Combatting Trafficking in Persons
Primary Guidance To Which This Policy Responds
Columbia University condemns all forms of human trafficking and complies with all regulations regarding human trafficking, including FAR 52.222-50 Combatting Trafficking in Persons.
Who is Governed by This Policy
All University employees, contractors and agents of the University.
Who Should Know This Policy
All University employees, contractors and agents of the University, especially those working on federally sponsored research projects.
Human trafficking is defined as the act of recruiting, harboring, transporting, providing or obtaining a person for labor services or commercial sex acts through force, fraud, or coercion (including any commercial sex act involving a minor), for the purpose of exploitation, involuntary servitude, peonage, debt bondage or slavery.
Under federal regulations, the University is required to notify its employees and agents of the United States government policy prohibiting trafficking in persons, as described above. In the context of a federally sponsored research project, examples of trafficking include:
- engaging in trafficking in persons during the performance of the award;
- procuring a commercial sex act during the performance of the award;
- using forced labor during the performance of the award;
- destroying or denying access by an employee to his, her or their identity or immigration documents;
- using misleading or fraudulent practices during the recruitment of employees, such as failing to disclose key terms or conditions of employment (e.g., wages and benefits, the location of work, any costs to be charged to the employee or, if applicable, the hazardous nature of the work);
- using recruiters that do not comply with the local labor laws of the country in which the recruiting takes place; and
- charging employees recruiting fees.
University employees are to report to the Compliance Hotline at [email protected] or (866)-627-3768, or their superior, any information that comes to their attention regarding human trafficking.
Any employee found to be engaging in prohibited activities under this policy is subject to immediate discipline, up to and including termination.
Please visit the National Trafficking Resource Center https://humantraffickinghotline.org/ for more information.
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