Anti-Trafficking Compliance Plan
Commitment to Combating Trafficking in Persons
The University of Nebraska at Omaha (UNO) is opposed to human trafficking and forced labor in any form. Human trafficking violates UNO's core values and commitment to equity and inclusion, in addition to being illegal under Nebraska 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.
UNO 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 UNO’s research projects?
When UNO receives a contract, grant or cooperative agreement from the Federal Government, UNO is required to prohibit its employees, subcontractors, and subrecipients from:
1. Engaging in severe forms of trafficking in persons during the period of performance of the award.
2. Procuring a commercial sex act during the period of performance of the award.
3. Using forced labor and specific acts that support or advance trafficking in the performance of the award or subawards under this agreement.
Federal Agencies may terminate awards without penalty if violations occur. 2 CFR Part 175 -- Award Term for Trafficking in Persons
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 UNO 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.
Office of Research and Creative Activity (ORCA) will notify subrecipients by flowing down the clause, as required, in subrecipient agreements.
Purchasing will notify any vendors by including the clause in purchase orders as needed.
UNO is required to report any violations of the clause to the sponsoring federal agency, which may result in sanctions by the agency.
Reporting Violations
UNO employees are expected to report any credible information regarding human trafficking incidents by clicking here https://www.unomaha.edu/report-a-concern/index.php or via phone at 402-554-2911. UNO employees can also call the Global Human Trafficking Resource Center Hotline at 1-888-373-7888 or send an email to help@befree.org.
Resources
Research Compliance is available to provide further assistance regarding these requirements and drafting a compliance plan. Please email with questions to researchcompliance@unomaha.edu.
Further information regarding state laws and policies, including how to recognize the potential signs of human trafficking, can be found at the following:
Nebraska | National Human Trafficking Hotline
Nebraska Legislature Nebraska Revised Statute 28-830, et al
FAR 52.222-50 Combating Trafficking in Persons
2 CFR Part 175: Award Terms for Trafficking in Persons
22 USC Chapter 78: Trafficking Victims Protection
Executive Order 13627: Strengthening Protections against Trafficking In Persons In Federal Contracts
Department of Homeland Security (DHS) Human Trafficking Training Program