Commitment to Combating Trafficking in Persons

The Univesty of Colorado Boulder (CU) is opposed to human trafficking and forced labor in any form. Human trafficking violates CU's core values and commitment to equity and inclusion, in addition to being illegal under Colorado 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.

CU 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. Adapted from FAR 52.222-50(a)

How is this relevant to CU's research projects?

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

  1. Engaging in severe forms of trafficking in persons during the period of performance of the award.
  2. Procuring a commercial sex act during the period of performance of the award.
  3. Using forced labor in the performance of the award or subawards under this agreement.

Who is responsible for compliance?

According to FAR 52.222-50(c), the Principal Investigator:

  1. Must notify all employees and volunteers working under the award of the U.S. 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 CU administration to take any appropriate actions up to and including termination of employees or subrecipients that violate the policy.
  4. 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 $550,000 may require implementation of a Compliance Plan. OCG maintains the Compliance Plan template and can assist in putting the plan in place.

Office of Contracts and Grants (OCG) 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.

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

Reporting Violations

CU employees are expected to report any credible information regarding human trafficking incidents by clicking here CU Hotline EthicsPoint or via phone 800-677-5590. CU employees can also call the Global Human Trafficking Resource Center Hotline at 1-888-373-7888 or send an email to


OCG 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: