In my experience, I have found that there tends to be a disconnect in program implementation between those who are technical experts and those who actually administer the government contract.
Government (USG) officials, companies, and NGOs have expressed concern about the risk of Human Trafficking in global supply chains, including in federal contracts. Victims originate from almost every region of the world; the top three countries of origin of federally identified victims in fiscal year (FY) 2017 were the United States, Mexico, and the Philippines.
Human Trafficking or Trafficking in Persons (TIP) is defined in the Trafficking Victims Protection Act of 2000 (TVPA). It is about people being bought and sold as chattel, involving the acquisition of a human being through the use of force, fraud, or coercion for the purpose of exploiting the individual for profit through forced labor or prostitution. The USG efforts to combat such trafficking, also incorporated in the United Nation’s Sustainable Development Goal 8.7, are to prevent it, protect the victims, and prosecute the traffickers. A fourth “p”, involves “partnership” between the public and private sectors, with state and local organizations, and with survivors.
The annual State Department TIP Report classifies countries into tiers based on a government’s efforts to comply with the “minimum standards for the elimination of trafficking” found in TVPA. Although the U.S. is a Tier 1 country according to the 2017 TIP Report, it is also “a source, transit, and destination country for men, women, transgender individuals, and children— both U.S. citizens and foreign nationals—subjected to sex trafficking and forced labor. Trafficking occurs in both legal and illicit industries, including in commercial sex, hospitality, sales crews, agriculture, fishing, manufacturing, janitorial services, construction, restaurants, health and elder care, salon services, fairs and carnivals, peddling and begging, and domestic service.
The National Defense Authorization Act (NDAA) allows the USG to terminate a contract if the prime contractor or subcontractor commits acts that directly support or advance trafficking in persons, such as: confiscating an employee’s identity or immigration documents; offering employment using fraudulent or misleading pretenses; charging placement or recruitment fees; and providing housing that fails to meet the host country housing and safety standards.
Judicial reform programs might include capacity training on TIP, and it is important to understand how TIP issues can affect the federal contractor in its day-to-day business affairs.