Arizona State University’s commitment to combating trafficking in persons

Arizona State University (ASU) is firmly opposed to human trafficking and forced labor in any form. Human trafficking violates ASU’s and the Arizona Board of Regents’ core values of equity, inclusion, and integrity. It is also a crime under Arizona and U.S. law.

The U.S. government enforces a zero-tolerance policy prohibiting government employees, contractor personnel, or their agents from engaging in trafficking in persons. ASU complies with all federal regulations, including:

  • FAR 52.222-50: Combating Trafficking in Persons (federally funded contracts)
  • 2 CFR Part 175: Trafficking in Persons (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 using force, fraud or coercion for the purpose of subjection to involuntary servitude, peonage, debt bondage or slavery and sex trafficking.

Relevance to ASU research projects

When ASU receives a contract, grant or cooperative agreement from the federal government, ASU is required to prohibit its employees, subcontractors, and subrecipients do not:

  • Engage in any forms of trafficking in persons during the period of performance of the award.
  • Procure commercial sex acts during the period of performance of the award.
  • Use forced labor in the the execution of the award or subawards.

Responsibilities for compliance

Principal investigators (PIs) must:

1. Develop and implement a compliance plan, if required by the sponsor.

2. Notify all employees and volunteers working under the award of the U.S. government’s zero-tolerance policy and the consequences of violations (e.g., removal from the award, reduction in benefits, or termination).

3. Immediately report allegations of trafficking violations by employees or subcontractors.

4. Work with ASU administration to take appropriate action, up to and including termination of employees or subrecipients.

ASU administrative roles

  • Research Operations: Flows down the required clause to subrecipient agreements.
  • Purchasing: Includes the clause in purchase orders when applicable.
  • ASU Administration: Reports violations to the sponsoring federal agency. Violations may result in sanctions by the agency.

Compliance plan

Certain federally funded projects may require a compliance plan if they:

  • Involve supplies acquired outside the United States or services performed internationally, and
  • Have an estimated value of over $550,000.

A Compliance plan template is available here.

Reporting violations

ASU employees are required to report any credible information regarding human trafficking. Reports can be made through:

Resources

National Human Trafficking Resource Center – Assistance and resources for victims of trafficking.

State of Arizona Human Trafficking Website – Arizona-specific laws and resources.

FAR 52.222-50 Combating Trafficking in Persons – Federal contracting requirements.

2 CFR part 175: Award Terms for Trafficking in Persons – Federal award terms addressing trafficking in persons.

22 USC Chapter 78: Trafficking Victims Protection – Federal protections for trafficking victims.

Executive Order 13627: Strengthening Protections against Trafficking In Persons In Federal Contracts – Strengthening protections against trafficking in federal contracts.

DHS Human Trafficking Training – Awareness training for federal award recipients.

Research Compliance: Contact Research Compliance for questions or assistance.