1)  WGBH Respectful Workplace Policy which can be found at the following url: https://wiki.wgbh.org/x/9Nn-BQ ALREADY ON THE EXTERNAL WIKI 

2)  WGBH Drug-Free Awareness Program -  ALREADY ON THE EXTERNAL WIKI (checking online policy first - if the same, replace with a link)

Purpose and Goal

Our drug-free workplace program consists of:                     

A drug-free workplace policy that prohibits drug use in the workplace, including during working hours, while on GBH property, while conducting business on behalf of GBH, or while acting as a representative of GBH

• Employee education opportunities;
• Prevention tools;
• Manager training; and
• Employee assistance and treatment options.

Drug-Free Policy

As required by federal law, the unlawful manufacture, distribution, dispensation, possession, or use of a controlled substance is prohibited while on GBH premises and/or while conducting GBH business.  If you participate in any of these activities, you are subject to disciplinary action by GBH up to and including termination of employment.  Any employee who is convicted of a criminal drug violation in the workplace must notify the Foundation within five calendar days after such conviction.  The Foundation is required to report such information to the applicable federal government agency within ten days of receiving such notification.  The Foundation is also required, within 30 calendar days of receiving notice, to take appropriate personnel action against the employee, up to an including termination, or requiring the employee to participate satisfactorily in an appropriate drug abuse assistance or rehabilitation program.

Employee Education

To make sure that employees understand the danger of substance abuse and its impact, GBH has or will take several steps to educate employees about substance abuse:

• GBH maintains resources for employees to learn about substance abuse, and posts informative materials in areas frequented by employees;
• GBH plans to offer workplace seminars or other learning opportunities to employees concerning substance abuse; and
• GBH, through its partnership with St. Elizabeth’s Medical Center, provides employees the opportunity to participate in substance abuse programs offered by St. Elizabeth’s Hospital.

Prevention

Prevention is critical to ensuring employee safety and a drug-free workplace.  To prevent drugs in the workplace and minimize substance abuse, GBH provides employees several tools:

• Health insurance plans offered by GBH cover mental health, which includes counseling and other treatment options;
• Through GBH’s partnership with St. Elizabeth’s Medical Center, employees may participate in support groups and substance abuse programs that the hospital offers.

Manager Training

Managers can play a key role in helping prevent substance abuse by watching for signs that an employee may need help.  GBH is committed to providing training to managers to help them recognize behavior that may indicate substance abuse or that an employee is at risk and know how to help.

Employee Assistance, Treatment and Support

GBH recognizes that alcohol and drug abuse and addiction are treatable illnesses.  We also realize that early intervention and support improve the success of rehabilitation. To support our employees, we:

• Encourage employees to seek help if they are concerned that they or their family members may have a drug and/or alcohol problem;
• Encourage employees to utilize the services of qualified professionals in the community to assess the seriousness of suspected drug or alcohol problems and identify appropriate sources of help;
• Offer all employees assistance with alcohol and drug problems through the Employee Assistance Program (EAP);
• Allow the use of accrued paid leave while seeking treatment for alcohol and other drug problems;
• Offer employees health insurance plans that cover treatment for substance abuse;
• Offer employees the opportunity to participate in substance abuse and support programs offered by St. Elizabeth’s Medical Center through our partnership with it; and
• Treat information received by the Foundation through the drug-free workplace program as confidentially as practicable under the circumstances, restricting access to this information to those who have a legitimate need to know, in compliance with relevant laws and management policies.

Shared Responsibility

A safe and productive drug-free workplace is achieved through cooperation and shared responsibility.  Both employees and management have important roles to play.  As noted above, all employees are prohibited from reporting to work while their ability to perform job duties is impaired due to on- or off-duty use of alcohol or other drugs.  In addition, employees are encouraged to:

• Be concerned about working in a safe environment.
• Support fellow workers in seeking help.
• Use the Employee Assistance Program where appropriate.
• Report dangerous behavior to their supervisor.

It is the supervisor's responsibility to:

• Inform employees of the drug-free workplace policy.
• Observe employee performance.
• Investigate reports of dangerous practices.
• Document negative changes and problems in performance.
• Counsel employees as to expected performance improvement.
• Refer employees to the Employee Assistance Program.
• Clearly state consequences of policy violations.

For More Information

GBH’s Human Resources, oversees our Drug-Free Workplace Program.  If you have questions or would like help finding resources or understanding various benefits that help with substance abuse issues, please contact Human Resources at (617) 300-2000. 

3) Whistleblower Policy NEED TO CHECK WITH HR IF OK TO POST

In order to create a safe, secure and ethical workplace, GBH has established a relationship with a hotline/helpline firm, EthicsPoint. EthicsPoint provides Staff and other stakeholders additional methods to raise concerns about possible safety or security issues or unethical or inappropriate behavior within our community. Issues may be filed by phone or through the EthicsPoint website, and, if preferred, may be made anonymously.  To submit a potential allegation or question using EthicsPoint, please log on to www.ethicspoint.com and click on “File a Report” where you can search for GBH’s specific reporting page.  If you prefer to communicate by phone, please call 888-359-6297.  If you have questions, please contact GBH’s Compliance Department or Human Resources (617) 300-2000 (the “Whistleblower Contacts”).

• Reporting Responsibility
  
  It is the responsibility of all trustees, officers and employees to comply with the Foundation’s Code and to report violations or suspected violations in accordance with this Whistleblower Policy.
  
  • No Retaliation
  
  No trustee, officer or employee who in good faith reports a violation of any of the provisions of either of the Codes shall suffer harassment, retaliation or adverse employment consequence.  An employee who retaliates against someone who has reported a violation in good faith is subject to discipline up to and including termination of employment. 
  
  This Whistleblower Policy is intended to encourage and enable employees and others to raise serious concerns within the Foundation rather than seeking resolution outside the Foundation.
• Reporting Violations
  
  The Codes address the Foundation’s open door policy and suggest that employees share their questions, concerns, suggestions or complaints with any of the individuals identified in this policy. In most cases, an employee’s supervisor is in the best position to address an area of concern.  However, if an employee is not comfortable speaking with his/her supervisor or is not satisfied with the supervisor’s response, the employee should speak to his/her vice-president, to the Whistleblower Contacts, to the Foundation’s General Counsel or to any of the other lawyers in Business and Legal Affairs.  Supervisors and managers are required to immediately report suspected violations of the Codes, in writing, to either of the Foundation’s Compliance Officers, who have specific and exclusive responsibility to investigate all reported violations.  For suspected fraud, or when an employee is not satisfied with or is uncomfortable following the Foundation’s open door policy, individuals should contact the Foundation’s Whistleblower Contacts directly.
  
  • Whistleblower Contacts
  
  The Foundation has named two senior employees as Whistleblower Contacts because of the size of the organization and the possibility that an employee might not be comfortable reporting to one of the named individuals. 
  
  The Foundation’s Whistleblower Contacts are responsible for investigating and resolving all reported complaints and allegations concerning violations of the Codes and, as either deems appropriate, should advise the President and/or the Audit Committee Chair.  A Whistleblower Contact shall not participate in the investigation of any complaint involving that Officer or anyone who reports to that Officer.  The Whistleblower Contacts shall have direct access to the Audit Committee of the Board of Trustees, report to the Audit Committee at least annually and identify in that report any material.  Reported concerns or complaints regarding corporate accounting practices, internal controls or auditing. 
  
  • Acting in Good Faith
  
  Anyone filing a complaint concerning a violation or suspected violation of the Codes must act in good faith and have reasonable grounds for believing the information disclosed indicates a violation of one or more provisions of either or both of the Codes. 
  
  Any allegation that is not substantiated and that proves to have been made maliciously or knowingly false will be viewed as a serious disciplinary offense.
  
  • Confidentiality
  
  Violations or suspected violations of the Foundation’s codes may be submitted on a confidential basis by the complainant or may be submitted anonymously. Reports of violations or suspected violations will be kept confidential to the extent consistent with the Foundation’s overriding need to conduct an adequate investigation. Complainants should recognize the limits that are inherent in anonymous or confidential complaints. It may be difficult to take corrective action based on these types of complaints. However, all complaints will be investigated.
  
  • Handling of Reported Violations
  
  A Whistleblower Contact receiving a complaint will acknowledge receipt of a reported violation or suspected violation promptly, generally within five business days.  All reports will be promptly investigated, and appropriate corrective action will be taken if warranted by the investigation.

4)  WGBH Travel and Expense Reimbursement Policy - ALREADY ON THE EXTERNAL WIKI (checking online policy first - if the same, replace with a link)

INTRODUCTION

Purpose of Policy

This document sets forth the policies of GBH with respect to certain business and travel expenses of independent contractors working on GBH projects.  This policy outlines what qualifies as an accountable reimbursement plan under US Treasury Regulation §1.62-2(c).

Please direct any questions regarding this policy to your GBH Project contact or the Compliance Department at (617) 300-2000.

GBH appreciates the efforts of those who travel on GBH-related business.  It is necessary to keep travel costs within reasonable limits and to follow consistent procedures. Independent contractors working on GBH projects are required to submit an itemized accounting of these expenditures. Sound judgment is necessary in managing such expenses.

GBH retains final approval of all expenditures and periodically reviews and adjusts its reimbursement policies.

This policy is intended to:

• Ensure clear and consistent understanding of procedures
• Ensure compliance with state, federal, and IRS regulations, including federal cost regulations under the Office of Management and Budget (OMB) and including donor and funder guidelines
• Ensure maximum insurance coverage for the travelers as well as for GBH
• Provide guidelines that simplify travel arrangements and enable GBH to better manage its annual travel costs

Responsibility of the Traveler

Independent Contractors working on GBH projects are expected to spend funds prudently. Business expenses will be reimbursed by GBH if they are:

• Reasonable
• Appropriately documented
• Properly authorized by the GBH project contact
• Within the guidelines of this policy

Non-compliance with these policies and procedures or failure of Independent Contractors working on GBH projects to properly and accurately expense documentation will result in a delay in receiving reimbursements when due, difficulties in obtaining additional funds, and in some cases disallowance of part or all of the expense(s). Questions regarding the interpretation of these policies and procedures should be directed to the Compliance Department. 

For travel associated with projects funded by federal grants, additional restrictions may apply. See the Appendix for further information.

Reimbursable Expenses

In addition to expenses for hotels, transportation, and meals, as defined in the policy, travelers will be reimbursed for the following expenses with proper receipt documentation:

• TSA Pre-check will be reimbursed to frequent travelers with a projected business travel schedule and once approved by their supervisor.
• Business office expenses (fax, copy service, )
• Business phone calls
• Conference fees (include copy of registration form with expense report)
• Currency conversion fees
• Personal phone calls, not to exceed an average of 15 minutes per day
• Gasoline allowance for rental car (if mileage allowance not claimed)
• Mileage allowance for personal car usage per IRS rates, allowable only above and beyond normal daily commute

• Ground transportation (taxi, bus, train, subway,)
  • Laundry/dry cleaning/suit pressing for trips exceeding 5 days
  • Luggage fees for airlines that charge for normal baggage
  • Overnight delivery/postage for business purposes
  • Parking and tolls for business purposes
  • Tips related to business meals and travel (see guide to tipping, page 10)
  • Visa/passport consulate fees for business travel
  • Supplies when on site (production, conference,)

For Independent Contractors that work on projects funded by federal funds, the Independent Contractor should also refer to the Appendix to this policy for special requirements applicable to these types of grants.

Non-Reimbursable Expenses

Travelers will not be reimbursed for the following expenses:

• Alcohol see Appendix re: travel and expenses for projects funded by federal grants
• Airline club membership dues and other award programs
• Annual fees for personal credit card used for travel purposes
• Airline upgrades
• Car rental upgrades or GPS systems
• Purchase of prepaid cards are not allowed for travel related expenses.
• Auto repairs
• Child care services
• Barbers, hairdressers, clothing, or toiletry items
• Baggage fees associated with personal items such as skis, golf equipment,
• Portion of meals for conference where meals are part of registration
• Health club/resort fees, gym, or recreational fees
• Corporate card delinquency fees or finance charges
• Expenses related to vacation or personal days taken before, during, or after a business trip
• Laundry or dry-cleaning services for travel of fewer than 5 consecutive days
• Valet service (unless mandatory at the location)
• Loss or theft of cash or airline tickets
• Loss or theft of personal funds or property
• Lost baggage or associated costs (losses covered by airlines)
• Luggage, briefcases
• Magazines, books, or personal reading materials
• Medical expenses incurred while traveling, except for business-related injury or accident (medical services covered by insurance)
• Mini-bar/ in-room refreshments (non-alcoholic only may be meal expense)
• Movies (including in-flight and hotel in-house)
• “No show” charges for hotel or car service
• Optional personal travel or baggage insurance
• Parking tickets or traffic violations
• Personal entertainment, including sports events
• Personal telephone calls in excess of reasonable calls home, as defined in the “Reimbursable Expenses” section
• Pet care
• Spa services, shoe shines
• Personal guest travel and expenditures
• Souvenirs, personal gifts (except in lieu of lodging)

Required Receipts for Reimbursement

The traveler should include:

• A copy of the airfare itinerary or original ticket receipt
• Original folio for all lodging expenditures, regardless of amount
• Car rental agreement and detailed statement of amount paid (not estimate)
• Credit card receipts (not statements) for entertainment expenses (must include names, titles, and business purpose of meeting and detailed restaurant meal receipts)

AIR/TRAIN TRAVEL

Air Travel

All air travel is restricted to coach class or to the least expensive airfare available, unless circumstances prevent it. It is GBH’s policy not to cover the cost of business class travel, even for international flights, except under extraordinary circumstances. Independent Contractors seeking reimbursement for business class travel outside North America under such unusual circumstances must obtain prior written approval from GBH’s Accounting office. Business class travel that does not follow this procedure will risk non-reimbursement of expenses.  When traveling on a federally funded project, (see Appendix) travelers must book the lowest coach class airfare available, and travel may only be on approved airlines (generally American-owned carriers).  Any international travel on non-American-owned carriers must receive prior written approval from GBH’s Accounting office.

First-class travel is prohibited for all destinations unless pre-approved by GBH’s Accounting office.  First class travel is not allowed for federally-funded projects.

Travelers attending a conference are strongly encouraged to consider multiple-stop fares as time allows and should review the conference registration forms for details regarding discount airfare and hotel rate made available through the agency of the conference.

The use of personal aircraft is not allowed for GBH business travel.

 Train Travel

Out-of-town train travel is restricted to coach class or its equivalent. First class or business class train travel is not allowed under GBH policy. For rail travel only, if coach class is not available due to the type of train, business class is acceptable. This fact should be documented. First class rail travel is not acceptable in any circumstances.

HOTEL/LODGING

Independent contractors working on GBH projects who are required to stay overnight when traveling for business purposes should stay in a standard, business-class, single room in a non-luxury hotel. Suite or luxury accommodations will not be reimbursed unless pre-approved by GBH’s Accounting office, or unless no other rooms are available.  Approved supporting documentation should be submitted.

Hotel rates in major cities (Chicago, Los Angeles, San Francisco, Washington, DC) may not exceed $250 per night, excluding taxes. New York rates may not exceed $400 per night, October through December; $300 all other months. Please note: GBH is exempt from some hotel taxes in New York, and a tax- exempt certificate for the state of New York (available from the Accounting office) should be provided upon check-in.

It is the responsibility of the traveler to notify the hotel to cancel a room reservation. Travelers should request and record the cancellation number in case of billing disputes. Travelers will not be reimbursed for “no show” charges.

Original hotel paid folio receipts must be retained.  If a business trip is 5 or more days long, laundry, dry cleaning, and pressing services are allowed when reasonable and receipts are retained.

Reasonable gratuities to porters and bellmen will be reimbursed:

• Bellmen: $2-$3 per bag
• Housekeeping: $5 per night maximum
• Cabs: 15-18% of fare
• Porters: $2-$3 per bag
• Valet 15 – 18%

Travelers who stay in a private residence (with relatives or friends) in lieu of a hotel while on business travel will be reimbursed for reasonable, actual expenses up to a limit of $150 per trip, to extend appreciation to their hosts for their hospitality. A dated receipt (e.g., florist receipt, restaurant receipt, grocery receipt) must be submitted with the expense report under this provision.  Note: When traveling on a federally funded project, tokens of appreciation are not allowable (see Appendix regarding federal grant travel and business expenses)

Airbnb can be used in a limited basis and only with proof of it being the least expensive option.  Any damages caused to a property by guest(s) will be the responsibility of the traveler. 

GBH independent contractors who travel with persons not tied to the purpose of the business trip are expected to pay all incremental costs associated with the guests’ travel, including transportation costs, additional lodging expenses, if any, meal expenses, and registration fees.

TRANSPORTATION

Automobile Rental

Car rentals are currently not allowed unless used for out of town travel. Local car rentals will only be allowed with proof of least expensive option or when contractually obligated. 

Car rental should be limited to situations where public or other forms of transportation would not be practical or economical.

A compact to mid-size car is considered adequate for general transportation, but larger vehicles may be rented if required for the number of passengers or equipment being transported.  Approval for a larger car should be obtained from your GBH project contact and documented as to the reason a larger car is required.  A car to be used for more than a few days should be contracted at the most economical weekly rate available. Independent contractors traveling to the same destination should make every effort to share automobile rentals whenever possible.

Gas tanks should be filled prior to returning cars to rental agencies to avoid refueling charges, which may be billed at as much as $5 per gallon or more. Cars should be returned on time to avoid additional hourly charges. 

Allowance for Personal Auto

The use of a personal car for GBH business will be reimbursed at the federal reimbursement rate per mile for the most direct route to and from the business destination. Federal reimbursement rate is issued by the IRS every year and will be updated every year. Independent contractors on GBH projects must keep track of the origin and destination of the trip and total number of miles driven. Costs incurred for parking and tolls are reimbursable and receipts should be submitted for all auto expenses.

Unacceptable transportation expenses include:

• Car repairs
• Rental car costs during repair of personal car
• Tickets, fines, or traffic violations incurred while driving a car for business purposes or for commuting to work

Local Public Transportation

Business travel expenses for bus, MBTA, train, or taxis within the local area are reimbursable Travelers should note the origination and destination of each portion of the trip.

Taxi Service

Taxi fares paid out of pocket are acceptable and receipts should be retained. Taxis are not authorized for routine commuting to and/or from work.

Car Services

Car services are more expensive than taxis and should not be used.  Use of car services should be limited to talent/VIP purposes only and requires pre-approval by GBH.

Uber and other services will be reimbursed and should only be used for business purposes.  Reimbursement requires written explanation for the business purpose of the Uber trip.

MEALS (INDIVIDUAL)

Individual

Individual meals are defined as food or beverage consumed on-site or off-site by one independent contractor while on GBH business. Meals also include food items consumed during a hotel stay.

Expense Limits

Independent contractors working on GBH projects will be reimbursed for personal meal expenses by providing original detailed receipts. Meal expenses per day, including tax and gratuity should not exceed $75. (For New York, San Francisco, and Los Angeles an additional $20 per day is reimbursable.)

The individual daily meal allowance (including snacks and non-alcoholic refreshments) is not to exceed the daily spending limit of $75.  If meals are provided as part of a conference, event, or meeting, there will be no additional reimbursement for the meal. The daily spending limit will be reduced by the following amounts- breakfast $15, lunch $20, dinner $40 - for these meals provided to the traveler.  Independent contractors working on GBH projects must submit itemized receipts for all meals for which they are expecting reimbursement. Individuals performing work for projects funded by federal grants should refer to the Appendix for additional restrictions.

Receipt Requirements

Receipts are required for individual meals.

GROUP MEALS/MEETINGS

Group

Group meals are food and beverages consumed on- or off-site by more than one person.

Receipt Requirements

Itemized receipts are required for all group meals. In order to be reimbursed for all meal expenses (including business lunches and dinners), the following information must be included with your receipt:

• Names and titles of attendees
• Date and place
• Nature of the business taking place

For audit purposes, the meeting agenda (or summary of business discussed) also should be attached.

TELECOMMUNICATIONS

Business Phone Calls

The Foundation will reimburse independent contractors working on GBH projects for reasonable business phone calls, while traveling. Hotel bills, telephone bills, or other documentation detailing names and companies are required for phone call reimbursement.

APPENDIX:  ADDITIONAL GUIDELINES FOR TRAVEL AND BUSINESS EXPENSES WHEN WORKING ON PROJECTS FUNDED BY FEDERAL GRANTS

Independent contractors charging expenses to projects funded by federal grants should be cognizant of the special requirements and limitations related to expenses charged to federal grants.  These policies are in addition to the GBH travel and expense policies and expenses need to be in compliance with both policies.

1. All expense reports are subject to review by the Compliance Manager before being submitted for processing.

1. The independent contractor submitting the expense report and the Supervisor/Manager approving the expense report are responsible for ensuring each expense is allowable under the terms of the grant, and 2 CFR, Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (the Uniform Guidance). 2 CFR, Part 200 sets forth standards for obtaining consistence and uniformity among Federal agencies in the administration of grants to agreements with the institutions of higher education, hospitals, and other non-profit   2 CFR, Part 200, Appendix IV establishes principles of determining costs of grants, contracts and other agreements with non-profit organizations.

1. Every expense item must be supported by a detailed receipt, regardless of A credit card statement is not an acceptable form of receipt.

1. GBH will not reimburse an independent contractor for expenses associated with the purchase of alcoholic beverages, gifts or contributions, donations and entertainment charged to federal To provide positive proof that meal reimbursements do not include charges for alcohol, detailed receipts with proof of payment (listing of items included in the total) must be submitted for reimbursement of meal expenses.

1. The Uniform Guidance discourages grant recipients (GBH) from purchasing unnecessary items and incurring meal expenses when not traveling on grant related business, with federal grant Local lunches, and dinners that are not deemed necessary will not be reimbursed.  Additionally, entertainment costs such as the cost of amusement, diversion, social activities (including “wrap parties” or other project completion celebratory events), ceremonials, and costs relating thereto, such as meals, lodging, rentals, transportation and gratuities are unallowable.

1. Expenses for gifts may not be charged to federal

5)  WGBH Policy on Conflicts of Interest ALREADY ON THE EXTERNAL WIKI (checking online policy first - if the same, replace with a link)

1. Purpose

Federal regulations require Investigators to disclose certain financial interests (defined below) to ensure that the design, conduct or reporting of federally-funded projects will not be biased.  This procedure describes the conditions under which these financial interests should be disclosed by Investigators, regardless of whether the Investigator is an employee of GBH or not.  The procedure is applicable to all research and educational activities supported by the National Science Foundation (NSF) and to all research activities supported by the Public Health Service (PHS) and other federal agencies, and by other funders and programs that specifically request review consistent with federal regulations on objectivity in research. 

1. Definitions

Investigator:  For purposes of this procedure, Investigator means any individual, subawardee, contractor or collaborator who shares responsibility for the design, conduct or reporting of the results of a sponsored project, and includes the Principal Investigator.

Principal Investigator (PI):  An Investigator who has primary responsibility for the scientific and technical conduct, reporting, fiscal and programmatic administration of a sponsored project.

III.   Significant Financial Interest

For purposes of this policy, a “Significant Financial Interest” is anything of monetary value owned by an Investigator (and/or those of the Investigator’s spouse and/or dependent children) that reasonably appears to be related to the federally-funded project, including but not limited to:

• Any income or other payment for services including: salary, consulting payments, honoraria, reimbursement of expenses, royalty payments, dividends, loans or any other payments or consideration of value, during the prior twelve months or anticipated in the next twelve months when aggregated exceeding $5,000;
• Any equity interest including stock, stock options, warrants, real estate, loans or any other investment or ownership interest;
• Intellectual property rights and interests interest (e.g., patents, copyrights), upon receipt of income related to such rights and interests, assigned or licensed to a party other than GBH.

Significant Financial Interest does not include the following:

• Salary, royalties or other remuneration from GBH or from the subrecipient organization when an Investigator is employed by the subrecipient;
• Income from seminars, lectures, or teaching engagements sponsored by public or nonprofit entities;
• Income from service on advisory committees or review panels for public or nonprofit entities; and
• Salaries, royalties or other payments that, when aggregated with those of a spouse and dependent children, are not reasonably expected to exceed $5,000 during the past twelve months or over any twelve month period during the term of the project.

1. Policy

Disclosure Requirement

Investigators are required to disclose any Significant Financial Interest (as defined above) in any federally-funded project which would reasonably appear to be affected by the work that will be performed on the Project and/or any Significant Financial Interests in entities whose financial interests (e.g., its earnings, value, sales of its products) would reasonably appear to be affected by the project.

Specifically, the Investigator is required in all cases to provide to GBH information regarding any Significant Financial Interest on behalf of the Investigator, his/her spouse and any dependent children.  Any Significant Financial Interest in a federally-funded project MUST be disclosed to GBH in the “Principal Investigator Certification and Financial Disclosure for Federal Awards” prior to the submission of a proposal to the government.

Investigators from other organizations who share responsibility for the design, conduct or reporting of project results, and who will be performing work under a sub-grant or subcontract from GBH, are expected to comply with GBH’s policies and procedures for disclosure and review of any Significant Financial Interest at the institution at which they are employed.  Where an Investigator is unable to comply with GBH’s policy due to restraints imposed by his or her organization, GBH’s Director of Compliance will ensure that the entity for which the Investigator works has its own policies in place that meet federal requirements. 

Investigators must ANNUALLY disclose and certify as to any Significant Financial Interests. 

Disclosures of Significant Financial Interests must also be made, updated, or supplemented:

• Each time a request for new funds including progress reports (non-competing continuations), are submitted to PHS, no-cost time extensions are requested, or incremental funds are accepted under contracts; 
• Each time a request for new funds is submitted to NSF or another federal agency;
• Each time a request for support is submitted to another project sponsor or program that requires review under federal regulations;
• Any time a new Investigator is added to the project; and
• Any time during the term of an ongoing award that an Investigator has a change in a reportable Significant Financial Interest or acquires a new Significant Financial Interest that was not reported on the original disclosure form, within thirty days of discovering or acquiring the interest. 

Examples of situations in which Significant Financial Interests should be disclosed include, but are not limited to:

• An Investigator is conducting a sponsored project where the results could be relevant to the development, manufacturing or improvement of the products or services of an entity in which the Investigator has a Significant Financial Interest;
• An Investigator has a Significant Financial Interest in an entity which might manufacture or commercialize a product or service that might result from the sponsored project; or which manufactures or sells any product that will be tested or used in the sponsored project, or that would reasonably appear to be affected by work performed during the project;
• An Investigator has a Significant Financial Interest in an entity which manufactures or sells a concomitant or comparator product or service and would reasonably appear to be affected by the work performed during the project;
• An Investigator received consulting income that exceeded $5,000 from any entity during the prior 12 months or anticipates receiving income of $5,000 or more over the next 12 months, and the financial interests of that entity would reasonably appear to be affected by the work performed during the project;
• An Investigator has a Significant Financial Interest in an entity to which a portion of the work under the project will be subcontracted, from which space will be leased, to which participants will be referred, or from which purchases will be made; or
• An Investigator is carrying out a sponsored project and has a Significant Financial Interest in an entity that is part of a consortium or that will otherwise participate in the sponsored project.

Submission and Review of Disclosures

In accordance with federal regulations, all disclosures must be received by the Director of Compliance before the application for funding can be submitted to the agency.  Disclosure of Financial Interests will be reviewed by the Director of Compliance in order to determine whether they reasonably appear to directly and materially affect the design, conduct or reporting of projects and thereby constitute a conflict of interest that may need to be managed, reduced or eliminated.

Where an Investigator discloses a Significant Financial Interest in a project, GBH’s Director of Compliance and the Central Procurement Group will review and ensure that the disclosing Investigator does not participate in the selection, award, or administration of a contract supported by Federal funds if a real or apparent conflict of interest would be involved. 

Should a conflict of interest be identified, the Director of Compliance will contact the Investigator to determine the best solution to manage, reduce or eliminate the identified conflict, including imposing any restrictions or conditions.  These solutions may include, but not be limited to, the following:

• Public disclosure of significant financial interests;
• Monitoring of project performance by independent reviewers;
• Modification of the project plan;
• Disqualification from participation in any portion of the project funded by federal funds;
• Divestiture of significant financial interests; or
• Severance of relationships that create conflicts.

If the Director of Compliance determines that imposing conditions or restrictions would be either ineffective or inequitable and that the potential negative impacts that may arise from a significant financial interest are outweighed by the objectives of the project, the Director of Compliance may allow the project to go forward without imposing such conditions.  However, GBH is required to notify the federal sponsoring agency if the conflict of interest can’t be satisfactorily managed.  GBH’s Director of Compliance will inform the General Counsel of the relevant federal agency in the event that a conflict arises that cannot be managed by GBH.

Subrecipient Monitoring

In accordance with federal guidelines, GBH’s Director of Compliance shall ensure that any subrecipient of federal funds either 1) has its own conflict of interest policy in place which is compliant with federal regulations; or 2) that the investigators working for such entities follow GBH’s policy regarding conflicts of interest.

Disclosure and Record Retention

GBH will attempt to maintain the confidentiality of significant financial interest disclosures received.  However, in certain situations, GBH may be required to share information regarding significant financial interests with the federal sponsoring agency or other parties under regulatory requirements.

Records of financial disclosures, reviews and any actions regarding management of a conflict of interest will be retained for at least three years beyond the termination or completion of an award (at least three years from the date of submission of the final expenditures report), or until the resolution of any action by the sponsoring federal agency involving the records, whichever is longer. 

1. Enforcement and Sanctions

Individuals are required to comply fully with all components of the Policy.  This includes filing and updating annually a complete and truthful financial disclosure for pending proposals; updating any previous disclosure when a new interest is obtained; and complying with any conditions or restrictions directed or imposed, including cooperating with appointed reviewers.  Failure to adhere to any component of the Policy may subject the individual to disciplinary actions, up to and including termination.

Note:  This Conflict of Interest Policy regarding federally-funded projects is in addition to, and not a substitute for, any other GBH policy concerning conflicts of interest, including those for trustees, officers and senior managers, and those applying to all employees.

6)  WGBH Anti-Texting While Driving Policy NOT ON THE WIKI - NEED TO CHECK WITH SUE K IF OK TO POST

Federal grant recipients, sub recipients and their grant personnel are prohibited from text messaging while driving a government owned vehicle, or while driving their own privately owned vehicle during official grant business, or from using government supplied electronic equipment to text message or email when driving. Please note that although Massachusetts law already prohibits drivers from texting while driving, the GBH Anti-Texting While Driving Policy applies to driving anywhere, in or out of the state of Massachusetts.