PSI CODE OF BUSINESS ETHICS AND CONDUCT
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PSI CODE OF BUSINESS ETHICS AND
CONDUCT
Introduction
Population Services International (PSI) strives for the highest standards of ethical behavior. We are
committed to act at all times in a manner consistent with the laws of the United States as well as other
laws and regulations applicable to our work around the world. This Code of Business Ethics and Conduct
(“Code”) sets forth the standards for PSI employees worldwide with respect to ethical behavior, legal
compliance, and business and professional conduct. PSI employees are expected to perform their duties
in good faith, with honesty and integrity, and in furtherance of the mission, goals and purposes of our
organization. The reputation of PSI depends on employees’ adherence to these values and to the
principles and standards set forth below.
Following this introductory section, the Code is presented in two parts. Part I is a Code of Business
Ethics and Conduct (COBEC), required under U.S. Government contracts. Employees are asked
periodically to certify in writing that they have received and read the COBEC. Part II sets out additional
conduct guidelines for PSI employees.
These policies supplement but do not replace policies set forth in Country Programs. All country and
local laws supersede PSI HQ policy where applicable.
Compliance
Employees have a responsibility to understand and follow this Code, and may be required to certify
periodically that they have reviewed it. A violation of the Code may result in disciplinary action up to and
including dismissal. The Code is subject to revision at any time by PSI with appropriate notification to
employees.
Questions about compliance with this Code should be referred to the Director, People Department.General Principles
The following general principles form the basis for the standards contained in this Code. While the Code
seeks to address the major ethical and legal challenges employees may face, it cannot anticipate every
situation. In circumstances not covered by this Code, employees are expected to use these principles as
guides in determining proper conduct. Employees who perform any procurement or logistics
functions for PSI should also consult the PSI Procurement and Logistics Code of Conduct.
1. Employees must comply with all laws, regulations, and other official directives governing their
own or PSI’s activities in the United States and abroad. Laws and customs vary throughout the
world, but employees must uphold the integrity of PSI in all countries in which it does business.
In the case of any conflict or discrepancy between the laws of the U.S. and another country,
employees should consult with the Director, People Department.
2. Employees have a duty of loyalty to PSI. They must at all times place loyalty to our organization
and its mission above private gain and must avoid any act or omission that might tarnish PSI’s
reputation.
3. Employees are expected to conduct themselves in a professional, respectful and appropriate
manner at all times and in all situations in which they are on PSI premises, engaging in PSI
business, or representing PSI in any fashion.
4. Employees should act fairly and impartially, ensuring that evaluations and selections are
conducted without improper bias.
5. Employees must refrain from improper attempts to influence government officials in the U.S. or
abroad.
6. Employees are expected to deal honestly and transparently with PSI’s funders, board members,
fellow employees, and program partners, making sure that information shared and representations
made are complete, accurate and clear.
7. Employees should report any illegal, unethical, or wasteful activity of which they become aware
in the manner directed by PSI policies.
8. Employees should avoid seeking loopholes, taking shortcuts, or relying upon “technicalities” to
avoid responsible conduct, and reject any notion that unethical behavior is acceptable because
“everyone is doing it.”
9. Employees should avoid any actions creating even the appearance that they are violating any laws
or any standards of ethics or conduct set forth in this Code.
2PSI CODE OF CONDUCT – PART I
Conflicts of Interest
Personal Conflicts of Interest and Conduct of PSI Business
Employees should avoid situations in which their personal financial or other interests could conflict with,
or even appear to conflict with, the interests of PSI or their responsibilities to conduct PSI business fairly,
impartially, and in compliance with this Code. Conflicts of interest arise when an individual’s position or
responsibilities at PSI present an opportunity for personal gain or profit for that individual or someone
they are close with, or where the employee’s interests are otherwise inconsistent with those of PSI. Some
apparent conflicts of interest may be resolved through disclosures and authorized waivers. A conflict of
interest may arise in any number of situations and it is impossible to describe each and every instance.
While not exhaustive, some areas of potential conflict of interest are addressed below:
1. Absolute Prohibition. An employee may not participate in the selection, award, or administration
of a PSI contract, subcontract, grant, sub grant, loan or other funding mechanism if the employee,
a member of his/her immediate family, or business associate has any current or prospective
interest, financial or otherwise, including current or prospective employment, in an entity being
considered or selected for an award.
2. Other Potential Financial/ Representational Conflicts: If an employee, spouse, domestic partner or
any other member of an employee’s immediate family has or is considering a financial or
organizational interest (as an employee, consultant, business partner, investor, borrower, lender,
beneficiary, or paid or unpaid board member or trustee) in a PSI competitor, contractor,
consulting firm, customer, vendor, donor or funding recipient, the employee should promptly
disclose this interest to the Director, People Department (Investments in the stock of public
companies are exempt from this restriction, unless the size of an investment puts the employee in
a position to influence the company’s decision-making). If PSI determines that the interest
disclosed presents an actual or potential conflict with the interests of PSI, the employee may be
directed to take appropriate steps to avert or resolve such conflict.
3. Outside employment/ Board membership: An employee of PSI who wishes to (i) perform
services for, or accept employment from, anyone other than PSI, (ii) engage in any other business
or professional activity with an outside entity, or (iii) accept a significant leadership position,
including board membership, in another organization (with or without compensation), should do
so only after obtaining prior written approval from his/ her supervisor and the Director, People
Department. Note: Approvals are not required for membership in PSI Affiliates’ boards.
Employees may not use PSI time or resources to further non-PSI business. At no time may
an employee’s outside employment or other activity (i) interfere in any way with the fulfillment
of the employee’s duties to PSI; (ii) adversely affect the quality of the employee’s work; (iii)
compete in any way with PSI; (iv) compromise PSI’s reputation; or (v) imply sponsorship or
support by PSI of an outside affiliation.
4. Use of Proprietary Material. Employees may not use any PSI property or information learned in
the course of employment at PSI for personal financial gain or to compete with PSI.
Organizational Conflicts
3Employees should be mindful of, and comply with, U.S. Government rules designed to prevent unfair
competitive advantage in bids for government contracts. These include restrictions on:
1. Participation in a competition by an organization under contract to design the scope of work for that
competition; and/or
2. Use of contractor bid or proposal information or government source selection information not
available to all competitors and/or obtained from a government official or otherwise without proper
authorization. Specifically, employees are prohibited from soliciting, receiving or disclosing, directly
or indirectly, federal, state, local, municipal or foreign government “source selection” information
other than with proper authorization and through official means or methods. “Source selection”
information is information not previously made available to the public that is prepared for use by an
agency evaluating a bid or proposal, such as listings of offers and prices, identification of bidders prior
to bid openings, technical evaluation plans, technical evaluations of competing proposals, competitive
range determinations, and evaluations and recommendations. Employees are also prohibited from
soliciting, receiving or disclosing, directly or indirectly, any information submitted by a prospective
contractor to a government agency in connection with a bid or proposal, including cost or pricing data,
indirect costs and direct labor rates, proprietary information, and any other information marked by a
contractor as “contractor bid or proposal information.”
Policy Against Discrimination and Harassment
Policy Against Discriminiation
PSI prohibits, and will not tolerate discrimination against any employee or prospective employee on the
basis of race, color, religion, sex, age, marital status, national origin, disability, status as a veteran or
disabled veteran, personal appearance, sexual orientation, gender identity or expression, family
responsibilities, genetic information, matriculation or political affiliation. This policy extends to all
aspects of employment, including hiring, transfer, promotion, training, working conditions, compensation,
benefits, evaluation, discipline and termination.
Policy Against Harassment
PSI is also committed to providing a work environment that is free of unlawful harassment. Accordingly,
PSI prohibits any statement, action or conduct by any employee, or by any other person working for PSI,
that reasonably could be viewed as harassment. Comments, actions, or displays based on another’s race,
color, religion, sex, age, marital status, national origin, disability, status as a veteran or disabled veteran,
personal appearance, sexual orientation, gender identity or expression, family responsibilities, genetic
information, matriculation or political affiliation will not be tolerated. For specific guidance on sexual
harassment, and reporting and investigation of all forms of unlawful harassment, please see Section II of
this Code.
Policy Against Interference and Retaliation
PSI employees may not interfere with, or retaliate against, another employee who seeks to invoke his or
her rights under labor, employment, equal opportunity/non-discrimination, or any other laws.
Sex Trafficking and Forced Labor
1. PSI has a zero tolerance policy with respect to trafficking in persons. Employees are prohibited from
engaging in severe forms of trafficking, procuring commercial sex acts, or using forced labor in the
performance of a U.S. government-funded project.
42. PSI opposes prostitution and sex trafficking and forbids its employees from engaging in any practice
that attempts to promote or advocate the legalization or practice of prostitution or sex trafficking.
Nothing in the preceding sentence shall be construed to preclude the provision to individuals of
palliative care, treatment, or post-exposure pharmaceutical prophylaxis, and necessary
pharmaceuticals and commodities, including test kits, condoms and, when proven effective,
microbicides. Sex trafficking is defined as the recruitment, harboring, transportation, provision, or
obtaining of a person for the purpose of a commercial sex act.
Any violation of these prohibitions will result in disciplinary action, up to and including termination.
Drug Free Workplace
In order to maintain a safe and healthy work environment, to avoid drug-related performance and other
problems in the workplace, and to comply with the requirements of federal law, PSI is committed to
maintaining a drug free workplace at all times. The following rules implement the Drug-Free Workplace
Act of 1988 and reflect PSI policy and practice:
1. PSI employees are prohibited from the unlawful manufacture, distribution, dispensation,
possession, or use of a controlled substance in the workplace. The workplace is defined as any
PSI office or project site.
2. Any employee convicted of violating a Federal or State criminal drug statute in the workplace
must provide written notification to his/her supervisor and the Director, People Department, no
later than five (5) days after the conviction. Failure to notify the proper PSI officials within this
time period will result in immediate termination. Within thirty (30) days of receiving notice from
an employee of a drug conviction, PSI will notify the employee of his/her obligation to participate
in an approved drug abuse assistance or rehabilitation program.
3. An employee who is convicted of violating a criminal drug statute in the workplace, or who
violates any other aspect of this policy, may be subject to disciplinary action, up to and including
termination.
Use of a controlled substance as part of a prescribed medical treatment program will not be grounds for
disciplinary action. Employees undergoing a prescribed medical treatment with a controlled substance or
any medication that may affect employee behavior or performance should report this information to their
immediate supervisor or to the Director, People Department, so that appropriate accommodations, if any,
may be made. Every effort will be made to keep such reported information confidential.
PSI Property
Employees are responsible for the proper use of PSI’s resources and property.
Physical Property
1. Except for limited use for essential personal communications, PSI property, facilities and physical
resources, including computers, phones and fax machines, may not be used for any non-PSI
business. This includes solicitation, promotion or distribution activities unrelated to an
employee’s duties, except for charitable activities that have been approved in advance in writing
by the employee’s supervisor and the Director, Facilities Department.
2. Any employee found to be engaging in or attempting theft or other improper use or diversion of
PSI property, including funds, credit or debit cards, bank accounts, documents, equipment,
5intellectual property, personal property of other employees, or any other items of value, will be
subject to immediate discharge and possible criminal proceedings. Employees have a
responsibility to report any such activities to PSI management.
3. PSI management reserves the right to inspect any employee’s assigned workspace, desk,
computer or phone when there is a management or business reason to do so, and to allow another
employee to use such workspace, computer, desk, and phone when the employee is not in the
office.
Intellectual Property
1. Employees are expected to take all necessary steps to protect PSI intellectual property
a) Any work produced in the course of employment at PSI is the exclusive property of PSI.
Employees waive any rights, including intellectual property rights, in such work product,
and are prohibited from reproducing, distributing or making any other use of it outside
PSI without express written authorization from the employee’s supervisor and the
Director, People Department.
b) Any work developed, designed or authored by or on behalf of PSI or by any of its
employees and authorized for external distribution, including any websites or other
material posted on the Internet, must bear a copyright notice in the form prescribed by
federal copyright law.
c) All brands and logos developed by PSI must be registered as trademarks in any country
in which they will be used in connection with products or services. Employees should
consult with the Corporate Marketing Department concerning trademark registration.
2. Employees must avoid the unauthorized use of copyrighted materials of others, including
material which may be readily available without charge on the Internet. Employees should
confer with their supervisor and the Corporate Marketing Department if there is any question
regarding the permissibility of photocopying, excerpting, displaying, distributing,
electronically copying, transmitting, or otherwise using copyrighted materials. Similarly,
using the trademark or service mark of another company, even one with which PSI has a
business relationship, always requires approval by the Corporate Marketing Department to
ensure that the use of the other company’s mark is proper and in accordance with any
applicable PSI agreements.
3. Employees are expected to comply fully with license agreements that govern the use of
software created and/or copyrighted by entities other than PSI. Reproducing or installing
software without authorization may violate these agreements and be illegal.
Confidential and Proprietary Information
1. PSI Confidential & Proprietary Information should never be given to an outside firm or individual
without appropriate prior authorization. As a condition of employment at PSI, all employees
must agree not to disclose any PSI Confidential or Proprietary Information during or after
employment to anyone outside PSI, except as authorized by PSI, or as otherwise required by law.
“PSI Confidential or Proprietary Information” includes, without limitation, any information
regarding PSI’s employees, operations, products, services, strategies, research, policies, systems,
budgets, proposals, finances, programs, plans, donor or business relationships, or any other
information not generally known to the public that is learned by the Employee as a consequence
of employment by PSI. Any improper transfer or disclosure by an employee of material
containing PSI Confidential or Proprietary Information, even though it is not apparent that the
employee has personally gained by such action, constitutes unacceptable conduct. Participation
62. PSI is an open environment and as such, employees may have access to internal information of a
confidential or sensitive nature. Dissemination of such information should be limited to those
employees properly and directly involved in work or deliberations relating to it. Confidential or
sensitive internal information includes proposals, budgets, marketing plans, salaries, costs and
other internal financial data, material in personnel files, and similar information. It is a
requirement of employment that employees maintain confidentiality both internally and
externally. Those employees whose job responsibilities entail regular or frequent access to
sensitive, confidential or proprietary information concerning PSI employees (such as personnel
records and employee compensation), accounting and finances, confidential communications,
passwords and other information intended for limited internal access or distribution are expected
to be especially vigilant in maintaining the strict confidentiality of this information. Some
employees with access to higher levels of sensitive, confidential or proprietary information may
be required to sign a Restricted Information Agreement that details the requirements for
maintaining such confidentiality and outlines the procedures for reporting violations or
unauthorized use.
3. Employees who leave PSI are required to return all documents (including any hard copies or
electronic versions) that belong to PSI, relate to PSI or its employees, activities, finances, systems
or operations, or that contain PSI Confidential or Proprietary information.
4. To protect against deliberate or inadvertent disclosure outside PSI of any sensitive, confidential or
proprietary PSI information, and to protect PSI’s investment in the training and development of
its employees, PSI requires employees to agree to the following additional restrictions:
a) While employed at PSI, and for a period of one year thereafter, employees may not directly
or indirectly solicit or induce, or attempt to solicit or induce, any PSI employee to leave
employment with PSI for any reason whatsoever.
b) While employed at PSI, an employee may not knowingly authorize his/her name to be used
by any organization other than PSI in connection with a bid for contract, grant, or other
award, without prior written authorization from PSI. An employee may be required to pay
PSI as much as $25,000 for violation of this prohibition, and be subject to immediate
dismissal.
Reports and Records
1. When preparing reports, budgets, statements, invoices, time sheets or other documentation for
government bodies, donors, or contracting agencies, employees must see to it that information
provided is accurate, complete, clear, and presented in a manner designed to enlighten and not to
mislead. Under no circumstances may an employee make a claim for payment for amounts not
properly due to PSI for work performed or goods or services provided, or any other false
statement, representation or certification on behalf of PSI, in either written or oral form. This
includes falsification of time sheets or other time records, cost reports, expense reports, pricing
proposals, certifications relating to cost or pricing data, or requests for payment.
2. PSI employees responsible for financial and/or personnel recordkeeping must see to it that such
records are developed and maintained carefully and accurately in accordance with all applicable
legal requirements and PSI procedures, and that PSI funds are scrupulously expended and
accounted for. Access to such records should be limited to those employees who require it to
carry out their job responsibilities.
73. Documents related in any way to an ongoing or potential investigation of PSI by a government
agency or to any other official proceeding must not be destroyed, discarded or altered. Employees
should familiarize themselves with and follow PSI’s document retention policy.
4. PSI records and documents are not to be removed from PSI premises without the express prior
permission of the employee’s manager.
Audits and Investigations
Employees are expected to cooperate fully with all authorized investigations, including internal audits and
any external audits by, or required by, PSI donors, government agencies, or related bodies, and must
never lie to or mislead an investigator or obstruct the collection of information relating to an investigation
or a legal proceeding. Employees must always consult in advance with their supervisors and/or the Chief
Financial Officer (CFO) to make sure they understand the scope of their responsibilities in connection
with particular audits or investigations.
Dealings with Government Officials
Employees may not offer or provide, directly or indirectly, any money, in-kind compensation, gifts, loans,
rewards, services, facilities, transportation, entertainment, lodging, meals, or any other favors or things of
value to any federal, state or local government employee, including members of Congress or their staffs,
with a view to inducing such employee to use his/her influence in an action or decision relating in any
way to PSI, including the award or modification of grants, contracts, cooperative agreements, or loans.
Employees should consult with their supervisors and the Director, People Department before discussing
employment possibilities with any current or former U.S. Government employee to insure compliance
with federal laws concerning the hiring of former government employees.
Gifts and Payments
All forms of bribery and kickbacks are illegal and strictly prohibited. Employees may not offer, provide
or accept any form of payment, including monetary compensation, credit, gifts, gratuities, favors,
entertainment, meals, transportation, lodging, services, facilities or any other thing of value, directly or
indirectly, as a “kickback” to influence, or be influenced by, any person or entity for the purpose of
obtaining favorable treatment in connection with a contract, subcontract, grant, sub grant or any other
benefit to or from PSI. Any employee who is asked to make or accept a prohibited kickback or bribe
should report this immediately to his/ her supervisor.
Employees may not give or accept money, credit, gifts, gratuities, favors, entertainment, meals,
transportation, lodging, services, facilities or anything else of value to or from parties to current funding
agreements with PSI, other than gifts of nominal value not exceeding $20 per source per occasion, or
$100 to or from any single source in a calendar year, without prior approval from an employee’s
supervisor. The onus is on each individual employee to keep track of such gifts up to the limits indicated
and to provide adequate proof if required.
Political Activity
No PSI funds, property, assets, services or facilities may be used, directly or indirectly, to participate or
intervene in any political campaign on behalf of, or in opposition to, any candidate for public office, or
contributed to or used by any political party, campaign, political action committee or public office-holder.
No U.S. Government funds may be used, directly or indirectly, to influence or attempt to influence:
81. The outcome of any federal, state or local election, referendum, initiative or similar procedure; or
2. The introduction, enactment, or modification of federal or state legislation (commonly called
“lobbying”).
PSI employees, with the approval of appropriate management and Government Affairs personnel, may
provide technical or factual information, analysis and research results to legislators or their staffs in
response to documented requests for such information.
The prohibition on lobbying does not apply to the activities of PSI’s Government Affairs staff which are
not charged to the USG, and which are conducted within special legal guidelines applicable to authorized
lobbying activities. Any PSI employee who is contacted by, or is considering contacting any
Member of Congress, congressional staff, Executive Branch official, or any state-level elected
official, legislative or administrative staff must consult with the Government Affairs staff before
engaging in any such contact.
Prohibitions on political activity by PSI employees do not extend to:
1. Making voluntary personal contributions to political candidates, organizations or causes;
2. Engaging in political activities on an employee’s own time, off PSI premises, and at the
employee’s own expense;
3. Expressing views on legislative or political matters; or
4. Participating in any other lawful political events or activities. However, any political activity or
contribution that might create even the appearance of a contribution or endorsement by PSI is
prohibited unless approved in advance by the Regional Director or the Executive Office.
Conduct of Employees Overseas
1. Employees may not pay, offer or promise to pay, or authorize anyone else to pay, offer or
promise to pay money or anything else of value to a foreign official, political party or party
official, or any candidate for foreign political office, directly or indirectly, including through
agents or intermediaries, with the intent to induce the recipient to misuse his/her official position
to obtain or retain business for PSI or to direct business to any other person. To avoid any such
violation, employees should exercise due diligence and take all necessary precautions to ensure
that they enter business relationships on behalf of PSI with reputable and qualified partners and
representatives.
2. Employee assigned to work overseas or on an overseas project may not (other than assigned work
on such project) engage, directly or indirectly, either in his/her own name or in the name or
through an agency of another person, in any business, profession or occupation in any such
country of assignment, nor make any loans to or investments in any business, profession or
occupation in such country of assignment, except in a country where the employee is a citizen or
legal resident.
3. Employees working on U.S. Government-funded projects overseas should also be aware that the
sale of automobiles and other personal property in foreign countries may be subject to restrictions
and should consult with the Director of Contracts before engaging in any such transaction.
4. In some countries, it is customary and lawful for business leaders to give gifts. If an employee
receives such a gift of more than nominal value under circumstances where returning the gift or
offering to pay for it may be considered an affront to the giver, the employee should report the
gift immediately to his/her supervisor. In such instance, the gift may be given to a charitable
institution, and the giver informed of its disposition, if appropriate.
9Sanctions, Export Controls, and Trade Embargoes
Employees must take care to comply with all applicable international economic sanctions, prohibitions or
limitations on resource transfers, and legal restrictions or embargoes on travel and/or trade. These
include: (i) the USA Patriot Act and related legal requirements prohibiting terrorist financing; (ii)
country-specific economic sanctions programs administered by the U.S. Department of Treasury’s Office
of Foreign Assets Control (OFAC); and (iii) export controls administered by the U.S. Department of
Commerce’s Bureau of Industry and Security (BIS). Employees should consult with their supervisor for
guidance on compliance with these requirements.
Reporting Violations
Employees who become aware of any suspected, planned or actual violation of laws, regulations,
financial or accounting standards, or PSI policies, including this Code, by an officer, director, employee
or any other person connected with PSI, should immediately report this as directed in the PSI
Whistleblower Policy below. Employees are expected to cooperate fully with any investigation by PSI or
a governmental authority into a possible violation.
Whistleblower Policy
PSI employees are expected to observe the highest standards of business and financial ethics and to
comply with all applicable laws, regulations and PSI policies in the conduct of their duties. PSI urges
employees to report any suspected financial or accounting impropriety or illegal or unethical business
behavior without fear of retribution.
Should an employee become aware of, or be concerned about, financial or other activity which he or she
believes in good faith to be illegal, dishonest, unethical, fraudulent, or in violation of PSI policy, the
employee should report this to his/her immediate supervisor, director, or the People Department Director.
Supervisors and directors should promptly convey such reports to the People Department Director and/or
the CFO.
If an employee is uncomfortable reporting activity he/she believes to be improper through internal PSI
channels, or is not satisfied with the response received, such activity may be reported on a confidential
basis or submitted anonymously to EthicsPoint, the outside firm retained by PSI for this purpose, using
the contact information below. EthicsPoint will be responsible for passing on reports they receive to PSI
management or the PSI Board, so that the appropriate actions may be taken to resolve concerns raised.
Whistleblower Hotline Information
EthicsPoint may be contacted through any of the following methods:
1. toll free number: 888-238-1438
2. this direct link: http://www.psi.ethicspoint.com
No employee who reports a suspected violation under this policy, provides information to a law
enforcement official or agency, or assists in the investigation of a suspected violation will suffer
harassment, retaliation, discrimination, or adverse employment action of any kind, even if a subsequent
investigation determines that no violation occurred, provided the employee report is made in good faith
and with reasonable belief in its accuracy.
Employee complaints of harassment, retaliation, discrimination or adverse employment action in violation
of this policy should follow the reporting procedures outlined above, and will be promptly investigated.
If an investigation results in a determination that there has been retaliation or other prohibited action
against an employee, appropriate corrective action will be taken.
10Employees are expected to exercise sound judgment to avoid baseless allegations. An employee who
knowingly or recklessly makes an allegation or disclosure that proves to be unsubstantiated may be
subject to discipline, up to and including dismissal.
Reports by employees of violations or suspected violations, as well as the identity of whistle-blowers, will
be kept confidential to the extent possible, consistent with the need to conduct a thorough investigation.
PSI CODE OF CONDUCT – PART II
Professional Conduct
PSI promotes a productive work environment in which professional and appropriate conduct is expected
of all employees. While it is not possible to compile a complete list of all of the possible actions or
behaviors that might violate these standards and result in disciplinary action, examples of misconduct in
addition to those addressed elsewhere in this Code that may subject an employee to disciplinary actions
up to and including termination include the following:
1. Excessive absenteeism or lateness; absence without notification.
2. Failure to satisfactorily perform assigned duties.
3. Engaging in conduct that is detrimental to the development of a cooperative "team" work
environment or otherwise disruptive of harmonious working relationships.
4. Dishonesty.
5. Insubordination or argumentative reluctance.
6. Threatening, intimidating or coercing any employee on or off the job.
7. Behavior which interferes with operations or brings discredit to PSI or other employees.
8. Theft or destruction of property belonging to PSI or to other employees.
9. Physical assault upon another employee or visitor.
Sexual and other Prohibited Harassment
Unwelcome sexual advances, requests for sexual favors, and other verbal or physical conduct of a sexual
nature constitute sexual harassment when:
1. submission to such conduct is made either explicitly or implicitly a term or condition of an
individual’s employment;
2. submission to or rejection of such conduct by an individual is used as the basis for employment
decisions affecting such individual; or
3. such conduct has the purpose or effect of unreasonably interfering with an individual’s work
performance or creating an intimidating, hostile or offensive working environment.
Sexual harassment can include, but is not limited to:
a) Verbal harassment: Any of the following, whether conveyed orally or in writing – sexual
innuendos, suggestive comments, or graphic expressions about an individual’s body; jokes or
vulgar language of a sexual nature; sexually degrading words used to describe an individual;
11repeated offensive or unwanted flirtation, advances, propositions or threats; and repeated
verbal abuse, whether of a sexual nature or otherwise.
b) Physical actions: Unwanted physical contact, including touching, pinching, brushing the
body, impeding or blocking normal work or movement, or coerced sexual acts.
c) Inappropriate displays: Sexually suggestive objects or pictures, sexually graphic
commentaries, suggestive or insulting sounds, leering, or obscene gestures.
Sexual harassment does not generally include occasional compliments of a socially acceptable nature. It
also does not include consensual relationships. Commonly accepted “fraternization” among employees,
defined as conduct of a socially acceptable, friendly and congenial nature that adds to team building or a
pleasant work environment is not considered sexual harassment. However, some behavior which is
appropriate in a social setting may not be appropriate in the workplace. When “fraternization” goes
beyond what reasonably can be deemed behavior of a socially acceptable nature in the workplace and/or
becomes unwelcome, it may become sexual harassment.
Harassment via Electronic Communications
PSI’s harassment policy applies equally to communications via e-mail, Internet, telephone, text
messaging, voice mail, facsimile, or any other electronic means of communication.
Unique Nature of PSI’s Work
Due to the unique nature of PSI’s work marketing condoms and other contraceptives and educating
people about sexual and reproductive matters, employees who join PSI must understand and accept that
sexually explicit discussions are an integral part of accomplishing our mission. Appropriate oral and
written communications conducted in connection with PSI’s work will not be considered sexual
harassment. By accepting employment at PSI, each employee acknowledges and accepts this special
work condition.
Reporting and Investigation of Complaints
Any employee who becomes aware of sexual or other prohibited harassment, or any sexually
inappropriate conduct, whether affecting themselves or others, has an obligation to report this to his or her
supervisor, to a member of the People Department, or to any other member of PSI management. An
employee who has a complaint against the President of PSI or who otherwise is not comfortable reporting
sexual or other harassment via established internal channels may contact Ethics Point (see Whistleblower
policy). Employees are strongly urged to report harassment before it becomes severe or pervasive.
Any supervisor or manager who receives a complaint of possible sexual or other prohibited harassment
should promptly contact the Director, People Department, so that an investigation may be initiated in a
timely manner.
All complaints of sexual or other prohibited harassment will be investigated promptly and thoroughly.
Where appropriate, PSI may use outside experts to investigate a complaint of harassment. PSI will make
every effort to protect the confidentiality of employees lodging complaints or participating in
investigations under this policy. However, PSI cannot guarantee complete confidentiality, since an
effective investigation may not be possible without revealing certain information to the alleged harasser
and/or potential witnesses.
12No employee will suffer retaliation for reports of harassment if made in good faith. PSI encourages any
employee to bring questions regarding this policy and its implementation to the Director, People
Department.
Consequences for Violation of Policy
Any PSI employee or contractor who violates PSI’s policy against harassment will be subject to
appropriate corrective action, ranging from a disciplinary warning to termination. PSI may take whatever
corrective action necessary to prevent inappropriate employee behavior before such behavior reaches the
level of legally actionable harassment.
Filing a Formal Charge of Harassment
Employees should also be aware that the D.C. Office of Human Rights and the Federal Equal
Employment Opportunity Commission (EEOC) investigate and prosecute complaints of prohibited
harassment in employment. Complaints must be filed with the D.C. Office of Human Rights within one
year of the occurrence or discovery of harassment, and with the EEOC within three hundred days of the
alleged violation. Please note that these deadlines run from the last date of the alleged unlawful
harassment, not from the date a complaint to PSI management is made or resolved.
Close Personal Relationships
PSI seeks to avoid potential internal conflicts of interest posed by close personal relationships between
employees, including local staff in PSI and affiliate offices. “Close personal relationships” include
marriage, domestic partnership or other committed relationships, close familial relationships (i.e., parent-
child, sibling), or consensual romantic or sexual relationships. To ensure that close personal relationships
between employees do not influence decisions with respect to hiring, evaluation, compensation,
assignment, training, promotion, discipline, termination, or any other aspect of employment, any
employee engaged in a close personal relationship with another PSI employee is responsible for
disclosing this in writing to the Director, People Department. Each participant in a close personal
relationship is also responsible for notifying the Director, People Department in writing in the event the
relationship ends. When informed of a close personal relationship in accordance with this policy, the
Director, People Department, will consult with the appropriate parties and recommend steps to address
any resulting workplace issues. Such steps may include reassignment of duties, transfer, or change in
reporting relationship. At a minimum, steps will be taken to insure that a manager will no longer
supervise or participate in decisions, either directly or indirectly, that may affect another employee with
whom he or she has a close personal relationship. The Director, People Department, will also review
each situation to insure that there is no evidence of sexual harassment.
Drug and Alcohol Use Policy
PSI employees are expected to come to work able to perform their duties productively and safely. Use of
illegal drugs (including misuse of prescription medication) or alcohol on PSI premises or during work
hours, or arriving at work under the influence of illegal drugs or alcohol is strictly prohibited. Employees
are expected to comply with PSI’s Drug Free Workplace Policy, detailed in Part I of the Code, and the
alcohol use policies set forth below.
13Except for PSI-sponsored events, consumption of beverages containing alcohol on PSI premises is strictly
forbidden. Additional rules concerning permissible alcohol consumption are detailed below
PSI is proud of the unique dedication and spirit of its employees and encourages opportunities for
informal socializing and celebration of successes. At the same time, we take very seriously our
responsibility to protect the safety of our employees, guests, and others with whom they come in contact.
PSI has adopted the following guidelines for all PSI sponsored functions, whether held on or off PSI
premises:
1. A “PSI-sponsored” function includes any event (i) held at a PSI office or worksite, or (ii) funded
or reimbursed even partially by PSI.
2. Any PSI-sponsored event at which alcohol will be served must be authorized in advance in
writing by a member of senior management (Director level and above). No alcohol may be
consumed on PSI premises or using PSI funds without such prior written authorization.
3. Employee attendance at any event at which alcohol is served must be entirely optional, and these
events should not serve as occasions to conduct official PSI business.
4. Employees of legal drinking age are welcome to attend PSI-sponsored events at which alcohol is
served, but are expected to act responsibly and to drink, if at all, in moderation. Employees are
reminded that their behavior at PSI-sponsored events reflects directly upon our organization.
5. Each PSI sponsored event must have a designated employee in attendance who voluntarily
assumes responsibility for ensuring that alcohol consumption follows company guidelines and
that the bill for the alcohol does not exceed limits set as part of the event’s authorization or
otherwise. Employees are expected to comply with any direction given by such designated
employee.
6. At PSI sponsored events at which alcohol is served, PSI may offer alternative ride home solutions
when necessary (recommending a taxi ride or a ride home with a fellow employee, offering to
pay for safe transportation, etc.).
Other Alcohol Use Guidelines
While employees are free to make their own decisions about consuming alcohol off work premises and
outside of work hours, any work conducted while an employee is under the influence of alcohol that does
not meet PSI standards of quality and professionalism will be reflected in performance evaluations.
Following the consumption of alcohol above the legal limit employees should not drive any vehicle.
Following consumption of any amount of alcohol above the legal limit employees may not (i) drive PSI-
owned or leased vehicles; or (ii) drive any vehicle containing PSI employees, contractors, volunteers,
vendors, clients, customers, program partners or participants, board members, or donor personnel.
All PSI behavior standards and policies, including the sexual harassment policy, are in effect both on and
off PSI premises, including all PSI-sponsored events, and apply whether or not alcohol consumption is a
contributing factor.
PSI reserves the right to require any employee to submit to drug or alcohol testing at any time during
normal business hours.
PSI’s Employee Assistance Program (EAP) is available to employees if they have concerns about the use
of drugs or alcohol. Employees should contact the appropriate People Department contact or the Health
Insurance vendor for more information.
Dress Code
14In order to maintain PSI’s professional image both internally and with the public, employees are expected
to dress in appropriate professional attire at all times. Monday through Thursday employees should wear
business attire; Fridays employees may wear casual attire, which includes jeans. Employees may also
dress in casual attire on days when PSI is open for a half day because of a scheduled holiday and on days
when the office opens late due to inclement weather. Tank tops, shorts, flip flops and sneakers are not
considered appropriate professional attire even on days when PSI allows casual attire. Customary
business attire is expected when you are meeting with external clients, vendors or are representing PSI.
Access to Personnel Files
PSI Maintains a personnel file on each domestic and international employee. The personnel files may
contain such items as, but not limited to: resumes, biodatas, evaluations, application forms, memos and
insurance information. You may not add or remove anything from your personnel file.
In addition, management staff has the right to review the personnel files of their immediate reports and of
PSI staff who have applied for and are being considered for a position within the department. Information
available to the supervisor includes performance and salary related data, attendance and disciplinary
records, and training and development.
The personnel files are the property of PSI and access to the files is restricted. If an employee
wishes to review their file,he/she must make a request in writing to the appropriate People Department
contact.
Counseling and Disciplinary Action
A current employee who is not meeting the expectations of his/her position may be subject to an
accelerated review process including more intensive direction and coaching from his/her supervisor
toward achieving improved performance and expected results. A follow-up evaluation will be conducted
as appropriate.
PSI retains full discretion to modify or eliminate its review procedures, to maintain compensation levels
without annual increases, or to decrease compensation where necessary.
An employee whose job performance, work habits, conduct or demeanor, in the sole judgment of PSI, fail
to conform adequately to the policies and expectations of PSI, may be subject to disciplinary action, up to
and including termination. Forms of discipline that PSI may use include verbal warnings, written
warnings and final written warnings. Where possible, warnings will include counseling to the employee
about steps he/she can and should take to avert more serious job consequences. This system is not
formal, and PSI may, at its sole discretion, from any order of progressive disciplinary actions and utilize
whatever form of discipline it deems appropriate under the circumstances, up to and including immediate
termination without notice.
[Note: Nothing in this section or the previous section on performance evaluations is to be read or
interpreted to modify the “at will” status of all PSI employees, which gives PSI the right to terminate any
employee, at any time, with or without cause.]
Administrative Leave
Under certain unusual circumstances, PSI management may determine that an employee should take
administrative leave while his/her employment status with PSI is evaluated. PSI will determine whether
the leave will be paid.
15Grievance Procedure
When an employee has a concern about the conditions of his or her job, it should be brought to the
attention of the employee’s supervisor. [Note: For procedures in the case of concerns about possible
discrimination or harassment, please see Manual sections on those subjects.]
An employee who is not satisfied with the outcome of discussions with his/her supervisor, or feels it is
inappropriate to speak with the immediate supervisor, is encouraged to request a meeting with the
Director, People Department, or the next level of management (your supervisor’s immediate manager) to
air the issue. Employees have access to all levels of management to ask questions, offer suggestions and
resolve problems.
PSI does not tolerate any form of retaliation against employees who avail themselves of this grievance
procedure. This procedure should not be construed, however, as preventing, limiting, or delaying PSI
from taking disciplinary action against any individual, where appropriate, or from exercising its “at will”
termination rights.
The grievance procedure is established to promote open, two-way communication between employees
and all levels of management. To ensure effective working relations, it is important that grievances be
raised so they can be addressed before serious problems develop.
Resignation
Any employee planning to resign from PSI is requested to give written notice to their immediate
supervisor and provide a copy to the appropriate People Department contact minimum of three weeks
prior to his or her last day of employment, in order to provide sufficient time to recruit and train a
replacement. This will allow PSI to conduct a smooth transition and avoid disruption of field activities.
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