy to:

  • Principal Investigator (as applicable),
  • Title IX Coordinator,
  • Equal Opportunity and Compliance Office, and
  • UNC Police.

The Principal Investigator must report credible violations to the Equal Opportunity and Compliance Office and to the Assistant Vice Chancellor for Research Compliance to coordinate communications with federal sponsors.

Compliance Plan

Research Compliance Services maintains a standard Anti-Human Trafficking Compliance Plan.

If needed, Research Compliance Services can create a tailored compliance plan in coordination with the Office of Sponsored Programs, Procurement, and Principal Investigators.

Definitions

Human Trafficking: The Trafficking Victims and Protections Act of 2000 and its subsequent reauthorizations define two primary forms of human trafficking: sex trafficking and forced labor.

  • Sex Trafficking: The recruitment, harboring, transportation, provision, obtaining, patronizing, or soliciting of a person for the purpose of a commercial sex act in which a commercial sex act is induced by force, fraud, or coercion, or in which the person induced to perform such act has not attained 18 years of age. See 22 U.S.C. § 7102(11)(A).
  • Forced Labor: 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. See 22 U.S.C. § 7102(11)(B).

Related Requirements

External Regulations

Resources

  • If you need immediate assistance, call 911.
  • If you are not in immediate danger, call the Equal Opportunity and Compliance (EOC) Office at 919-966-3576 during normal business hours.
  • Reports may also be made through the Global Human Trafficking Hotline (1-844-888-FREE or help@befree.org).
  • Reports may also be made to UNC-Chapel Hill's EOC Office regarding an incident of sexual harassment, sexual assault, or sexual exploitation, which includes prostitution of an individual. The EOC Office also addresses incidents of dating or domestic violence and stalking.
  • Reports may also be made to UNC-Chapel Hill's Office of Human Resources, Senior Director of Employee and Management Relations.

Contact Information

Primary Contact

Name: Quinton Johnson

Email: quinton@unc.edu