Notice Regarding U.S. Government Policy Prohibiting Human Trafficking and Forced Labor

The U.S. government has adopted a policy prohibiting human trafficking in persons and trafficking-related activities. As an entity that has received U.S. government grants and contracts, Northeastern University must notify the university community about this government policy.

Human trafficking can be classified as the recruitment, harboring, transportation, provision, or obtaining of persons using force, fraud, or coercion for the purposes of subjection to involuntary servitude, peonage, debt bondage, slavery, or sexual acts (which is also known as sex trafficking).

Forced labor can include threats of serious harm or physical restraint against a person if the person did not perform certain labor or services.
The U.S. government’s policy prohibiting trafficking in persons is as follows:

Contractors, including Northeastern University contractors, employees, and agents, shall not:

(1) Engage in severe forms of trafficking in persons during the period of performance of the contract;
(2) Procure commercial sex acts during the period of performance of the contract;
(3) Use forced labor in the performance of the contract;
(4) 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;

(5) (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 recruiting takes place;

(6) Charge employees or potential employees recruitment fees;

(7) (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 U.S. 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).

(ii). The requirement of section (7)(i) of this clause shall not apply to an employee who is:

a. Legally permitted to remain in the country of employment and 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 section (7)(i) 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 section (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 documents 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

Northeastern University forbids human trafficking, sex trafficking, forced labor, or any action that violates the U.S. government’s policy prohibiting trafficking in persons. Any employee, agent, independent contractor, or sub-recipient who violates the U.S. government’s policy prohibiting trafficking in persons may face removal from the contract, reduction in benefits, termination of employment or other disciplinary action.

Reporting Incidents or Policy Violations
Reporting incidents or policy violations:

It is crucial to call local law enforcement if you or someone else are in immediate danger. All university employees and contractors must notify Global Safety Operations Systems if they become aware of or witness anything related to human trafficking, sex trafficking, or forced labor at:

Global Safety Operations System: (+1) 617.373.5000