45.25 - Combating Trafficking in Persons

Preamble: This document sets forth the policy governing University of Idaho activities in relation to U.S. human trafficking laws and the federal regulations which implement those laws.

Contents:

A. Policy
B. Procedures
C. Review of Policies and Procedures
D. Sanctions
E. Reporting of Violations and Protection of Whistleblowers
F. Contact Information

A. Policy. The University of Idaho supports and is committed to compliance with federal laws and regulations intended to combat trafficking in persons by recipients of federal grants and contracts, or their employees, subcontractors, or agents, including but not limited to: the Trafficking Victims Protection Act, §§22 U.S.C. 1701 et seq.; Federal Acquisition Regulations 48 C.F.R. § 52.222-50; and Defense Federal Acquisition Regulations, 48 C.F.R. § 252.22-7007; and Uniform Guidance, 2 C.F.R §§175.5 et seq.. No university employees, subcontractors, or agents working under federally funded grants, cooperative agreements, or contracts shall engage in or support prostitution, sex trafficking, forced labor, or similar acts prohibited by federal law or regulation.

B. Procedures. The University Office of Research Assurances shall assist Principal Investigators (PIs), other university employees, subcontractors, and agents in ascertaining and understanding applicable federal statutes and regulations for combating trafficking in human persons. The Office of Research Assurances shall be responsible for establishing procedures for implementing this policy and applicable federal statutes and regulations. Primary compliance responsibility in the conduct of research rests with the employee or subcontractor based on the guidance and assistance from the Office of Research Assurances, and as needed, the Office of General Counsel.

C. Review of Policies and Procedures. The Office of Research Assurances shall annually review this policy and the processes and all related procedures, recommending updates as necessary to comply with changes in federal human trafficking laws and/or their implementing regulations. Any changes to this policy shall be reviewed and approved by the Vice President for Research and Economic Development the Office of the General Counsel, and shall be available from the Office of Research Assurances.

D. Sanctions. The University may impose appropriate sanctions against employees or agents for violations of this policy. Such sanctions may include, but are not limited to, removal from the contract, reduction in benefits, or termination of employment, along with any other actions the University deems appropriate given the circumstances.

E. Reporting of Violations and Protection of Whistleblowers.

E1. Reporting. It is the responsibility of all employees, subcontractors, and subcontractor employees to report any suspected violations of this policy and/or federal laws and regulations on combating trafficking in persons. Within the University, reports of violations subject to this policy may be made to the Vice President for Research and Economic Development, the Director of the Office of Research Assurances, the Director of Internal Audit, or through the University Hotline at 800-775-1056 (See FSH 3290). 

E2. Protection of Whistleblowers. The University will not engage in retaliatory conduct, as defined in FSH 3810, against an employee as a reprisal for reporting, in good faith, a human trafficking violation that was committed by any person subject to this policy. (See FSH 3810).

C. Contact Information:

Office of the Vice President for Research and Economic Development
Phone: 208-885-6689

Office of Research Assurances
Phone: 208-885-6162
Email: ored-export@uidaho.edu

Office of Internal Audit
Phone: 208-885-2133
Email: white@uidaho.edu

University Hotline
800-775-1056

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