The University has created policies and procedures that describe the community standards of conduct as well as the procedures for grievances and complaints alleging violations of its discrimination and harassment policies. 

Brown is committed to assisting researchers in complying with agency-specific requirements and regulations. In addition to adhering to the requirements in sponsored awards, all members of the University community must review, understand and comply with Brown’s policies and procedures, including the University and Student codes of conduct.

• Terms and Conditions in Sponsored Research Agreements
• University Code of Conduct

The National Aeronautics and Space Administration (NASA) requires recipient organizations to report to NASA any findings or determinations of sexual harassment, other forms of harassment or sexual assault regarding a NASA-funded PI or co-investigator (Co-I). 

The term and condition also requires the recipient to report to NASA if the PI or Co-I is placed on administrative leave or if the recipient has imposed any administrative action on the PI or Co-I, or any determination or an investigation of an alleged violation of the recipient's policies or codes of conduct, statutes, regulations or executive orders relating to sexual harassment, other forms of harassment or sexual assault. 

Finally, the term and condition specifies the procedures that will be followed by NASA upon receipt of a report.

• NASA Reporting Requirements
• Letter from NASA Administrator Charles Bolden
• Compliance Requirements for NASA Grantees

The National Institutes of Health (NIH) requires that grantees have “policies and practices in place that foster a harassment-free environment.” With respect to this rule, NIH expects that grantee institutions do the following:

• Develop and implement policies and practices that foster a harassment-free environment.
• Maintain clear, unambiguous professional codes of conduct.
• Ensure employees are fully aware and regularly reminded of applicable laws, regulations, policies and codes of conduct.
• Provide an accessible, effective and easy process to report sexual harassment and provide protection from retaliation.
• Respond promptly to allegations to ensure the immediate safety for all involved, investigate the allegations and take appropriate sanctions.
• Inform NIH of administrative actions that remove senior/key personnel on an NIH award.

In addition to these expectations, NIH has established parameters relating to harassment that are specific to certain types of grants, such as Training Grants.

Brown has established policies and procedures that meet and provide mechanisms for researchers to comply with these expectations.

• Protections in NIH Training Grant Applications
• Updated Requirements for NIH Notification of Removal or Disciplinary Action
• NIH Anti-Sexual Harassment Statement
• NIH: Supporting a Safe and Respectful Workplace

NIH Support for Conferences and Scientific Meetings

Applicants for NIH Support for Conferences and Scientific Meetings (R13/U13) must include a plan to promote safe environments (safety plan) as part of Just-In-Time materials should the application be recommended for funding.  

Consistent with NIH Grants Policy Statement (Section 4.1.2 Civil Rights Protections) and federal civil rights laws, it is expected that organizers of NIH-supported conferences and scientific meetings take steps to maintain a safe and respectful environment for all attendees by providing an environment free from discrimination and harassment.

At a minimum, safety plans are required to include the following elements:

• Statement of commitment to provide a safe environment
• Expectations of behavior, including a list of behaviors considered harassing (specific emphasis on harassment, sexual, racial, ethnic or otherwise)
• Instructions on how to confidentially report alleged violations of the expectations of behavior to conference organizers
• Description of how the organizers will assess allegations and the consequences for those who are found to violate the expectations of behavior
• Information explaining that individuals who have questions, concerns or complaints related to harassment are also encouraged to contact the conference organizer or the Department of Health and Human Services Office for Civil Rights (OCR)
• Information about how to file a complaint with HHS OCR
• Information explaining that filing a complaint with the conference organizer is not required before filing a complaint of discrimination with HHS OCR, and that seeking assistance from the conference organizer in no way prohibits filing complaints with HHS OCR
• Information explaining how individuals can notify NIH about concerns of harassment, including sexual harassment, discrimination and other forms of inappropriate conduct at NIH-supported conferences

Along with the safety plan to be shared with attendees, R13/U13 applicants recommended for funding must provide to NIH as part of Just-In-Time materials:

• Description of the strategy that will be used to communicate the safety plan to conference attendees and a plan to document allegations and resulting actions
• Information on the steps the organizers will take to ensure a safe and respectful environment for all attendees, free from discrimination and harassment

Brown has made the required institutional commitments. Please contact Sponsored Projects or the BioMed Research Administration with questions about this requirement or assistance with NIH conference grant applications.

• NIH Support for Conferences and Scientific Meetings
• HHS Filing a Civil Rights Complaint
• NIH Conference Policy Definitions

The National Science Foundation (NSF) requires the University to notify the agency promptly of findings or determinations of “sexual harassment, other forms of harassment or sexual assault” concerning an NSF-funded PI or Co-PI, as well as of any interim administrative actions imposed by the University (e.g., administrative leave or curtailment of certain University duties) relating to any finding, determination or investigation of an alleged violation by a PI or Co-PI of the University’s policies relating to harassment and assault.  

Brown has established procedures that comply with these requirements. Please contact Sponsored Projects or the BioMed Research Administration with questions or for more information.

NSF Conference Requirements

The NSF Proposal and Award Policies and Procedures Guide (PAPPG) requires conference proposers to have “a policy or code-of-conduct that addresses sexual harassment, other forms of harassment and sexual assault, and that includes clear and accessible means of reporting violations of the policy or code-of-conduct.” Notably, this “policy or code-of-conduct must be disseminated to conference participants prior to attendance at the conference and made available at the conference itself.” 

For more information on applicable Brown policies and how Brown can assist researchers with complying with NSF conference requirements, please contact the Office of Sponsored Projects or the BioMed Research Administration.

• NSF Notification Requirements
• NSF: Stopping Harassment and Assault

Effective January 30, 2023, the NSF Proposal and Award Policies and Procedures Guide (PAPPG) was updated to incorporate language on Safe and Inclusive Working Environments for Off-Campus or Off-Site Research (Chapter II.E.9), which describes the new requirement for the University’s authorized organizational representative to certify that Brown has a plan in place for safe and inclusive research for any proposal that proposes to conduct off-campus or off-site research. 

About the Policy

It is NSF policy to foster safe and harassment-free environments wherever science is conducted. NSF’s policy recognizes that a community effort is essential to eliminate sexual and other forms of harassment in science and to build inclusive scientific climates where people can learn, grow and thrive. Brown’s policies closely align with the NSF policy.

To ease administrative burden, Brown has prepared a template for PIs to use when creating a Safe and Inclusive Working Environments Plan, available upon request via email to resadmin@brown.edu.

For solicitations not requiring the submission of the plan to NSF, the University requires a copy of the plan at the proposal submission stage to ensure that the application package is complete in the event an award is made.

Definitions and Timeline

Off-campus and off-site research is defined by the NSF as “data/information/samples being collected off campus or off site, such as fieldwork or research activities on vessels and aircraft.” Brown defines “off-campus” as sponsored activities that take place on land, in buildings or facilities (e.g., research vessels) not owned or leased by Brown at locations where Brown’s facilities-related indirect costs do not cover these location costs.

Several solicitations from the NSF directorates for Biological Sciences and Geosciences require the submission of a Safe and Inclusive Working Environments Plan for research proposals (vs. education/ training) that will be considered as part of the broader impacts criteria during the review process. Additional directorates are also expected to include this requirement.

Components of a Safe and Inclusive Working Environments Plan

The plan must describe how the following types of behavior will be addressed:

• Abuse of any person, including, but not limited to, harassment, stalking, bullying or hazing of any kind, whether the behavior is carried out verbally, physically, electronically or in written form;
• Conduct that is unwelcome, offensive, indecent, obscene or disorderly

The plan must address the following four sections (maximum two pages):

• Brief description of the field setting and unique challenges for the team
• Steps the proposing organization will take to nurture an inclusive off-campus or off-site working environment, including processes to establish shared team definitions of roles, responsibilities and culture (e.g., codes of conduct, trainings, mentor/mentee mechanisms and field support that might include regular check-ins and/or developmental events)
• Communication processes within the off-site team and to the organization(s) that minimize singular points within the communication pathway (e.g., there should not be a single person overseeing access to a single satellite phone)
• Organizational mechanisms that will be used for reporting, responding to and resolving issues of harassment if they arise.

The development and distribution of the plan is the responsibility of the award PI. The plan must be distributed to each participant in advance of departure for an off-campus research activity.

• NSF PPAG: Safe and Inclusive Working Environments
• FAQs on Safe and Inclusive Fieldwork Plans
• Safe and Inclusive Work Environments Virtual Office Hour