Notice Regarding US Government Policy Against Human Trafficking and Forced Labor

The US government has adopted a policy prohibiting human trafficking, sex trafficking, forced labor and trafficking-related activities. As a recipient of federal funds from grants, cooperative agreements, and contracts (collectively, “awards”), Boston University is obligated to inform its employees, agents, independent contractors and sub-recipients performing awards about the US government’s policy.

Boston University opposes human trafficking, sex trafficking and forced labor, which are inherently harmful and contrary to the University’s core values, and which may violate applicable laws.

Trafficking in persons includes the recruitment, harboring, transportation, provision, or obtaining of persons through the use of force, fraud, or coercion for the purpose of subjection to involuntary servitude, peonage, debt bondage, or slavery.  It also includes sex trafficking, procurement of a commercial sex act and prostitution 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.

The University, its employees, agents, independent contractors and subcontractors (and their employees) that are sub-recipients of federal funds are prohibited from:

  • Engaging in human trafficking or sex trafficking, or procuring commercial sex acts, during the award period;
  • Using forced labor to perform the award;
  • Destroying, concealing, confiscating, or otherwise denying access to an individual’s identity or immigration documents;
  • Using misleading or fraudulent practices about the recruitment process for work on a project outside the U.S., such as failing to disclose, in a format and language accessible to the potential worker, key terms and conditions of the engagement, such as wages and fringe benefits, work location, living conditions, housing costs, and any hazardous nature of the work;
  • Using recruiters that do not comply with local labor laws in the countries in which recruiting takes place;
  • Charging recruitment fees to the individuals recruited to work on the award;
  • Providing or arranging housing that fails to meet host country housing and safety standards;
  • If required by law or contract, failing to provide an employment contract, recruitment agreement, or similar work paper in writing in the employee’s native language prior to the employee departing from his or her country of origin to work on the contract in another country; and
  • Under certain circumstances, failing to supply return transportation, or payment for return transportation, at the conclusion of the work, if the worker is not a national of the country in which the work occurs and was brought into the country to work on the federal award.

In addition, federal law requires that an anti-trafficking compliance plan be in place for any federal contract and subcontract where supplies are acquired outside the United States, or services will be performed outside the United States, and the estimated value of the supplies and/or services outside of the United States exceeds $500,000. The PI is responsible for developing any required compliance plan, with the assistance of the BU Sponsored Programs.

Reporting Resources

Always contact 911, local law enforcement or BUPD (3-2121) if you or someone else is in immediate danger. In addition, all University employees, agents and independent contractors must notify one of the following, if they become aware of any credible information alleging human trafficking, sex trafficking, forced labor, or other violations of the policy:

BU Sponsored Programs – 617-353-4356

BU Global Programs –  617-358-6350

BU Compliance Services – 617-358-8090

BU’s EthicsPoint hotline

The University prohibits retaliation against an individual who makes a good faith report of suspected wrongful conduct pursuant to this policy and notice.

In addition, individuals may contact or report concerns to the Global Human Trafficking Hotline at 1-844-888-FREE or help@befree.org or the Massachusetts Attorney General’s Human Trafficking Division.

 

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