Guidance on USAID Anti-Trafficking Provisions and Compliance

Trafficking in persons is a global problem and millions of adults and children around the world are trafficked due to the rising demand for cheap labor and prostitution.  Winrock acknowledges that it works in environments that are at high risk for trafficking in persons and is taking steps to prevent it from occurring in our work and any of our work with local partners.

June 20, 2023

Winrock’s Combating Trafficking in Persons and Protection from Sexual Exploitation and Abuse Policy is here. It sets for the mandatory requirements for Winrock staff, Board members, volunteers, interns and fellows, and consultants.  It includes a clear statement of prohibited conduct and definitions of terms such as “trafficking in persons” and “commercial sex act.”

Guidance is provided below on complying with USAID anti-trafficking provisions.  

Requirements

USAID’s Mandatory Standard Provision M20. Trafficking in Persons  for grants and cooperative agreements, and Federal Acquisition Regulation (FAR) 52.222-50 Combating Trafficking in Persons for contracts establishes the requirements and prohibited conduct.

Under its USAID funding, Winrock is responsible for developing an award-specific compliance plan when the award is a grant or a cooperative agreement and the amount is over $500,000, and when the award is a contract and the amount is over $550,000, and the work is performed outside of the U.S. For these awards Winrock must:

• Provide a copy of the Compliance Plan to the Agreement or Contracting Officer upon request
• Post the useful and relevant contents of the plan or related materials on its project website (if one is maintained) and at the workplace
• Submit an annual “Certification regarding Trafficking in Persons, Implementing Title XVII of the National Defense Authorization Act for Fiscal Year 2013” to its Agreement Officer or Contracting Officer.

Subawardees including grantees, implementing partners, and subcontractors falling under the above criteria are required to implement a plan and submit a certification to Winrock on an annual basis.  

Responsibilities

Winrock’s project COP or project lead is responsible for ensuring that the program complies with USAID requirements, including 1) developing a project-specific Compliance Plan; 2) post the project-specific Compliance Plan on the internal project website ; and 3) ensuring that annual certifications are completed and submitted to Awards Management for concurrence and sent for internal approval per Winrock’s Scheduled Delegation of Authority(SDA) . A template for the Plan is found  on Winrock’s Awards Management intranet site.   

The Awards Management team ensures that applicable Anti-Trafficking requirements are incorporated into subaward agreements when required. The Awards Management Team is available to provide guidance on compliance requirements as needed.   

Certifications must be signed by the authorized individual specified in the Delegation of Authority (SDA).

Questions?

Questions regarding Winrock International’s Code of Conduct may be directed to the Risk and Compliance Office at AskEthics@winrock.org.

Questions regarding USAID Standard Provision Trafficking in Persons and award-specific compliance plans may be directed to the Awards Management Department at contracts@winrock.org.

References

Winrock International’s Code of Professional Conduct

Winrock’s Combating Trafficking in Persons and Protection from Sexual Exploitation and Abuse (PSEA) Policy

Prior revision March 2021.