Anti-Human Trafficking Guidelines

University of Montana Anti-Human Trafficking Guidelines

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

UM 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.

How is this relevant to UM’s research projects?

When UM receives a contract, grant or cooperative agreement from the federal government, UM is required to prohibit its employees, sub-contractors, and sub-recipients from:

Engaging in severe forms of trafficking in persons during the period of performance of the award.

  1. Procuring a commercial sex act during the period of performance of the award.
  2. Using forced labor in the performance of the award or sub-awards under this agreement.

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 sub-recipients 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 the UM administration to take any appropriate actions up to and including termination of employees or sub-recipients 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. The plan must be appropriate to the size and complexity of the award and to the nature and scope of the activities, including the number of non-United States citizens expected to be employed. The plan must include, at the minimum, the following elements:
    1. An awareness program to inform employees about the trafficking related prohibitions included in this provision, the activities prohibited and the action that will be taken against the employee for violations.
    2. A reporting process for employees to report, without fear of retaliation, activity inconsistent with the anti-trafficking policy, including means to make available to all employees the Global Human Trafficking Hotline at 1-844-888-FREE and its e-mail address at help@befree.org.
    3. A recruitment and wage plan that only permits the use of recruitment companies with trained employees, prohibits charging of recruitment fees to the employee, and ensures that wages meet applicable host-country legal requirements or explain any variance.
    4. A housing plan, if UM or any sub-awardee intends to provide or arrange housing. The housing plan is required to meet any host-country housing and safety standards.
    5. Procedures for UM to prevent any agents or sub-awardee at any tier and at any dollar value from engaging in trafficking in persons activities. UM must also have procedures to monitor, detect, and terminate any agents or sub-awardee or sub-awardee employees that have engaged in such activities.

 

The Office of Sponsored Programs (OSP) will notify sub-recipients by flowing down the clause, as required, in sub-recipient agreements.

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

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

Procedures to Report Potential Human Trafficking

Always report emergency situations directly and immediately to 911!

If you believe you have information about a potential trafficking situation, please contact the National Human Trafficking Resource Center (NHTRC) using:

The toll-free hotline at (888) 373-7888. Specialists are available 24/7 to take reports of potential human trafficking. All reports are confidential and you may remain anonymous. Interpreters are available; or

Submit a tip through the NHRTC anonymous online reporting form.

The information you provide will be reviewed by NHTRC and forwarded to specialized law enforcement and/or service providers, as appropriate.

Potential human trafficking situations can also be reported to local law enforcement, the Montana Human Trafficking Hotline ((833) 406-STOP), or to the Montana University System Compliance Hotline.

 

Resources

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

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