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University of North Carolina Anti-Human Trafficking Commitment

UNC Chapel Hill’s Commitment to Combating Trafficking in Persons

UNC Chapel Hill (UNC) is opposed to human trafficking and forced labor in any form. UNC is committed to compliance with all applicable U.S. laws, regulations, and policies regarding combating trafficking in persons, including Federal Acquisitions Regulation (FAR) 52.222-50 Combating Trafficking in Persons and FAR 52.222-56 Certification Regarding Trafficking in Persons Compliance Plan for federally funded contracts; Title 2 of the Code of Federal Regulations (2 CFR) Part 175 Award Term for Trafficking in Persons for federally funded grants and cooperative agreements; and USAID’s Standard Provision M20 regarding Trafficking in Persons for U.S. Nongovernmental Organizations for USAID funded grants and cooperative agreements.

What is Human Trafficking?

The Trafficking Victims Protection Act of 2000 and its subsequent reauthorizations recognize and define two primary forms of human trafficking:

  • Sex trafficking is 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. (22 U.S.C. § 7102(11)(A)).
  • Forced labor 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. (22 U.S.C. § 7102(11)(B)).

Prohibition on Human Trafficking Related to UNC’s U.S. federal contracts and research projects

UNC, its employees, its subcontractors/subrecipients, vendors, and their respective employees, labor recruiters, brokers, or other agents, are prohibited from engaging in human trafficking or practices related to human trafficking (“Prohibited Activities”). Prohibited Activities include, but are not limited to:

  • Engaging in severe forms of trafficking in persons during the period of performance (federal contracts) or that the award is in effect (federal grants or cooperative agreements);
  • Procuring commercial sex acts during the period of performance (federal contracts) or period of time that the award is in effect (federal grants or cooperative agreements);
  • Using forced labor in the performance of the award or subawards;
  • Destroying, concealing, confiscating, or otherwise denying access by an employee to his or her identity or immigration documents;
  • Using misleading or fraudulent recruitment practices;
  • Using recruiters that do not comply with local labor laws;
  • Charging employees or potential employees recruitment fees;
  • Failing to provide return transportation or pay for the cost of return transportation for certain employees upon the end of employment if requested by the employee;
  • Providing or arranging housing that fails to meet the host country housing and safety standards;
  • If required by law or contract, failing to provide an employment contract, recruitment agreement, or other required work document in writing.

Reporting Requirement

UNC is required to report any violations of anti-trafficking requirements or credible information alleging human trafficking by an employee, subcontractor/subrecipient, vendor, or subcontractor/subrecipient or vendor employee, or their agent to the sponsoring federal agency, which may result in sanctions by the agency. UNC must also fully cooperate with federal agencies regarding alleged human trafficking conduct and related audits, investigations, or corrective actions. Cooperation includes providing timely and complete responses to requests for documents, providing reasonable access to facilities and staff to conduct audits, and protecting all employees suspected of being victims of or witnesses to trafficking-related activities.

Resources

  • If you are in need of immediate assistance, call 911.
  • If you are not in immediate danger, call the Equal Opportunity and Compliance Office during normal business hours at 919-966-3576.
  • 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’s Equal Opportunity and Compliance (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 should also be made to UNC’s Office of Human Resources, Sr. Director of Employee and Management Relations.

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

Compliance Plan for Combating Trafficking in Persons Overview

UNC provides a definition, in this resource, of prohibited activities related to human trafficking in compliance with federal prohibition of human trafficking.

Compliance Plan Requirement

FAR 52.222-50, Combating Trafficking in Persons (Nov 2021) and USAID Standard Provision M20 require that UNC have a compliance plan when certain contracting/award conditions are met. UNC’s Compliance Plan for Combating Human Trafficking applies to all awards that meet these conditions and can be found on UNC’s Research Compliance Service webpage. Additional measures must be implemented where the size and complexity of the award or the nature and scope of the activities to be performed under the award warrant it.

Who is responsible for anti-trafficking compliance at UNC?

Principal Investigator (PI):

  • Must notify all project personnel and volunteers working under the award of the U.S. Government’s zero tolerance policy regarding trafficking in persons, the requirement to notify immediately the PI, Title IX Coordinator, UNC Office of Human Resources (OHR), and UNC Police of any information received from any source that alleges human trafficking related activities, and the actions that will be taken against employees or subcontractors/subrecipients and vendors for violation of applicable anti-trafficking prohibitions;
  • Immediately report any information they received from any source that alleges an employee, subcontractor/subrecipient, vendor, or subcontractor/subrecipient or vendor employee has violated applicable anti-trafficking laws;
  • Work with UNC administration to take any appropriate actions up to and including termination of employees, subrecipients/subcontractors, or vendors that violate applicable anti-trafficking laws;
  • Provide a compliance plan tailored to the project as part of the proposal package, when required and where UNC’s Compliance Plan for Combating Human Trafficking is insufficient based on the size and complexity of the award of the activities to be performed thereunder.

Office of Sponsored Projects (OSP):

  • Notify subrecipients/subcontractors by flowing down applicable anti-trafficking requirements in subrecipient/subcontract agreements;
  • For funded grants and cooperative agreements, include in subawards a provision allowing UNC to terminate the agreement in the event of a human trafficking violation.

Purchasing:

  • Notify any vendor by including the relevant anti-trafficking requirements in purchase agreements as needed;
  • For funded grants and cooperative agreements, include in agreements under the award a provision allowing UNC to terminate the agreement in the event of a human trafficking violation.