Law360, New York (August 28, 2015, 12:02 PM EDT) -- Compliance officers and attorneys need to develop a working understanding of the term "credible information" as used in the Federal Acquisition Regulation (FAR) Combating Trafficking in Persons (CTIPs) clause in order to comply with the clause's requirement to report violations of CTIPs policy.[1] The CTIPs policy prohibits nine activities, including engaging in severe forms of CTIPs, procuring commercial sex acts, using forced labor, denying an employee access to his or her identity documents, using misleading or fraudulent recruitment practices, charging an employee a recruitment fee, failing to provide an employee return transportation home, providing inadequate housing and failing to provide an employee a copy of her or his employment contract.[2] An allegation of a violation of a CTIPs policy may arise through anonymous hotline complaints,[3] from foreign law enforcement,[4] from "walk-in" sources or through other means. It is critical that a government contractor compliance officer who reviews an allegation of a CTIPs policy violation be able to answer the title question: Is there "credible information" of a CTIPs violation?...