Compliance Plan for Combating Trafficking In Persons

Compliance Plan

The US policy regarding Combating Trafficking in Persons is implemented through Federal Acquisition Regulations (FAR) and Defense Federal Acquisition Regulations Supplement (DFARS) provisions, which accompany certain Federally funded grants and contracts to NC State.  Specifically FAR 52.222-50, Combating Trafficking in Persons, requires that a Compliance Plan must be maintained for the duration of the performance of the contract, for any portion of the contract that (a) Is for supplies, other than commercially available off-the-shelf items, acquired outside the United States, or services to be performed outside the United States; and (b) Has an estimated value that exceeds $550,000.

At a minimum, the compliance plan must include the following:

• An awareness program to inform all employees, agents, and subcontractors engaged in the performance of work under the contract at all project tiers and dollar values of
• The U.S. Government’s policies prohibiting human trafficking and trafficking-related activities;
• The prohibited activities; and
• The disciplinary actions that may result for individuals acting in violation of the policy.
• Reporting resources and processes for employees to report suspected violations of the policy, without fear of retaliation, including a means to make available to all employees the hotline phone number of the Global Human Trafficking Hotline at 1-844-888-FREE and its email address at help@befree.org. 
• A recruitment and wage plan that requires partnership with recruitment companies that have trained employees, prohibits charging recruitment fees to the employee or potential employee, and ensures wages meet applicable host-country legal requirements.
• Procedures to prevent agents and subcontractors at all project tiers and dollar values from engaging in human trafficking and trafficking-related activities and to monitor, detect, and terminate any employees, agents, or subcontractors who have engaged in such activities.

Who is responsible for compliance?

Prior to the execution of an agreement subject to the Compliance Plan requirement, the Director of Sponsored Programs and the Director of Research Compliance will meet with the  Principal Investigator and the College Research Office to explain the obligations.

Sponsored Programs and Regulatory Compliance Services (SPARCS)

SPARCS is responsible for:

• obtaining PI signature on the Compliance Plan prior to execution of the agreement and noting the requirement within the Notice of Award.
• obtaining subrecipient signature on the Compliance Plan prior to execution of the subcontract. 
• notifying subrecipients of the requirement by flowing down the clause, as required, in subcontracts.

Principal Investigator (PI)

The PI is responsible for the implementation of the Compliance Plan, including:

• notifying all employees, consultants, and vendors working under the award of the United States 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, including but not limited to removal from the contract, reduction in benefits, or termination of employment.
• distributing the Compliance Plan to all employees, consultants, and vendors working under the award prior to the performance of the project and obtain appropriate certifications annually thereafter.
• immediately reporting any information received from any source that alleges an employee or subcontractor employee has violated the policy.  
• working with NC State administration to take any appropriate actions up to and including termination of employees or subrecipients that violate the policy.

College Research Offices (CRO)

CROs are responsible for: 

• including the Federal Prime Agreement in PO requests to the NC State Purchasing office.

Contracts and Grants (C and G)

C and G is responsible for: 

• obtaining annual certification from subrecipient during annual subaward audit process.

Reporting Violations 

Principal Investigators must immediately report any information they receive from any source that alleges an employee or subcontractor employee has violated the policy by calling (1-844-599-8786) or making a report to NC State’s EthicsPoint Hotline, and by calling the Global Human Trafficking Hotline at 1-888-373-FREE or sending an email to help@befree.org. 

Employees are expected to report any credible information of violations of this Compliance Plan and/or FAR 52.222-50(b), without fear of retaliation, by calling (1-844-599-8786) or making a report to NC State’s EthicsPoint Hotline, and by calling the Global Human Trafficking Hotline at 1-888-373-FREE or sending an email to help@befree.org.   Always contact 911 or local law enforcement if you or someone else is in immediate danger.