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 https://wiki.wgbh.org/x/uBOsC (St. Elizabeth mentions only diff)

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: https://wiki.wgbh.org/x/shOsC 

5)  WGBH Policy on Conflicts of Interest PAGE ALREADY ON THE EXTERNAL WIKI BUT DIFFERENT CONTENT (check which is up to date and fine to share)

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.