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PATH’s principles and policies relating to responsible conduct

How we apply our code of ethics, governance, and responsibility

PATH has established principles relating to responsible conduct in governance, workforce environment, research, collaboration, financial stewardship, intellectual property and confidential information, conflict of interest, communications, advocacy, and the environment. We have also established policies on harassment and retaliation, workplace bullying, child safeguarding, and trafficking in persons. These principles and policies guide our work in accordance with our Code of Ethics, Governance, and Responsibility.

Click the links below to navigate to specific principles and policies.

Governance
In all aspects of our work, PATH adopts applicable and good-practice governance rules and principles. These include both the United States and other countries’ rules regarding how nonprofit organizations are organized, how they are governed, and how they conduct their affairs. PATH strives for robust decision-making, transparency, and reporting for the legal entities we have established to conduct our operations. PATH is committed to gender equity; geographic, ethnic, and racial diversity; and inclusion of people with disabilities in the composition of our board.

PATH adheres to government regulations and legal requirements for the locations in which we work. Relevant laws include federal laws such as the US Internal Revenue Service Code, state corporation laws, and country-specific regulatory laws that impact how we are structured, are governed, operate, and report to governmental authorities in particular jurisdictions.

To ensure accountability and transparency, the boards governing PATH and our affiliated organizations meet regularly and follow applicable laws and bylaws established to conduct our affairs. We have established internal governance and authorization policies and procedures that provide a foundation for this work, including the conflict of interest policies described below. We also strive to follow evolving best practices for governance.

Workforce Environment
PATH is committed to a work environment in which all employees are treated fairly and with respect and dignity. Each employee has the right to work in a professional atmosphere that abides by all applicable labor and wage laws and that promotes equal employment opportunities and prohibits discriminatory practices, including harassment. Therefore, PATH expects that all relationships among persons in the workplace will be lawful; professional; respectful; and free of bias, prejudice, and harassment.

To ensure accountability and transparency, PATH has established internal policies and procedures that provide clear direction regarding labor and wage practices, diversity, harassment, and professional conduct. We follow local laws and regulations regarding these areas and strive to follow evolving best practices. PATH’s HR Business Partners are trained to identify and address these issues, should they arise in the workplace.

PATH values its employees and, in order to fulfill its duty of care, endeavors to protect their health, safety, and security against any reasonably foreseeable dangers in the workplace. PATH will take practical steps in order to fulfill its duty of care for employees whenever they are at work, including while they are in PATH offices and when they are traveling. (More information for PATH staff can be found on our internal Policy Portal and on the Global Facilities, Travel, and Security SharePoint site.)

PATH is committed to deterring all activities that would facilitate or condone abuse, exploitation, or neglect of children who are served by PATH programs or come into contact with PATH personnel implementing those programs. We comply with host country and local child welfare and protection laws and international standards, whichever gives greater protection, as well as US law where applicable. We prohibit all personnel from engaging in child abuse, exploitation, or neglect. We consider child safeguarding in project planning and implementation to determine potential risk to children that are associated with project activities and operations, and we apply measures to reduce the risk of child abuse, exploitation, or neglect, including, but not limited to, limiting unsupervised interactions with children; prohibiting exposure to pornography; and complying with applicable laws, regulations, or customs regarding the photographing or filming of children. We promote child-safe screening procedures for personnel, particularly personnel whose work brings them in direct contact with children. Finally, PATH has a Child Safeguarding policy which requires that personnel and others recognize child abuse, exploitation, or neglect; mandates that personnel and others immediately report concerns regarding violations of this policy and/or applicable law to your HR Business Partner or manager; provides mechanisms for investigating and managing allegations; and confirms that appropriate action will be taken in response to violations, including but not limited to, termination of employment or contract.

PATH is opposed to all forms of trafficking in persons and is committed to mitigating the risk of trafficking in persons in connection with our operations, personnel, and programs. PATH has adopted a Trafficking in Persons policy that prohibits trafficking in persons, procurement of commercial sex acts, and using forced labor and mandates that personnel and others immediately report concerns regarding violations of this policy and/or applicable law to your HR Business Partner or manager. This policy is applicable to all PATH employees, consultants, contractors, subrecipients, and anyone working on behalf of or representing PATH.

Employee Parental Resources
At PATH, we are a global team of employees and we strive to offer a fulfilling, productive and successful employment experience. We understand that in order to achieve this, we must recognize employees have external obligations and family commitments, in addition to their PATH work. For this reason, PATH is committed to supporting employee family responsibilities by offering parental leave policies, additional leave options for new parents, flexible work and resources for parents through our employee assistance provider. Within the context of this global commitment, each region-specific employee handbook offers details for employees on applicable policies, benefits, and resources.

Ethical Conduct of Research
PATH is committed to rigorously designing and carefully implementing research that meets or exceeds national and international ethical standards. Whether we work independently or in collaboration with other groups, we strive to ensure the ethical conduct of research.

PATH maintains a committee charged with determining which data-collection activities fall under the US government’s definition of research and an institutional review board that, under a federal-wide agreement with the US government, reviews both biomedical and behavioral research. All PATH’s human subjects research is reviewed by an institutional review board. All of PATH’s human subjects research must undergo a separate review for scientific merit as well.

PATH human subjects research performed outside of the United States requires locally applicable ethical review and must follow all local research ethics requirements. All research performed by third parties under contract to PATH must adhere to this policy. In addition, all PATH research that involves recombinant DNA is reviewed by an institutional biosafety committee.

PATH is committed to ensuring that the clinical trials which we fund, conduct, or otherwise support are registered in a publicly available clinical trial registry in accordance with international standards established by WHO. We are likewise committed to ensuring that the results of these trials are made publicly available within 12 months of primary study completion. We monitor our commitment to these principles on an annual basis.

We require our senior leaders and all staff with oversight or involvement in research projects to maintain current research ethics training certification. In addition, we expect all staff and consultants who conduct research for PATH to observe the highest standards of scientific integrity. PATH’s policy on scientific integrity includes administrative processes to ensure that any allegations of research misconduct are reviewed and, if appropriate, investigated and reported.

Collaboration with Donors and Partners
PATH succeeds through partnerships marked by a respect for people, cultures, and ideas. This collaborative approach is embedded in our relationships with those who grant us funds for restricted or unrestricted purposes, as well as those with whom we partner to implement our work.

In engaging partners to carry out our work, we seek qualified, mission-consistent organizations, individual philanthropists, and family foundations well suited to the work at hand. Among potential nonprofit partners and individual partners, we seek collaborators that have values consistent with our own and a track record of success in advancing their own missions. Among potential private-sector donors, we seek collaborators willing to apply their development, manufacturing, and distribution strengths toward technologies that will benefit the low-resource populations we serve. We developed PATH’s Guiding Principles for Private -Sector Collaboration to describe how we engage the private sector to achieve maximum, sustainable benefits in global health. We also operate a Corporate Contributions Review Committee to inform PATH’s strategy for working with the corporate sector and to review current and prospective corporate contributions. Additionally, PATH has adopted the Code of Ethics from the Association of Fundraising Executives as a set of guiding principles as we engage individuals, corporations, and family foundations in support of PATH’s mission.

Financial Stewardship
PATH has adopted policies that enable us to be good stewards of funds we receive. We abide by institutional funders’ rules, regulations, and guidelines, and we strive for the best stewardship of individual donors’ valued donations. We uphold applicable financial standards and principles in all aspects of our work. These include Generally Accepted Accounting Principles and standards defined by the Financial Accounting Standards Board, the International Accounting Standards Board, and the Governmental Accounting Standards Board. We also uphold internal accounting policies that provide a foundation for this work.

PATH adheres to state, federal, and international regulations and legal requirements for the locations in which we work. Relevant US government regulations include the Internal Revenue Service Code, Code of Federal Regulations, Federal Acquisition Regulations, Office of Management & Budget Uniform Guidance under Title 2 of the Code of Federal Regulations Section 200, the Foreign Corrupt Practices Act, and the Patriot Act. We also abide by relevant state laws and country-specific regulatory and tax laws.

To ensure accountability and transparency, we perform external audits, internal audits, and third-party audits and reviews. We uphold our fiduciary responsibilities through our donor policies, investment policies, and oversight of employee pension assets. We take particular care with institutional, for-profit donors to create arms-length arrangements and avoid inappropriate quid pro quo transactions. Finally, we have developed and maintain policies—including procurement policies, travel policies, and accounting policies—that are intended to ensure ethical procurement of goods and services. Read more about our commitment to good stewardship.

PATH strives to detect, prevent, and correct wrongdoing that violates federal, state, or local laws with regard to corruption, fraudulent billing and financial reporting, or other wrongdoing or unethical conduct. PATH has a whistleblower policy and maintains an anonymous reporting option through a third-party compliance vendor to further enable reporting regarding allegations of misconduct or impropriety.

Protection of Intellectual Property and Confidential Information
Intellectual property includes patents, copyrights, trademarks, trade secrets, and confidential information (including business, financial, technical, or other proprietary data) and any other form of legal protection for intellectual creations.

PATH views managing intellectual property as an important means of advancing our mission. We also recognize the importance of intellectual property to our partners, and we seek to determine an intellectual property management approach that will ensure that global health goals are met while critical intellectual property is protected. PATH’s publication Maximizing the Benefits of Public-Private Partnerships details how we use intellectual property as a vehicle to achieve our mission.

PATH creates intellectual property alone or in collaboration with our partners, receives confidential information, and licenses or acquires intellectual property from other parties. We have policies to ensure that we properly protect intellectual property, whether it belongs to PATH or a third party. PATH complies with the laws and regulations that govern the rights of our own and others’ intellectual property. We expect our employees, directors, and those with whom we work to respect both PATH and third-party confidential and proprietary nonpublic information and to use it only for PATH business and not for personal advantage. In addition, PATH expects confidentiality to be maintained after an employee, director, consultant, or collaborator is no longer employed or working with PATH.

Conflict of Interest
Understanding and managing bias and conflict of interest are important and ongoing responsibilities for PATH. On local, national, and international levels, awareness and sensitivity regarding bias and conflict of interest are increasing across a range of areas, from research involving human subjects to technology-development collaborations with private companies.

At PATH, “conflict of interest” refers to situations in which financial or other interests or duties may compromise or have the appearance of compromising objective judgment or fulfillment of professional duties. Individual conflict of interest may exist when an individual’s financial or other interests create (or appear to create) a competing interest for the individual. Institutional or organizational conflicts of interest may exist when the financial interests of the organization affect (or reasonably appear to affect) PATH’s processes or decisions.

PATH works to ensure that our commitment to integrity will not be compromised by competing personal or institutional interests or obligations. We therefore strive for maximum transparency in our business arrangements for our products and program activities, and we monitor our business arrangements to avoid institutional conflicts of interest and to restructure arrangements if necessary.

PATH requires employees, investigators, and board members to abide by gift and anti-kickback policies and to disclose financial and other interests that may pose actual or perceived conflicts of interest. PATH works to eliminate or manage any conflicts of interest that arise from such disclosures. We developed PATH’s Guiding Principles for Managing Conflict of Interest as a guide for staff and collaborators, and we have implemented a procurement policy in which conflicts of interest are disclosed and addressed.

US Public Health Service regulations set standards to ensure that the design, conduct, and reporting of research funded under the service’s grants, cooperative agreements, and contracts will not be biased by any conflicting financial interest of participating investigators. Accordingly, all PATH investigators working on research projects funded by the National Institutes of Health or Centers for Disease Control and Prevention are guided by the PATH Investigator Conflict of Interest Policy.

Communications
PATH believes that providing accurate and timely information about our work is an inherent component of successful collaboration. We strive to ensure transparency and effectively communicate the results of our programs to relevant partners, supporters, and stakeholders, and we abide by the Public Relations Society of America Member Code of Ethics.

On the project level, we encourage staff to share project results, particularly among global health audiences. Because our collaborations may involve proprietary information, we strive to balance global health goals with our partners’ needs to protect business-sensitive information. We therefore work with our partners to proactively define issues related to proprietary or confidential information in our contractual agreements.

On the organizational level, we develop corporate communications such as annual reports, the PATH website, and newsletters and engage with the media to share information about PATH’s programmatic, financial, and business operations. We also provide services to all PATH staff to facilitate effective communications and the development of user-centered materials. To ensure accuracy and completeness of the resulting materials, we maintain a document approval policy that requires technical and leadership review of PATH materials.

Advocacy
PATH advocates for policies and resource commitments that address global health priorities. We support coalitions, provide evidence, and strengthen legislation and policies that advance health solutions that are most likely to achieve sustainable improvements in global health, whether or not they have been developed by PATH. The goal of this work is to create a policy environment that supports good health, particularly among the world’s most vulnerable populations.

Throughout our advocacy efforts, we abide by all federal regulations pertaining to our status as a 501(c)(3) organization, and we comply with funder restrictions. In particular, we comply with all funder restrictions on the use of grant funds for lobbying, and we do not participate in any political campaigns on behalf of (or in opposition to) any candidate for public office. Read more about our work in advocacy.

Environment
PATH is aware of the growing body of data on the impact of environmental degradation and climate change on our planet, particularly in the developing world. We recognize the importance of individual and organizational environmental responsibility in reducing this impact.

Our work to develop, introduce, and integrate health technologies includes efforts that protect communities and their environments from the risks associated with medical waste and minimize the volume of contaminated waste that must be managed.

To reduce PATH’s organizational environmental impact, PATH operates the Green PATH initiative, which guides staff in reducing energy consumption, reducing paper consumption, reducing the generation of nonrecyclable waste, increasing recycling, and reducing our carbon footprint.

PATH also considers environmental impact when designing and siting new facilities. For example, PATH’s offices in Seattle and Washington, DC, are located in buildings certified to the Leadership in Energy & Environmental Design (LEED) Gold and Platinum standards established by the US Green Building Council.

The above policies were revised in September 2018.

Policy on Harassment and Retaliation
This policy applies to all PATH employees (including temporary and contract employees), Board members, consultants, contractors, subrecipients, volunteers, interns, fellows or other talent program participants, individuals seconded to PATH and anyone working on behalf of or representing PATH (“personnel”).

Definitions

Gender expression or identity: means having, or being perceived as having, a gender identity, self-image, appearance, behavior or expression, whether or not that gender identity, self-image, appearance, behavior or expression is different from that traditionally associated with the sex assigned to that person at birth. Gender identity is a person’s internal sense of being male, female, or something else. Note: Because gender identity is internal, a person’s gender identity is not necessarily visible to others. “Gender expression” is the way a person represents or expresses one’s gender identity to others, often through behavior, clothing, hairstyle, and/or voice or body characteristics.

Policy Statement

PATH is committed to every person’s right to be treated with courtesy, dignity, and respect and to work in an environment that is free of discrimination and harassment. PATH strictly prohibits discrimination and all forms of harassment based on legally protected status, including sexual harassment. Any personnel who violate this policy is subject to corrective action, up to and including immediate termination of employment or contract.

PATH is committed to investigating any report of harassment based on the legally protected status of personnel. Any investigation regarding a potential violation of this policy will be conducted in confidence to the degree possible while still conducting a fair and objective investigation. PATH is committed to prohibiting retaliation against those who report incidents of harassment in good faith.

Unlawful Harassment

Harassment is defined as verbal, written, or physical conduct that is hostile and adverse toward others based on the race, creed, color, national origin, religion, sex, marital status, age, physical or mental disability, genetic information, sexual orientation, gender expression or identity, military status, or any other characteristic protected by applicable law. This policy also prohibits harassment and discrimination based on the perception that anyone has any of the protected characteristics, or is associated with a person who has or is perceived as having any of those characteristics.

Unlawful harassment covers a range of behaviors, including subtle and not-so-subtle, verbal and non-verbal behavior. It can be engaged in or experienced by individuals regardless of gender. PATH will not tolerate any form of harassment based on a protected characteristic. Prohibited harassment includes, but is not limited to, the following examples of offensive conduct:

  • Verbal conduct such as threats, epithets, derogatory comments, jokes or slurs referencing a protected class
  • Visual conduct such as derogatory posters, photographs, cartoons, drawings or gestures referencing such protected classes
  • Written communication containing statements or images which may be offensive to individuals in a particular protected group, such as racial or ethnic stereotypes, caricatures, jokes, symbols, or nicknames including, but not limited to, the use of PATH equipment though e-mail, texts, tweets, blogs, social networking sites, or other means
  • Physical conduct such as assault, unwanted touching or blocking another individual’s movement

Sexual Harassment

Sexual harassment includes a broad spectrum of conduct, including unsolicited and unwelcome sexual advances, requests for sexual favors, and other written, verbal, physical, or visual conduct of a sexual nature that is imposed on an individual. Example of unacceptable behavior include, but are not limited to:

  • Offering a job or an employment benefit (such as a raise, promotion or career advancement) in exchange for sexual favors, or threatening an employment action (such as termination or demotion) for an employee’s refusal to engage in sexual activity
  • Unwelcome sexual advances, like requests for dates or propositions for sexual favors
  • One-sided, romantic attention in the form of requests for dates, love letters, telephone calls, emails, texts or gifts
  • Making or threatening reprisals, or changing performance expectations after an employee has turned down a sexual advance
  • Visual or physical conduct, such as leering, making sexual gestures, or displaying sexually suggestive objects, pictures, cartoons, calendars or posters in the workplace
  • Verbal conduct, like making or using derogatory comments, epithets, slurs, teasing, or jokes of a sexual nature
  • Making sexually oriented comments about an individual’s sex life, clothing, or body
  • Sexually degrading words used to describe an individual
  • Suggestive or obscene letters, emails, texts, notes or invitations
  • Repeatedly talking about sex or describing sexual acts
  • Unwelcome physical contact, including pats, hugs, brushes, touches, shoulder rubs, assaults, or impeding or blocking movements
  • Offering or conditioning a business opportunity (such as a contract) in exchange for dates or sexual favors, offering or conditioning PATH-related programmatic services in exchange for dates or sexual favors, or changing or terminating such services, a contract or a scope of work due to a party’s refusal to submit to or engage in sexual activity

Harassment or discrimination based on a protected characteristic is unacceptable both in PATH’s offices and in any work-related setting outside our offices such as during business trips, trainings, on office outings, at parties, or at business-related social events.

It is also unacceptable to harass persons who are not PATH employees, and who you may encounter through or in connection with PATH activities, such as visitors, independent contractors, customers, partner staff, beneficiaries of PATH’s work, or others connected with PATH. Likewise, PATH employees are not to tolerate any conduct prohibited by this policy from anyone at while at work or engaged in PATH business. This includes harassment from their fellow co-workers, as well as by visitors, independent contractors, consultants, Board members, donor or partner staff, or other individuals they interact with while performing their work.

Reporting Unlawful Harassment

PATH personnel are obliged to create and maintain an environment that protects human dignity and prevents harassment.

PATH personnel who experience or observe harassing behavior must immediately report that behavior to PATH following PATH’s Procedures on Harassment and Retaliation, as soon as possible after the incident.

Your reporting of the problem is essential to PATH. We cannot resolve a harassment problem unless we know about it. Therefore, it is the responsibility of all PATH personnel to bring harassment incidents to our attention so that we can take whatever steps are necessary to address the situation.

Managers who observe harassing behavior or receive a report of harassment are required to immediately notify their Human Resources Business Partner or any Human Resources Director.

PATH takes all complaints of unlawful harassment seriously and will not penalize or retaliate against a person in any way for reporting a harassment problem in good faith.

All PATH personnel are expected to reasonably cooperate with a harassment investigation. Hindering or undermining an investigation is strictly prohibited.

To report incidents of unlawful harassment, discrimination, or misconduct, call 1-888-309-1559 (in the United States) or via www.path.ethics​point.com.

Consequences of Violations

Any PATH personnel determined by PATH to be responsible for harassment under this policy, or otherwise in violation of this policy, will be subject to disciplinary action, up to and including termination of employment or contract.

Retaliation Prohibited

PATH is committed to prohibiting retaliation against those who report incidents of harassment and those who participate in or cooperate in any way in the investigation of alleged misconduct.

Retaliation is when you suffer an adverse employment action, such as demotion or discipline, because you exercised a legal right. Examples of retaliation may include:

  • Transfer to a less desirable position
  • Termination, or threat of termination, of employment
  • Intimidation or verbal or physical abuse
  • Inappropriate reprimands
  • Unjustified negative performance feedback
  • Adverse actions with respect to your work assignments, salary, vacation, or other terms of employment
  • Discipline, or threats of discipline, for insubordination
  • Increased monitoring or surveillance without a legitimate business reason
  • Suspension or other punishment for complaining about harassment or participating in the reporting or investigation of harassment

PATH does not tolerate retaliation for filing a complaint, participating in an investigation, or otherwise opposing harassment. If you feel you are being retaliated against, or observe retaliation, you must immediately contact your Human Resources Business Partner or any Human Resources Director.

It is critical that PATH personnel, particularly managers, understand how important it is to avoid taking actions that while may be unintentional, could be perceived as retaliation for making a complaint. If you are a manager, consult with your HR Business Partner before taking adverse employment action against an individual who has filed a complaint or is participating in an investigation.

Any personnel determined to be responsible for retaliation will be subject to appropriate disciplinary action, up to and including immediate termination of employment or contract.

Personnel who knowingly and intentionally make a false report of harassment or retaliation may also be subject to appropriate disciplinary action, up to and including termination of employment or contract.

Training

PATH recognizes the need for organization-wide training and awareness raising. All PATH staff will be trained on this policy and associated procedure, including prohibited behavior, how to report, retaliation, and the actions that will be taken against PATH personnel for violations. PATH will regularly evaluate such training to ensure that it continues to provide effective guidance and awareness raising for inappropriate behavior in violation of this policy, and develops skills for personnel to detect, prevent, and report any form of conduct in violation of this policy.

Data and Reporting

Human Resources will maintain an incident report in which anonymized data and information will be collected for internal monitoring and analysis of unlawful harassment. No confidential or personal information will be included in such reports. The consolidated report for the previous year will be made available to staff annually.

Worldwide Scope

All personnel worldwide are required to comply with this policy at a minimum. However, if country and local-level requirements are stricter (such as additional protected classes or reporting requirements), employees must follow such local policy and/or requirements as set forth in country handbooks or similar policies, in addition to the terms of this policy. Please refer to your Human Resources Business Partner if you have questions.

This policy was updated in December 2019.

Policy on Workplace Bullying
This policy applies to all PATH employees (including temporary and contract employees), Board members, consultants, contractors, subrecipients, volunteers, interns, fellows or other talent program participants, individuals seconded to PATH and anyone working on behalf of or representing PATH (“personnel”).

Policy Statement

PATH is committed to providing a safe, supportive, and respectful environment for all personnel. To further these values, PATH does not tolerate abusive conduct or bullying. Workforce bullying refers to a pattern of repeated unreasonable actions of an individual (or a group) directed towards an employee (or group of employees), which intimidate, degrade, humiliate, or undermine; or which create a risk to the health or safety of the employee(s). Bullying behavior may take many forms including physical, verbal, or written acts or behaviors. Workplace bullying often involves an abuse or misuse of power.

Violations of this policy may result in disciplinary action, up to and including termination of employment or contract.

Workplace Bullying Examples

Examples of bullying may include:

  • Persistent or egregious use of abusive, insulting, or offensive language directed at an individual
  • Aggressive behavior that frightens, humiliates, belittles or degrades, such as insulting remarks, shouting, angry outbursts, finger pointing, invading someone else’s personal space and harsh emails or texts
  • Spreading misinformation or malicious rumors
  • Making repeated inappropriate comments about a person’s appearance, lifestyle, family, or culture
  • Regularly teasing or making someone the brunt of jokes or pranks
  • Inappropriately interfering with a person’s personal property or work equipment
  • Circulating inappropriate or embarrassing photos or videos via email, text, or social media or taunting on social media
  • Pushing, shoving, kicking, poking, tripping, or other physical assault or threat of physical assault
  • Staring, glaring, or other nonverbal demonstrations of hostility or threatening gestures or glances
  • Purposefully and inappropriately excluding, isolating, or marginalizing a person from normal work-related activities
  • Encouragement of others to turn against the targeted employee
  • Manipulating the ability of someone to do their work, such as removing tasks or tools that are imperative to job performance, withholding information that is necessary for the person to the do the job, or giving deliberately ambiguous instructions
  • Refusing reasonable requests for leave in the absence of work-related reasons not to grant leave
  • Constant criticism on matters unrelated or minimally related to the person’s job performance or description
  • Public reprimands
  • Repeatedly accusing someone of errors that cannot be documented
  • Monitoring another without a legitimate business reason
  • Undermining employees by demeaning their work standards, not giving them credit or stealing credit for their work, setting them up for failure and constantly reminding them of old mistakes

There is a difference between bullying and appropriate management or feedback. Examples of reasonable actions, when carried out in an appropriate manner, include:

  • Providing performance coaching or feedback on job performance
  • Re-balancing workload to core job duties as part of performance management
  • Monitoring or restricting access to sensitive information for legitimate business reasons
  • Scheduling ongoing meetings or other check-ins to address performance issues
  • Setting aggressive performance goals to help meet departmental, program, or other organizations goals
  • Counseling or disciplining an employee for misconduct or violation of PATH policy
  • Investigating alleged misconduct or policy violation

Differences of opinion, interpersonal conflicts, and occasional problems in working relations are an inevitable part of working life and do not necessarily constitute workplace bullying.

Reporting Incidents of Bullying

Early reporting and intervention have proven to the most effective method of resolving actual or perceived incidents of bullying. PATH strongly urges the prompt reporting of complaints or concerns so that rapid and constructive action can be taken. PATH will make every effort to stop alleged workplace bullying before it becomes severe or pervasive, but can only do so with the cooperation of all personnel.

If you believe that you are experiencing conduct that violates this policy, please contact your manager or Human Resources Business Partner, or, if you are not comfortable contacting these individuals, please contact any Human Resources Business Partner, or any Human Resources Director. Managers who observe bullying behavior or receive a report of bullying are required to report it immediately their Human Resources Business Partner.

The availability of this reporting procedure does not preclude individuals who believe they are being subjected to bullying conduct from promptly advising the offender that the behavior is unwelcome and requesting that such behavior immediately stop.

Resolution

Human Resources will promptly assess all allegations of bullying in violation of this policy. PATH strives to ensure that bullying complaints are addressed sensitively, promptly, and in accordance with PATH policy. All reasonable steps will be taken to respect the confidentiality of the people involved in a complaint. PATH is committed to facilitating a fair and impartial resolution process.

Options for resolving potential violations of this policy will vary depending on the circumstances, and may include a facilitated resolution or an investigation.

The goal of a facilitated resolution is to resolve concerns at the earliest stage possible with the cooperation of the parties involved. PATH encourages early resolution and HR will assist the parties in reaching a mutually agreeable resolution when the parties wish to resolve the situation collaboratively.

In some cases, HR may determine that a facilitated resolution process is either inappropriate or unsuccessful, and an investigation is warranted. Investigations will be conducted with due regard to procedural fairness, timeliness, and the individuals’ safety and well-being.

PATH will respond to reports of bullying brought anonymously or by third parties not directly involved in the complaint. However, the response to such reports may be limited if we do not have sufficient information about the alleged or suspected activity to adequately assess the allegations and/or initiate an investigation.

Retaliation

This policy prohibits retaliation (such as threats, intimidations, reprisals and adverse actions related to employment) against any person who reports workplace bullying, assists someone with a report of bullying, or participates in an investigation or resolution of a bullying complaint.

This policy was updated in December 2019.

Child Safeguarding Policy
This policy applies to all PATH employees (including temporary and contract employees), consultants, contractors, sub recipients, volunteers, interns, fellows, or other talent program participants, individuals seconded to PATH, and anyone working on behalf of or representing PATH (“personnel”).

Policy Summary

This policy describes PATH’s commitment to deterring all activities that would facilitate or condone abuse, exploitation or neglect of children who are served by PATH programs or who come into contact with PATH personnel implementing those programs. PATH prohibits any behavior or conduct that falls under the definitions set forth below.

PATH is committed to lawful, responsible, and ethical behavior in all of our activities. While such behaviors are broadly covered in PATH’s Code of Ethics, Governance, and Responsibility, this policy provides specific guidance on preventing any form of child abuse, exploitation, or neglect by PATH personnel.

Definitions

Child: A child or children are defined as persons who have not attained 18 years of age.

Child abuse, exploitation, or neglect: Any form of physical abuse; emotional ill-treatment; sexual abuse; neglect or insufficient supervision; trafficking; or commercial, transactional, labor, or other exploitation resulting in actual or potential harm to the child’s health, well-being, survival, development, or dignity. It includes, but is not limited to, any act or failure to act which results in death, serious physical or emotional harm to a child, or an act or failure to act which presents an imminent risk of serious harm to a child.

Physical abuse: Acts or failures to act resulting in injury (not necessarily visible), unnecessary or unjustified pain or suffering without causing injury, harm or risk of harm to a child’s health or welfare, or death. Such acts may include, but are not limited to, punching, beating, kicking, biting, shaking, throwing, stabbing, choking, hitting (regardless of object used), or burning. These acts are considered abuse regardless of whether they were intended to hurt the child.

Sexual Abuse: Constitutes fondling a child's genitals, penetration, incest, rape, sodomy, indecent exposure, and exploitation through prostitution or the production of pornographic materials.

Emotional abuse or ill treatment: Constitutes injury to the psychological capacity or emotional stability of the child caused by acts, threats of acts, or coercive tactics. Emotional abuse may include, but is not limited to humiliation, control, isolation, withholding of information, or any other deliberate activity that makes the child feel diminished or embarrassed.

Policy Statement

PATH strictly prohibits all PATH personnel from engaging in any form of child abuse, exploitation, or neglect.

Prohibited Activity

All PATH personnel must comply fully with host country and local child welfare and protection laws or with international standards, whichever gives greater protection, and must comply with U.S. law where applicable.

PATH personnel must consider child safeguarding in project design, planning, and implementation to determine and mitigate potential risks to children that are associated with project activities and operations.

PATH personnel implementing projects must take measures to reduce the risk of child abuse, exploitation, or neglect, including, but not limited to, limiting unsupervised interactions with children; prohibiting exposure to pornography; and complying with applicable laws, regulations or customs regarding the photographing, filming, or other image-generating activities of children.

Duty to report

PATH personnel are obliged to create and maintain an environment that prevents sexual exploitation and abuse of children.

PATH personnel who observe, suspect, or receive allegations of child abuse, exploitation or neglect must immediately report it to PATH following PATH’s reporting procedure.

Consequences of Violations

PATH personnel who commit child abuse, exploitation or neglect; fail to report or forward reports of suspected child abuse, exploitation or neglect; or otherwise violate this policy or related procedures will be subject to disciplinary action, up to and including termination of employment or contract.

Last updated December 2019

Policy on Trafficking in Persons
This policy applies to all PATH employees (including temporary and contract employees), consultants, contractors, sub recipients, volunteers, interns, fellows, individuals seconded to PATH, and anyone working on behalf of or representing PATH (“personnel”).

Policy Summary

PATH prohibits any behavior or conduct that falls under the definition of trafficking in persons as defined below.

Definitions

Trafficking in persons: the recruitment, transportation, transfer, harboring or receipt of persons, by means of the threat or use of force. This includes coercion, abduction, fraud, deception, the abuse of power or of a position, and the giving or receiving of payments or benefits to achieve the consent of a person, or having control over another person for the purpose of exploitation. Exploitation shall include, at a minimum, the exploitation or the prostitution of others, or other forms of sexual exploitation, forced labor or services, slavery, or practices similar to slavery, servitude, or the removal of organs1.

Commercial sex act: any sex act on account of which anything of value is given to or received by any person.

Forced labor: knowingly providing or obtaining the labor or services of a person:

(1) By threats of serious harm to, or physical restraint against, that person or another person;

(2) By means of any scheme, plan, or pattern intended to cause the person to believe that if the person did not perform such labor or services, that person or another person would suffer serious harm or physical restraint; or

(3) By means of the abuse or threatened abuse of law or the legal process.

Sex trafficking: the recruitment, harboring, transportation, provision, or obtaining of a person for the purpose of a commercial sex act.

Policy Statement

PATH is opposed to all forms of trafficking in persons and it is committed to mitigating the risk of trafficking in persons in connection with its operations, personnel, and programs.

PATH is committed to lawful, responsible, and ethical behavior in all of our activities. The well-being, dignity, and safety of our beneficiaries, personnel, and partners is critical to PATH, particularly the most vulnerable populations. While such behaviors are broadly covered in PATH’s Code of Ethics, Governance, and Responsibility, this policy provides specific guidance on preventing and responding to trafficking in persons by PATH personnel.

Prohibited activity

Trafficking in persons constitutes an act of gross misconduct and any PATH personnel found doing so is subject to disciplinary action, up to and including immediate termination of employment or contract.

In accordance with U.S. government policy, all PATH personnel, PATH sub recipients, and their employees and agents, including labor recruiters and brokers, are strictly prohibited from engaging in the following:

  • Trafficking in persons (as defined above);
  • Procurement of commercial sex acts (as defined above);
  • Using forced labor (as defined above); or
  • Acts that directly support or advance trafficking in person, including, but not limited to, the following acts:
  • Destroying, concealing, confiscating, or otherwise denying access to the employee’s identity or immigration documents;
  • Failing to provide or pay for return transportation upon end of employment for an employee who is not a national of the country where the work took place and who was brought into that country for the purpose of working on a U.S. Government contract or award;
  • Using misleading or fraudulent practices to recruit employees;
  • Charging recruiting fees to employees; or
  • Providing or arranging housing that fails to meet the host country housing and safety standards.
  • If required by law or contract, failing to provide an employment contract, recruitment agreement or other required work document in writing.

Duty to report

PATH personnel are obliged to create and maintain an environment that protects human dignity and prevents human trafficking.

PATH personnel who observe, suspect, or receive allegations of trafficking in persons must immediately report it to PATH following PATH’s Trafficking in Persons Procedures.

Consequences of Violations

PATH personnel who commit trafficking in persons activities as described in this policy; fail to report or forward reports of trafficking in persons; or otherwise violate this policy or related procedures, will be subject to disciplinary action, up to and including termination of employment or contract.

Last updated December, 2019