Combating Trafficking in Persons Compliance Plan


Updated July 2023

Buddhist Digital Resource Center, 210 South Street, 1st Floor, Boston MA 02111



BDRC has developed this Combating Trafficking in Persons Compliance Plan ("Plan") in accordance with the U.S. Government's zero-tolerance policy regarding trafficking in persons by government contractors and award recipients, as set out in FAR Subpart 22.17 and 52.222-50(h), and in USAID Standard Provision-Mandatory Reference for ADS Chapter 303 (provision M20) for U.S. Nongovernmental Organizations. 


The purpose of this Plan is to set out BDRC's policies and procedures for: (1) making BDRC employees and contractors aware of the conduct prohibited under BDRC policy and the Anti-Trafficking Provisions and the actions that may be taken against employees for violations; (2) employing fair recruitment, wage and housing practices; and (3) preventing prohibited trafficking activity by suppliers, subcontractors and subrecipients, and monitoring, detecting and terminating those who engage in such activities.



This Plan sets out BDRC's baseline standards for anti-trafficking in persons compliance and applies presumptively to all U.S. government contracts, subcontracts, cooperative agreements, awards and subawards. This Plan applies to all employees, contractors, Board of Directors, and others who represent or act for BDRC. ​​For purposes of this Plan, "employee" means an individual who is engaged in the performance of U.S. government awards or contracts as a direct employee, consultant, or volunteer of BDRC; "contractor" means contractors, vendors, suppliers, subcontractors and subrecipients of BDRC.


General Provision

All applicable parties defined above, must not engage in: (1) Trafficking in persons (as defined in the Protocol to Prevent, Suppress, and Punish Trafficking in Persons, especially Women and Children, supplementing the UN Convention against Transnational Organized Crime) during the period of performance of U.S. government awards or contracts; (2) Procurement of a commercial sex act during the period of performance of U.S. government awards or contracts; (3) Use of forced labor in the performance of performance of U.S. government awards or contracts


To minimize the risk of acts that directly support or advance trafficking in persons, BDRC employs a multifaceted approach to address the risk of human trafficking and related activities outlined below.


Recruitment and Wage Plan

BDRC prohibits the use of any misleading or fraudulent recruitment practices during the recruitment of employees or offering of employment to employees. BDRC employees must fully and accurately disclose, in a format and language accessible to the employee, all key terms and conditions of employment, including wages and benefits, work location, living conditions, housing and associated costs (where provided or arranged by BDRC), significant costs to be charged to the employee, and, if applicable, the hazardous nature of the work.


BDRC prohibits the use of recruiters that do not have trained employees, or that do not comply with all labor laws of the country where the recruitment takes place.


BDRC prohibits charging recruitment fees to any employee.


BDRC will pay to all employees wages that meet applicable host-country legal requirements, or will explain any variance.


Where required by law or contract, BDRC will provide to every employee an employment Handbook, contract, recruitment agreement, or other required work document, written in a language the employee understands, containing all required information about the terms of conditions of employment, which may include, by way of example, the work description, wages, work location, living accommodations and associated costs, time off, transportation arrangements, grievance process, the content of applicable laws and regulations prohibiting trafficking in persons, and the prohibition on recruitment fees.


BDRC prohibits destroying, concealing, confiscating or otherwise denying access to any employee who is directly engaged in the performance of work under a Contract to the Employee's identity or immigration documents, such as passports or drivers' licenses, regardless of issuing authority;


BDRC will provide or pay the cost of return transportation at the end of employment for any employee who is not a national of the country where the work took place and was brought into that country by BDRC for purposes of working on a covered US Government contract or award.


BDRC will provide or pay the cost of return transportation at the end of employment for any employee who is not a US national and was brought into the US for purposes of working on a covered US Government contract or award, if payment of such costs is required by the employee or pursuant to a written agreement with the employee unless (a) the person is exempted from the requirement to provide or pay for such return transportation by the US Government contract or award; or (b) the employee is a victim of human trafficking seeking victim services or legal redress in the country of employment or is a witness in a human trafficking enforcement action.


Housing Plan 

In situations where BDRC provides housing to employees, the housing will meet host country housing and safety standards.


Contractors Compliance

All BDRC contractors, vendors, suppliers, subcontractors and subrecipients ("Contractors") must agree to comply with this Plan and all applicable Anti-Trafficking in Person Provisions. BDRC will include ​​language to that effect in all contracts, subcontracts and sub-agreements (" Contracts"), including inserting FAR 52.222-50, FAR 52.222-56 and USAID Standard Provisions where applicable.

All Contractors must have a compliance plan to prevent prohibited trafficking-related activities and to monitor, detect and terminate any of its contractors, consultants, suppliers, subcontractors or subrecipients engaging in prohibited trafficking-relating activities, and provide a copy of its plan to BDRC. A Contractor's compliance plan must meet the minimum requirements in the Anti-Trafficking Provisions and be appropriate to the size and complexity of the contract, subcontract or sub-agreement with BDRC and the nature of the activities to be performed under it.

Prior to the award of any Contract or subcontract, and on an annual basis thereafter, all Contractors must submit a certification to BDRC:

  • That the Contractor has implemented a compliance plan and has complied with its plan; 
  • That after conducting due diligence, to the best of the Contractor's knowledge and belief, neither it nor any of its employees, or its contractors, consultants, suppliers, subcontractors, subrecipients or their employees, have engaged in any prohibited trafficking-related activities, or if any abuses relating to prohibited trafficking-related activities have been found, Contractor has taken appropriate remedial and referral actions.

If any Contractor fails to comply with the Policy or applicable Anti-Trafficking Provisions, BDRC will take appropriate action to remediate the violation and prevent future violations, including, but not limited to:

  • Requiring the Contractor to remove an employee or agent from a project;
  • Requiring the Contractor to terminate its relationship with any contractor, consultant, supplier, subcontractor or subrecipient;
  • Suspending payments to Contractor until violation is remedied
  • Immediately terminating the Contractor Contract


Reporting Requirements and Procedure

All BDRC personnel are required to report any suspected trafficking- related activity or violation of this policy to BDRC, with the assurance that there will be no retaliation or other negative consequences for persons acting in good faith. Reports may be made to any BDRC Executive Director, or program manager and supervisor. Any BDRC program manager and supervisor who receives such a report is required to immediately forward the report to BDRC's Executive Director and the Board of Directors. In addition, BDRC personnel who believe they or others have been subjected to prohibited trafficking-related activities may report the activity as outlined above, or may contact the Global Human Trafficking Hotline at 1-844-888-FREE or, and the US National Human Trafficking Hotline at 1-888-373-7888 or text 233733.



If BDRC receives credible information from an employee report or any other source alleging prohibited trafficking-related activity, the BDRC Executive Director and the Board of Directors will conduct an investigation and report its findings and determine what, if any, remedial action is appropriate. The Board of Directors will also monitor BDRC management's implementation of such remedial action.


BDRC will immediately notify the Agreement officer and the appropriate agency Inspector General of the information received and any resulting remedial action taken. BDRC will cooperate fully with any US Government agencies responsible for any investigations, audits or corrective actions relating to trafficking in persons, including, but not limited to, providing timely and complete responses to document requests, and providing reasonable access to BDRC facilities and staff.


BDRC will protect all employees suspected of being victims of or witnesses to prohibited activities, prior to returning to the country from which the employee was recruited, and will not prevent or hinder these employees from cooperating fully with US government authorities.


Periodic Reassessment of the Plan

BDRC will periodically review and assess the internal controls ensuring compliance with this Plan. Modification of controls and measures will be implemented as required.


Employee Awareness 

BDRC will inform Employees about the Plan, including prohibited conduct, consequences of violations, and mechanisms to report suspected violations by posting relevant contents of this Plan, no later than the initiation of Contract performance, in its HandBook and in a shared Google Drive repository.