Combating Trafficking in Persons


This policy applies to all Washington University in St. Louis employees, students,  trainees, agents, consultants, contractors, subcontractors, and subawardees and their employees.  This policy is intended to be in compliance with 48 C.F.R. § 52.222-50.

Policy Statement

Washington University in St. Louis has a zero tolerance policy on trafficking in persons.

Washington University in St. Louis, its employees, students, trainees, agents, contractors, subcontractors, and subawardees and their employees are prohibited from engaging in any of the following types of trafficking-related activities:

  1. Engaging in severe forms of trafficking in persons during the performance of any grant, cooperative agreement or contract. This includes the recruitment, harboring, transportation, provision, or obtaining of a person for labor services, 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 in which a commercial sex act is induced by force, fraud, or coercion, or in which the person induced to perform such act has not attained 18 years of age. 48 CFR § 52.222-50;
  2. Procuring commercial sex acts during the period of performance of any grant, cooperative agreement, or contract;
  3. Using forced labor in the performance of any grant, cooperative agreement or contract;
  4. Destroying, concealing, confiscating, or otherwise denying access by an employee to the employee’s identity or immigration documents, such as passports or drivers’ licenses, regardless of issuing authority;
  5. Using misleading or fraudulent practices during the recruitment of employees or offering of employment, such as failing to disclose, in a format and language understood by the employee or potential employee, basic information or making material misrepresentations during the recruitment of employees regarding the key terms and conditions of employment, including wages and fringe benefits, the location of the work, the living conditions, housing and associated costs (if employer or agent provided or arranged), any significant costs to be charged to the employee or potential employee, and, if applicable, the hazardous nature of the work; or using recruiters that do not comply with local labor laws of the country in which the recruiting takes place;
  6. Charging employees or potential employees recruitment fees as defined in 48 C.F.R. § 52.222-50;
  7. Failing to provide return transportation or pay for the cost of return transportation upon the end of employment, when required by law;
  8. Providing or arranging housing that fails to meet the host country housing and safety standards; and
  9. Failing to provide an employment contract, recruitment agreement, or other required work document in writing, when required by law or contract. These documents must be provided in a language the employee understands.
Compliance Plan

Pursuant to Part (h) of FAR 48 C.F.R. § 52.222-50, Washington University in St. Louis will create and maintain a Compliance Plan for programs that are funded by a federal contract where the estimated value of supplies, other than commercially available off-the-shelf items, acquired outside the United States, or services to be performed outside of the United States exceeding $550,000.

The Compliance Plan will include the following:

  1. An awareness program to inform employees about the government’s policy prohibiting trafficking-related activities;
  2. A process for employees to report, without fear of retaliation, any activity inconsistent with this policy, 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;
  3. A recruitment and wage plan that only permits the use of recruitment companies with trained employees, prohibits charging of recruitment fees to the employees or potential employees, and ensures that wages meet applicable host-country legal requirements, or explains any variance;
  4. A housing plan, if Washington University in St. Louis, or any of its contractors or subcontractors intends to provide or arrange housing, ensuring that the housing meets host-country housing and safety standards;
  5. Procedures for Washington University in St. Louis to prevent any of its contractors or subcontractors at any tier and at any dollar value from engaging in trafficking in persons (as described in this policy and applicable federal guidance or requirements). Qualifying programs must have procedures to monitor, detect, and terminate any agents, contractors, subcontractors, or subawardees that have engaged in any such activities.

Compliance Plans will be created in conjunction with the Office of the Vice Chancellor for Research when Part (h) of FAR 48 C.F.R. § 52.222-50 is applicable.


Any suspected violation of this policy must be reported immediately to the Office of University Compliance at 314-362-4998 or online.  Reports may also be made to the University Reporting Hotline online or by calling 1-844-484-5957

It may be required to report suspected violations to relevant law enforcement agencies, as well as appropriate federal, state, or funding agencies.

If you or someone else is in immediate danger, contact 911.

Washington University in St. Louis and its employees shall cooperate fully in providing reasonable access to allow other responsible enforcement agencies to conduct audits, investigations, or other actions to ascertain compliance with the Traffic Victim Protection Act (TVPA), Executive Order 13627, or any other applicable law or regulations establishing restrictions on trafficking in person, the procurement of commercial sex acts, or the use of forced labor.


Any violation of university policies will be addressed in accordance with applicable policies and procedures, which may include disciplinary actions up to and including termination of employment from the university.

In the case of a contractor, subawardee, or agent, violations of this policy may result in the termination of the contract.

Suspected violations of law will be referred to law enforcement and appropriate state, federal, and funding agencies and may result in criminal penalties.


Washington University in St. Louis prohibits retaliation against any individual who makes a good faith report of suspected wrongful conduct pursuant to this policy or related federal or state policies.

Reporting Resources
Related University Policies

Policy on Discrimination and Harassment

Youth Protection Policy