How we apply our code of ethics, governance, and responsibility
PATH has established policies for responsible conduct in governance, workforce environment, research, collaboration, financial stewardship, intellectual property and confidential information, conflict of interest, communications, advocacy, and the environment. These policies guide our work in accordance with our code of ethics, governance, and responsibility.
In all aspects of our work, PATH adopts applicable and good-practice governance rules and principles. These include United States and other countries’ rules governing 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 govern 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 by-laws 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 issues.
PATH is committed to a work environment in which all employees are treated with respect and dignity. Each employee has the right to work in a professional atmosphere that promotes equal employment opportunities and prohibits discriminatory practices, including harassment. Therefore, PATH expects that all relationships among persons in the workplace will be professional and free of bias, prejudice, and harassment.
To ensure accountability and transparency, PATH has established internal policies and procedures that provide clear direction regarding diversity, harassment, and professional conduct. We follow local laws and regulations regarding these areas and strive to follow evolving best practices.
PATH also cares about the health and welfare of our employees. We are committed to complying with all applicable laws and developing policies and effective practices for a safe and healthy workplace, wherever we operate. We also have developed and maintain policies, particularly for safe travel and crisis management, that help us ensure the safety of our staff.
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 Research Determination Committee charged with determining which data-collection activities fall under the US Government’s definition of research and a Research Ethics Committee that, under a federal-wide agreement with the US Government, reviews both biomedical and behavioral research. PATH’s vaccine clinical trial research is reviewed by an independent ethical review board. All of PATH’s human subjects research must undergo a separate review for scientific merit.
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 that PATH contracts with third parties to perform must adhere to this policy.
We require our senior leaders and all staff with significant 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 Scientific Integrity Policy includes administrative processes to ensure that 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 well suited to the work at hand. Among potential nonprofit partners, we seek collaborators that have values consistent with our own and a track record of success against their own missions. Among potential private-sector partners, 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.
PATH has adopted policies 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 circulars A-122 and A-133, 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 employee pension assets oversight. 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 accounts payable policies—that are intended to ensure ethical procurement of goods and services. Read more about our commitment to good stewardship.
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 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, or 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 non-public information, to use it only for PATH business and not 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 may create (or appear to create) a competing interest for the individual. Institutional conflict of interest may exist when the financial interests of the organization may 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 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 are guided by the PATH Investigator Conflict of Interest Policy (76 KB PDF).
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.
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 newsletters, annual reports, and the PATH website 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.
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.
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 also operates the Green PATH initiative, which guides staff in reducing energy consumption, reducing paper consumption, reducing the generation of non-recyclable waste, increasing recycling, and reducing our carbon footprint.