Financial Interest Disclosure Policy
As a 501(c)(3) education and research organization, APQC is committed to ensuring the disclosure of any financial or pecuniary interests of any program instructor, teacher, or leader in any of the materials, products, instruments, or other items prepared for, included or provided in connection with any APQC-sponsored learning program. APQC adopts this Policy to require the clear disclosure of any such interest (a) in the marketing materials of any program, (b) in the materials themselves, and (c) at the start of each training program.
All Interests to Be Timely Disclosed to APQC
This Policy requires that any program instructor, teacher, or leader disclose to APQC his or her financial or pecuniary interest in any of the materials, products, instruments, or other items to be prepared for, included or provided in connection with any APQC-sponsored learning program. Such interest(s) shall be disclosed in writing to APQC by the earlier of (a) the execution of any contract for services between APQC and the instructor or (b) the joint promotion or marketing of the program or any of its content or materials.
All Interests to Be Timely Disclosed by APQC
This Policy requires that APQC include in all promotional and marketing materials (e.g. email, website, brochure, etc.) any financial or pecuniary interest disclosed to or known by APQC that is subject to this Policy. In addition, any materials, products, instruments, or other items prepared for, included or provided in connection with any APQC-sponsored learning program that may be the subject of any financial or pecuniary interest shall include a clear disclosure of such interest and shall be printed in no smaller than 10-pt font and in such a manner as to be clearly visible to the reader.
Intellectual Property Rights Policy
As a 501(c)(3) education and research organization, APQC is committed to ensuring the intellectual property rights of all persons and organizations whose work may be incorporated in or disseminated in connection with any APQC-sponsored learning program. APQC adopts this Policy to ensure that all persons participating in or who develop materials for any APQC-sponsored learning program are (a) aware of this Policy, (b) understand the prohibition against the unlawful use, dissemination, or copying of intellectual property without permission, and (c) will comply with all applicable laws and contractual requirements for all such materials.
Statement on Intellectual Property Rights
Intellectual property includes any product that results from original creative thought and includes ideas, expressions, inventions, and other original products of the mind. Intellectual property includes:
• Copyright – the right of creators in their literary and artistic works
• Patents – the exclusive right of inventors
• Trademarks – the mark, characteristic, or signature used to distinguish products, goods, and services from another
• Designs – the two- or three-dimensional aspects of an article such as shapes, patterns, and the arrangement or use of colors
• Trade Secrets – confidential information that has economic value because the information is not generally known to others.
This Policy requires that all persons participating in or who develop materials for any APQC-sponsored learning program understand the prohibition against the unlawful use, dissemination, or copying of intellectual property without permission. Specifically, it is a violation of this Policy for any intellectual property to be included in any aspect of an APQC-sponsored learning event (whether in print or electronic format or by presentation, display, or statement) unless the appropriate, documented license or other rights have been secured from the owner of the intellectual property.
All materials that include the intellectual property of any third party must be promptly disclosed in writing to APQC at the earlier of (a) the execution of any contract for services between APQC and the provider or (b) the dissemination of any such materials.
Compliance with Law and Contract; Record Keeping
In addition, this Policy requires that all persons participating in or who develop materials for any APQC-sponsored learning program comply with all applicable laws and contractual requirements for all such materials.
Written proof of permission to use any copyrighted, trademarked, or patented materials must be kept on file no less than four (4) full calendar years following program or event at which the materials were included, used, disseminated, or displayed.
APQC is committed to a learning environment in which all individuals are treated with respect and dignity. Each individual has the right to participate in any APQC-sponsored program or event in a professional atmosphere that promotes fairness and prohibits unlawful discriminatory practices, including discrimination, harassment, or disparate treatment. Therefore, APQC expects that all relationships among individuals attending or participating in any APQC-sponsored program or event will be cordial, business-like, and free of explicit bias, prejudice, and harassment of any kind.
Equal Opportunity to Attend and Participate
It is the policy of APQC to ensure the opportunity of all persons to attend and participate in any APQC-sponsored event or program without discrimination, harassment, or disparate treatment on the basis of race, color, religion, sex, sexual orientation, gender identity or expression, age, disability, marital status, citizenship, national origin, genetic information, or any other characteristic protected by law. APQC prohibits any such discrimination, harassment or disparate treatment and will take appropriate corrective action to address any actual or alleged conduct in violation of this Policy.
APQC encourages reporting of all perceived incidents of discrimination, harassment, or disparate treatment. APQC prohibits retaliation against any individual who reports discrimination, harassment, or disparate treatment or who participates in an investigation of such reports.
Sexual harassment constitutes discrimination and is illegal under federal, state and local laws. For the purposes of this Policy, “sexual harassment” is defined as unwelcome sexual advances, requests for sexual favors and other verbal or physical conduct of a sexual nature when, for example: (a) submission to such conduct is made either explicitly or implicitly a term or condition of an individual’s participation in any program or event, (b) submission to or rejection of such conduct by an individual is used as the basis for adverse decisions or actions affecting such individual, or (c) such conduct has the purpose or effect of unreasonably interfering with an individual’s performance or participation or creating an intimidating, hostile, or offensive working environment.
Title VII of the Civil Rights Act of 1964 recognizes two types of sexual harassment: a) quid pro quo and b) hostile work environment. Sexual harassment may include a range of subtle and not-so-subtle behaviors and may involve individuals of the same or different gender. Depending on the circumstances, these behaviors may include unwanted sexual advances or requests for sexual favors; sexual jokes and innuendo; verbal abuse of a sexual nature; commentary about an individual’s body, sexual prowess or sexual deficiencies; leering, whistling or touching; insulting or obscene comments or gestures; display in the workplace of sexually suggestive objects or pictures; and other physical, verbal or visual conduct of a sexual nature.
All such conduct is a violation of this Policy.
Harassment on the basis of any other protected characteristic is also strictly prohibited. Under this Policy, harassment is verbal, written, or physical conduct that denigrates or shows hostility or aversion toward an individual because of his or her race, color, religion, sex, sexual orientation, gender identity or expression, national origin, age, disability, marital status, citizenship, genetic information, or any other characteristic protected by law, or that of his or her relatives, friends or associates, and that: (a) has the purpose or effect of creating an intimidating, hostile or offensive work environment, (b) has the purpose or effect of unreasonably interfering with an individual’s performance, or (c) otherwise adversely affects an individual’s participation in the program or event.
Harassing conduct includes epithets, slurs or negative stereotyping; threatening, intimidating or hostile acts; denigrating jokes; and written or graphic material that denigrates or shows hostility or aversion toward an individual or group that is placed on walls or elsewhere on the premises or circulated in the workplace, at an APQC-sponsored event, or by e-mail, phone (including voice messages), text messages, social networking sites, or other means.
All such conduct is a violation of this Policy.
Individuals and Conduct Covered
This Policy applies to all persons participating in an APQC-sponsored event or program whether related to conduct engaged in by fellow participants or by someone not directly connected to APQC (e.g., an outside vendor, consultant, or customer).
Conduct prohibited by this Policy is unacceptable in the workplace and in any work-related setting outside the workplace, such as during business trips, business meetings and business-related social events.
Reporting an Incident of Harassment, Discrimination or Retaliation
APQC encourages reporting of all perceived incidents of discrimination, harassment, disparate treatment or retaliation, regardless of the offender’s identity or position. Individuals who believe that they have been the victim of such conduct should discuss their concerns with the program instructor, manager, or host, in the event that such person is the subject of the complaint, to [INSERT]. See the complaint procedure described below.
In addition, APQC encourages individuals who believe they are being subjected to such conduct to promptly advise the offender that his or her behavior is unwelcome and to request that it be discontinued. Often this action alone will resolve the problem. APQC recognizes, however, that an individual may prefer to pursue the matter through complaint procedures.
Anyone who believes they have been the victim of conduct prohibited by this Policy or believe they have witnessed such conduct should discuss their concerns with the program instructor, manager, or host, in the event that such person is the subject of the complaint, to [INSERT].
APQC encourages the prompt reporting of complaints or concerns so that rapid and constructive action can be taken before relationships become irreparably strained or further harm is done. Therefore, while no fixed reporting period has been established, early reporting and intervention have proven to be the most effective method of resolving actual or perceived incidents of harassment.
Any reported allegations of harassment, discrimination, disparate treatment or retaliation will be investigated promptly. The investigation may include individual interviews with the parties involved and, where necessary, with individuals who may have observed the alleged conduct or may have other relevant knowledge.
APQC will maintain confidentiality throughout the investigatory process to the extent consistent with adequate investigation, due process, and appropriate corrective action.
Retaliation against an individual for reporting harassment or discrimination or for participating in an investigation of a claim of harassment or discrimination is a serious violation of this Policy and, like harassment or discrimination itself, will be subject to corrective action.
Misconduct constituting harassment, discrimination, disparate treatment or retaliation will be dealt with appropriately. Corrective action may include without limitation excluding the offender from further participation in the program or event but in all instances APQC will endeavor to tailor the response to the nature of the complaint and the overall circumstances consistently with the stated objectives of this Policy.
If a party to a complaint does not agree with its resolution, that party may appeal to APQC’s [INSERT].
False and malicious complaints of harassment, discrimination or retaliation (as opposed to complaints that, even if erroneous, are made in good faith) may be the subject of appropriate corrective action.
Dissemination of this Policy
In furtherance of the objectives of this Policy, APQC will make every reasonable effort to ensure that (a) all participants in any APQC-sponsored program or event are familiar with this Policy and the process for filing a complaint involving conduct alleged to be in violation of this Policy and (b) understand that any complaint of an alleged violation of this Policy will be investigated and resolved appropriately in a timely manner. Specifically, this Policy will be available as follows:
• A copy will be included with any APQC-sponsored program or event registration forms;
• A copy will be prominently posted at the location of the event in a conspicuous manner; and
• Reference will be made to the Policy and how to find a copy of it will be announced at the start of each program or event.
Training Records Release Policy
Maintaining learner privacy is essential. APQC has longstanding privacy policies in place which were most recently updated for GDRP compliance. The management and release of training records must comply with those overall policies.
All staff assigned to any training role will be made aware of training record management and release policies in advance of starting their performance of effort.
Training Records Management
APQC will ensure that training records are established for each enrolled learner to include:
- Enrollment date
- Completion status
- Completion date
- Completion Certificate
- Provider (e.g., instructor)
All records will be maintained within a designated system of record that includes backups and retention for a minimum of seven years. APQC will review the integrity of training records at least annually. Any issues will be captured and tracked to resolution.
Training Records Release
APQC will manage access to and release of training records. Access will be limited to training site and course administrators.
Staff with access to training records will not download and release any individual training records without authorization.
APQC will only release individual training records to a validated learner, or if requested in writing by a validated learner, to third-party they designate (e.g., supervisor, training coordinated, etc.).