Compliance Plan for Combating Trafficking in Persons

Compliance Plan Requirement

FAR 52.222-50, Combating Trafficking in Persons (Nov 2021) and USAID Standard Provision M20 require that GW have a compliance plan when certain contracting/award conditions are met. GW’s universal Compliance Plan for Combating Trafficking in Persons applies to all awards that meet these conditions and can be found on the OSP SharePoint site (GW login required). Additional measures must be implemented where the size and complexity of the award or the nature and scope of the activities to be performed under the award warrant it.

Who is responsible for anti-trafficking compliance at GW?

Principal Investigator (PI)/Project Director (PD):

• Must notify all project personnel and volunteers working under the award of the U.S. Government's zero tolerance policy regarding trafficking in persons, the requirement to notify immediately the PI/PD or the Office of Ethics, Compliance, and Risk of any information received from any source that alleges human trafficking related activities, and the actions that will be taken against employees or subcontractors/subrecipients and vendors for violation of applicable anti-trafficking prohibitions;
• Immediately report any information they received from any source that alleges an employee, subcontractor/subrecipient, vendor, or subcontractor/subrecipient or vendor employee has violated applicable anti-trafficking laws;
• Work with GW administration to take any appropriate actions up to and including termination of employees, subrecipients/subcontractors, or vendors that violate applicable anti-trafficking laws;
• Provide a compliance plan tailored to the project as part of the proposal package, when required and where GW’s universal Compliance Plan for Combating Trafficking in Persons is insufficient based on the size and complexity of the award of the activities to be performed thereunder.

Office of Sponsored Projects (OSP):

• Notify subrecipients/subcontractors by flowing down applicable anti-trafficking requirements in subrecipient/subcontract agreements;
• For USAID-funded grants and cooperative agreements, include in subawards a provision allowing GW to terminate the agreement in the event of a human trafficking violation.

Purchasing:

• Notify any vendor by including the relevant anti-trafficking requirements in purchase agreements as needed;
• For USAID-funded grants and cooperative agreements, include in agreements under the award a provision allowing GW to terminate the agreement in the event of a human trafficking violation.