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The OMB Guidelines to Agencies on Governmentwide Debarment and Suspension (Nonprocurement) contained in 2 CFR Part 180 and the corresponding IMLS regulations contained in 2 CFR Part 3185 apply to IMLS grants. The Consultant, as a primary tier participant, is required to comply with 2 CFR Part 180 subpart C (Responsibilities of Participants Regarding Transactions Doing Business with Other Persons) as a condition of participation in the award. The Consultant is also required to communicate the requirement to comply with 2 CFR Part 180 subpart C (Responsibilities of Participants Regarding Transactions Doing Business with Other Persons) to persons at the next lower tier with whom the Consultant enters into covered transactions. C. Drug -Free Workplace The Consultant must provide a drug-free workplace by complying with the requirements in 2 CFR Part 3186 (Requirements for Drug -Free Workplace (Financial Assistance)). In particular, the Consultant must comply with drug-free workplace requirements in subpart B (or subpart C, if the recipient is an individual) of 2 CFR Part 3186. This includes, but is not limited to: malting a good faith effort, on a continuing basis, to maintain a drug-free workplace; publishing a drug-free workplace statement; establishing a drug- free awareness program for the Consultant's employees; taking actions concerning employees who are convicted of violating drug statutes in the workplace; and identifying (either at the time of application or upon award, or in documents the Consultant keeps on file in its offices) all known workplaces under the Consultant's Federal awards. D. Trafficking in Persons The Consultant must comply with Federal law pertaining to trafficking in persons. Under 22 U.S.C. §71.04(g), any grant, contract, or cooperative agreement entered into by Federal agency and a private entity shall include a condition that authorizes the Federal agency (IMLS) to terminate the grant, contract, or cooperative agreement if the Consultant, subgrantee, contractor, or subcontractor engages in trafficking in persons, procures a commercial sex act, or uses forced labor. 2 CFR Part 175 requires IMLS to include the following award term, which is made a partofthese General Terms and Conditions: a. Provisions applicable to a recipient that is a private entity 1. You as the recipient, your employees, subrecipients under this award, and subrecipients' employees may not - i. Engage in severe forms of trafficking in persons during the period of time that the award is in effect; H. Procure a commercial sex act during the period of time that the award is in effect; or