THE UNIVERSITY OF PENNSYLVANIA’S NOTICE REGARDING U.S. GOVERNMENT POLICY AGAINST HUMAN TRAFFICKING AND FORCED LABOR
The U.S. 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”), the University of Pennsylvania is obligated to inform its employees, agents, independent contractors and subrecipients performing awards, regarding the U.S. government’s policy. The University of Pennsylvania 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 foreign, U.S., state, and/or local laws.
What is Human Trafficking?
Human trafficking (or “trafficking in persons” as used in the U.S. government policy) 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, and inducing a commercial sex act by force, fraud, or coercion, or in which the person induced to perform a commercial sex act is under 18 years old. (Definitions of other relevant terms used in the policy are set forth in the U.S. government’s regulations implementing its policy, available at 2 C.F.R. § 175.15 for grants and cooperative agreements and 48 C.F.R. § 52.222-50 for federally-funded contracts.)
What is Prohibited?
The University, its employees, agents, and independent contractors, and its subrecipients of federal funds (and their respective employees), are prohibited from the following:
Responsibilities of the Principal Investigator or Project Director (“PI”)
It is primarily the responsibility of the PI who receives the award to ensure compliance with the U.S. government policy and to take the actions outlined below. Specifically, the PI and his/her Business Administrator shall:
In addition, if the federal award is a contract (i.e., not a grant or cooperative agreement), the PI and his/her Business Administrator also shall:
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. For such contracts and subcontracts, the PI, with assistance from his/her Business Administrator and the University’s Office of Research Services, is responsible for creating a compliance plan specific to the project and local circumstances that complies with the federal requirements. In addition, the PI will be required to make annual certifications to research administration for the duration of the project, certifying that to the best of he PI’s knowledge and belief, none of the employees, agents, independent contractors, or subcontractors has been engaged in human trafficking, sex trafficking, forced labor, or other trafficking-related activities prohibited by the U.S. government policy, and that the PI has reported any known purported activities within the University. The University’s Office of Research Services maintains a template Compliance Plan to assist PIs and Business Administrators develop any required plan tailored to the performance of the specific federal contract. The PI and his/her Business Administrator are responsible for sending the final, compliant Compliance Plan to the University Office of Research Services, and publicly posting the plan, if required by law or the award.
Always contact 911 or local law enforcement 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:
1- 215-P-COMPLY (1-215-726-6759) or www.upenn.edu/215pcomply (the University’s Reporting and Help Line)
University Associate Vice President & Associate Vice Provost for Research Services Executive Director of Penn Global Support Services
The University prohibits retaliation against an individual who makes a good faith report of suspected wrongful conduct pursuant to this policy and notice.
For More Information
Individuals may contact the Global Human Trafficking Hotline at 1-844-888-FREE or firstname.lastname@example.org. To read more about the U.S. government policy applicable to individuals working on grants and cooperative agreements, please review 22 U.S.C. §7104(g) and 2 CFR §175.15. To read more about the U.S. government policy applicable to individuals working on a federal contract, please review 48 CFR 52.222-50.