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Combating Trafficking in Persons

ASU’s Commitment to Combating Trafficking in Persons

Arizona State University is opposed to human trafficking and forced labor in any form. Human trafficking violates ASU and ABOR core values and commitment to Equity & Inclusion, in addition to being illegal under Arizona and U.S. law.

The U.S. Government has a zero-tolerance policy regarding Government employees, contractor personnel or their agents engaging in any form of trafficking in persons.

ASU complies with all applicable regulations regarding Combating Trafficking in Persons including, FAR 52.222-50 Combating Trafficking in Persons for Federally funded contracts and 2 CFR Part 175 Trafficking in Persons, for Federally funded Grants and Cooperative Agreements.


What is Human Trafficking?

Human trafficking is the recruitment, harboring, transportation, provision or obtaining of a person for labor or services through the use of force, fraud, or coercion for the purpose of subjection to involuntary servitude, peonage, debt bondage or slavery, and sex trafficking.

How is this relevant to ASU research projects?

When ASU receives a contract, grant or cooperative agreement from the Federal Government, ASU is required to prohibit its employees, subcontractors, and subrecipients from:

  • Engage is severe forms of trafficking in persons during the period of performance of the award.
  • Procuring a commercial sex act during the period of performance of the award.
  • Using forced labor in the performance of the award or Subawards under this agreement


Who is responsible for compliance?

The Principal Investigator

  1. Must notify all employees and volunteers 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. Such actions may include but are not limited to removal from the contract, reduction in benefits, or termination of employment.
  2. Immediately report any information they received from any source that alleges an employee or subcontractor employee has violated the policy.  
  3. Work with ASU administration to take any appropriate actions up to and including termination of employees or subrecipients that violate the policy.

ORSPA will notify subrecipients by flowing down the clause, as required, in subrecipient agreements.

Purchasing will notify any vendors by including the clause in purchase orders as needed.

ASU is required to report any violations of the clause to the sponsoring federal agency, which may result in sanctions by the agency.

Compliance Plan: Certain government funded research projects that include supplies to be acquired outside the United States or services to be performed outside the United States and have an estimated value over $500,000 may require implementation of a Compliance Plan. ORIA maintains the Compliance Plan template and can assist in putting the plan in place.


Reporting Violations
ASU employees are expected to report any credible information regarding human trafficking incidents by calling the ASU Hotline for Ethics and Compliance at 877-SUN-DEVIL (786-3385).

ASU employees can also call the Global Human Trafficking Resource Center Hotline at 1-888-373-7888 or send an email to



The Office of Research Integrity & Assurance is available to provide further assistance regarding these requirements and drafting a compliance plan. Please email with questions.

Further information regarding state laws and policies, including how to recognize the potential signs of human trafficking, can be found at the following:

National Human Trafficking Resource Center

State of Arizona Human Trafficking Website

FAR 52.222-50 Combating Trafficking in Persons

2 CFR part 175: Award Terms for Trafficking in Persons

22 USC Chapter 78: Trafficking Victims Protection

Executive Order 13627: Strengthening Protections against Trafficking In Persons In Federal Contracts

DHS Human Trafficking Training