I. Scope
This policy applies to all George Mason faculty, staff, students, faculty affiliates, visiting faculty, contractors, vendors, and authorized volunteers and agents working on covered federal contracts or grants (“hereinafter Covered Individuals and/or Entities”).
II. Policy Statement
George Mason is committed to promoting an environment free from human trafficking, sex trafficking, and forced labor. The university will provide the means for reporting suspected violations of such laws, as well as resources for support. Principal Investigators (PI’s) responsible for covered federal grants, cooperative agreements, or contracts (hereinafter “Federal Awards”) that meet the dollar thresholds set forth in this policy must adopt and implement the university’s Compliance Plan to Combat Human Trafficking.
III. Definitions
Coercion: means (1) threats of serious harm to or physical restraint against any person; (2) any scheme, plan, or pattern intended to cause a person to believe that failure to perform an act would result in serious harm to or physical restraint against any person; or (3) the abuse or threatened abuse of the legal process.
Commercial sex act: means any sex act on account of which anything of value is given to or received by any person.
Commercially available off-the-shelf (COTS) item: means any item of supply (including construction material) that is (i) a commercial product per Federal Acquisition Regulation 2.101; (ii) sold in substantial quantities in the commercial marketplace; and (iii) offered to the Government, under a contract or subcontract at any tier, without modification, in the same form in which it is sold in the commercial marketplace. COTS Items do not include those such as agricultural products and petroleum products.
Debt bondage: means the status or condition of a debtor arising from a pledge by the debtor of his or her personal services or of those of a person under his or her control as a security for debt, if the value of those services as reasonably assessed is not applied toward the liquidation of the debt or the length and nature of those services are not respectively limited and defined.
Forced Labor: means knowingly providing or obtaining the labor or services of a person (1) by threats of serious harm to, or physical restraint against, that person or another person; (2) by means of any scheme, plan, or pattern intended to cause the person to believe that, if the person did not perform such labor or services, that person or another person would suffer serious harm or physical restraint; or (3) by means of the abuse or threatened abuse of law or the legal process.
Human Trafficking: means the use of force, fraud, or coercion to obtain some type of labor or commercial sex act (22 U.S. Code Chapter 78).
Involuntary servitude: includes a condition of servitude induced by means of (1) any scheme, plan, or pattern intended to cause a person to believe that, if the person did not enter into or continue in such conditions, that person or another person would suffer serious harm or physical restraint; or (2) the abuse or threatened abuse of the legal process.
Recruitment fees: means fees of any type, including charges, costs, assessments, or other financial obligations, that are associated with the recruiting process, regardless of the time, manner, or location of imposition or collection of the fee.
Severe forms of human trafficking in persons: means 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; or 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.
Sex trafficking: means the recruitment, harboring, transportation, provision, or obtaining of a person for the purpose of a commercial sex act.
IV. Compliance
A. U.S. Government Policy: Prohibited Activities
All Covered Individuals and/or Entities must be aware of the United States Government’s Policy Prohibiting Trafficking in Persons and, per that policy, shall not—
- Engage in Severe Forms of Trafficking in Persons during the period of performance of the contract;
- Procure Commercial Sex Acts during the period of performance of the contract;
- Use Forced Labor in the performance of the contract;
- Destroy, conceal, confiscate, or otherwise deny access by an employee to the employee’s identity or immigration documents, such as passports or drivers’ licenses, regardless of issuing authority;
- (i) Use 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 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;(ii) Use recruiters that do not comply with local labor laws of the country in which the recruiting takes place;
- Charge employees or potential employees Recruitment Fees;
- (i) Fail to provide return transportation or pay for the cost of return transportation upon the end of employment—
A. For an employee who is not a national of the country in which the work is taking place and who was brought into that country for the purpose of working on a U.S. Government contract or subcontract (for portions of contracts performed outside the United States); or
B. For an employee who is not a United States national and who was brought into the United States for the purpose of working on a U.S. Government contract or subcontract, if the payment of such costs is required under existing temporary worker programs or pursuant to a written agreement with the employee (for portions of contracts performed inside the United States); except that—
(ii) The requirements of paragraphs (b)(7)(i) of this clause shall not apply to an employee who is—
A. Legally permitted to remain in the country of employment and who chooses to do so; or
B. Exempted by an authorized official of the contracting agency from the requirement to provide return transportation or pay for the cost of return transportation;
(iii) The requirements of paragraph (b)(7)(i) of this clause are modified for a victim of trafficking in persons who is seeking victim services or legal redress in the country of employment, or for a witness in an enforcement action related to trafficking in persons. The contractor shall provide the return transportation or pay the cost of return transportation in a way that does not obstruct the victim services, legal redress, or witness activity. For example, the contractor shall not only offer return transportation to a witness at a time when the witness is still needed to testify. This paragraph does not apply when the exemptions at paragraph (b)(7)(ii) of this clause apply;
8. Provide or arrange housing that fails to meet the host country housing and safety standards; or
9. If required by law or contract, fail to provide an employment contract, recruitment agreement, or other required work document in writing. Such written work document shall be in a language the employee understands. If the employee must relocate to perform the work, the work document shall be provided to the employee at least five days prior to the employee relocating. The employee’s work document shall include, but is not limited to, details about work description, wages, prohibition on charging recruitment fees, work location(s), living accommodations and associated costs, time off, roundtrip transportation arrangements, grievance process, and the content of applicable laws and regulations that prohibit trafficking in persons.
B. Reporting Suspected Prohibited Activity
Covered Individuals and/or Entities who become aware of potential violations of the Government’s policy as set forth above must report suspected activity to:
The Office of Institutional Compliance [email protected]
All reports may be made free from fear of retaliation
V. Additional Resources
| Organization | Contact Information |
| Human Resources – Employee Relations | Support Resources Website
Call: [email protected] |
| Title IX Coordinator | Call: 703-993-8730
Email: [email protected] |
| GMU Police and Public Safety | Emergency – 911
Non-Emergency – 703-993-2810 TDD/TTY – (703) 993-2817 Anonymous Tip Phone Line – 703-993-4111 |
| Virginia Victims Assistance Network | Call: 833-INFO4HT
Email: [email protected] |
| National Human Trafficking Resource Center | Call: 1-888-373-7888 Text: 233733 TTY: 711 Chat: www.humantraffickinghotline.org/en/chat Email: [email protected] |
| Global Human Trafficking Hotline | Call: 844-888-FREE |
VI. Required Compliance Plan to Combat Human Trafficking
In addition to compliance with the foregoing policy provisions, the Principal Investigator (PI) for the Federal Award must adopt and implement George Mason’s Compliance Plan to Combat Human Trafficking, and must incorporate the Plan in federal subawards, if the following criteria are met:
- Federal grants or cooperative agreements where the estimated value of services to be performed outside of the United States exceeds $500,000; or
- Federal contracts for supplies (other than Commercially Available Off-the-Shelf Items), or contracts for services, which are purchased or performed outside of the United States, as applicable, and the value of which exceeds $550,000.
The Office of Sponsored Programs (OSP) will notify the PI for the Federal Award of the requirement to implement the Compliance Plan.
The PI for the Federal Award is responsible for adopting and implementing the Compliance Plan to Combat Human Trafficking, communicating the Plan to all Covered Individuals and/or Entities working on the Federal Award, monitoring for adherence to the Plan, taking action in response to violations, notifying OSP immediately upon discovery of suspected violations, and providing OSP with necessary certifications regarding the Plan.
VII. Dates
A. Effective Date
This policy will become effective upon the approval of the Executive Vice President for Strategic Initiatives and the Provost and Executive Vice President.
B. Date of Most Recent Review:
N/A
VIII. Timetable for Review
The policy and related procedures and documents shall be reviewed annually or as needed.
IX. Signatures
Approved:
_________________________________
Kenneth D. Walsh
Chief of Staff and Executive Vice President for Strategic Initiatives
_________________________________
James S. Antony
Provost and Executive Vice President
Policy Approved: April 29, 2025
Page last updated: May 17, 2025