A.2.1 Unlawful Harassment Policy
Marine Biological Laboratory
EEO Policy No. A.2.1
Initiated by: Equal Employment Opportunity Coordinator
Approved by: Director/CEO Date: July, 1987
Revision: #6, April 16, 2018
Distribution: The MBL Community
1.0 Policy Statement
It is the goal of MBL to promote a working and learning environment free of unlawful discrimination,
harassment, and intimidation for every member of its scientific community (employees, visiting
researchers and scholars, course participants, library users, etc.) and for anyone else who has a
relationship to the community (Trustees, Corporation members, contractors, vendors, etc.).
Harassment, whether discriminatory or sexual, is unlawful under both federal and state law and, as
such, will not be tolerated by MBL. Further, any retaliation against an individual who has complained
about harassment, or retaliation against an individual who has cooperated in an investigation of
harassment, is also unlawful and will not be tolerated. MBL takes allegations of harassment seriously
and will respond promptly to any complaint. Where it is determined that inappropriate conduct has
occurred, MBL will take the necessary action to eliminate the conduct and impose corrective measures,
including disciplinary action.
2.0 This policy applies to all work/program-related settings and activities, whether inside or outside
the MBL, and includes off-site research laboratories, field trips, business trips, and other business-
related social events. MBL property (telephones, copy machines, facsimile machines, computers,
computer applications such as e-mail and Internet, etc.) may not be used to engage in conduct that
violates this policy.
3.0 While this policy sets forth goals for promoting an environment free of harassment, it is not
designed or intended to limit MBLs authority to discipline or take remedial action for conduct which
is deemed unacceptable, regardless of whether that conduct satisfies the definition of unlawful
harassment. It is expected that all members of the MBL community will conduct themselves in a
manner that fosters mutual respect for one another and maintains an atmosphere of professionalism.
4.0 MBL requires each of its supervisors and managers to be responsible for the prevention and
elimination of all forms of harassment within their respective departments. Supervisors and
managers, new employees, and any employee who has not been recently trained will be given training
in ways to prevent unlawful harassment in the workplace.
5.0 Definitions
5.1 The definition of unlawful discriminatory harassment is any verbal or physical conduct which has
the intent or effect of unreasonably interfering with an individual’s work or academic performance or
which creates an intimidating, hostile, or offensive work or educational environment, when such
conduct is based upon race, color, religion, national origin, ancestry, gender/sex, age, disability,
sexual orientation, genetics, military status, or participation in discrimination complaint-related
activities. Prohibited behavior includes slurs or other derogatory comments, objects, pictures,
cartoons, or demeaning gestures connected to ones membership in a protected group.
5.2 The definition of unlawful sexual harassment is any sexual advances, requests for sexual favors, or
verbal or physical conduct of a sexual nature when: (a) submission to or rejection of such advances,
requests, or conduct is made either explicitly or implicitly a term or condition of employment or as a
basis for employment decisions (called quid pro quo) or (b) such advances, requests, or conduct have
the purpose or effect of unreasonably interfering with an individuals work performance by creating an
intimidating, hostile, humiliating, or sexually offensive work environment (called hostile environment)
5.2.1 Quid pro quo sexual harassment occurs when a supervisor takes an adverse job action against an
employee (such as discharge, demotion, or undesirable reassignment) because the employee refuses the
supervisor’s sexual advances.
5.2.2 Hostile environment sexual harassment includes, but is not limited to, unwelcome sexual
advances, whether or not they involve physical touching; sexual epithets, jokes, written or oral
references to sexual conduct; gossip regarding ones sex life; comments on an individuals body or
sexual activity; displaying sexually suggestive objects, pictures, cartoons; unwelcome leering,
whistling, brushing against someones body; sexual gestures; suggestive or insulting comments;
discussing ones
own or inquiring into anothers sexual activities.
6.0 Complaints
Any person who believes that he or she has been unlawfully or sexually harassed should bring his or
her concerns to the attention of management immediately. This can be done in writing or orally. You
may report such conduct to any one of the following: your immediate supervisor, your supervisor’s
manager, the EEO Coordinator (Homestead 109, x7378, eeo@mbl.edu), the Human Resources
Director (x7422), or to any member of management with whom you feel comfortable. These people are
available to discuss any concerns you may have and to provide information to you about this policy
and the complaint process.
7.0 Investigation
When a complaint is received, MBL will investigate the allegation in a fair and expeditious manner. The
investigation will
be conducted in such a way as to maintain confidentially to the extent practicable under the
circumstances. The investigation will include a private interview with the person filing the complaint
and with any witnesses. The person alleged to have committed the harassment will also be
interviewed. When the investigation is complete, MBL will, to the extent appropriate, inform the
person filing the complaint and the person alleged to have committed the conduct of the results of the
8.0 Disciplinary Action
If it is determined that inappropriate conduct has occurred, MBL will act promptly to eliminate the
offending conduct and, where it is appropriate, will impose disciplinary action. Resolution through
informal means is encouraged and, in most instances, will be satisfactory. If more formal action is
necessary this may include counseling, warnings, transfers, suspensions, reductions in pay or duties,
termination of employment, and/or dismissal from the MBL community. Since retaliation is also
unlawful, any such conduct will warrant disciplinary action as well.
9.0 State and Federal Remedies
MBL strongly encourages anyone who believes they have been harassed to bring the matter to MBLs
attention. Inquiries or concerns may also be directed to the governmental agencies responsible for the
enforcement of employment discrimination laws within 300 days of an incident:
Massachusetts Commission Against Discrimination, One Ashburton Place, Sixth Floor, Room 601,
Boston, MA 02108, 617-
United States Equal Employment Opportunity Commission, JFK Federal Building, 475Government
Center, Boston , MA
02203 , 800-669-4000
10.0 All members of the MBL community are expected to be aware of this policy and of the types of
conduct that constitute unlawful harassment, as well as the avenues of assistance provided by MBL for
addressing complaints. Compliance with this policy is a condition of each employees employment and
of each participant’s status in a program.
11.0 Policy clarification and updates are available from the EEO Coordinator, 508 289-7378 or
G.1.19 Code of Conduct
Marine Biological Laboratory
Policy No. G.1.19
Initiated by: Human Resources Office
Approved by: MBL Board of Trustees/Audit Committee
MBL Director
Date: January 19, 2006
Revision: Updated February 2013
Distribution: MBL Community
1.0 Policy Statement
The Marine Biological Laboratory (MBL) is an international center for research, education, and training
in biology. Founded in 1888, the MBL is the oldest private marine laboratory in the country.
The MBL has a responsibility to the international scientific community to provide leadership in all
endeavors. It is committed to the promotion of the highest standards of ethics, behavior, values and goals
for all of its scientific, technical, educational, and administrative operations.
This policy describes the standards of business and ethical conduct and practices the MBL expects of each
officer, employee, scientific staff member, and others acting on its behalf when working for or
representing the MBL, or when on MBL premises.
The quality of work and the atmosphere in which it is done is expected to be consistent with this
commitment and in line with the reputation of the MBL as a leading educational and research institution.
The atmosphere should be one of trust and confidence in those who act on behalf of the MBL.
Community members should be able to rely on the integrity of each other.
The personal and professional conduct of everyone acting on its behalf should reflect the MBL’s
commitment to the fundamental principles of dignity, integrity, and respect for the law; rights, health and
safety of the community and others; and should not conflict with or negatively impact their obligations to
the MBL or its welfare.
2.0 Standards
No policy can set forth every applicable rule and cover every situation; however, in carrying out the
organization’s mission and obligations, employees should use common sense, all relevant MBL policies,
all applicable local, state, and federal law, as well as laws of other countries where operations are being
conducted, as sources for guidelines of ethical conduct, in;
2.1 Applicable Statutes and Regulations: MBL’s commitment to integrity begins with complying with
pertinent laws, rules, and regulations. The work of the MBL is heavily regulated. Non-compliance with
laws and regulations can have severe adverse financial and other consequences, potentially affecting the
reputation and operations of the institution. In addition, individuals can suffer similarly severe financial
and reputation consequences. Everyone must understand the laws, rules, regulations, and
MBL policies that apply to their specific roles. If you are unsure of whether a contemplated action is
permitted by law or MBL policy, advice should first be sought from the appropriate resource expert listed
in Addendum A before taking action.
Everyone is responsible within his or her scope of work for preventing violations of law and for speaking
up if possible violations are observed.
2.2 Existing MBL Policies: In many cases, the MBL expects more than mere compliance with applicable
law, and so our policies may contain expectations of conduct not necessarily exclusively grounded in
legal requirements. All MBL policies are listed in Addendum B to this policy. Some of these represent
internal policies or control procedures and are not necessarily compliance policies. Nevertheless, all
members of the MBL community should become familiar with the policies related to their scope of work,
particularly those relevant to compliance issues. Existing policies may be updated, revised or deleted from
or added to from time to time. The Human Resources office coordinates the maintenance of all MBL
policies. Copies of current policies may be accessed internally on the Human Resources web-page on the
MBL web-site or obtained from any supervisor, the Grass Reading Room of the MBLWHOI Library or
Human Resources office in the Homestead Building.
2.3 Conflicts of Interest: The complex relationships among government, industry, research institutions,
and researchers, as well as the demands of commerce necessitate the establishment of guidelines for
Trustees, Officers, and scientific & administrative staff regarding conflict of interest in carrying out their
duties and obligations. These guidelines have both ethical and legal (federal and state) bases. Generally
these guidelines call for disclosure of any situation that could reasonably be considered or even have the
appearance of a conflict of interest. Also the interests of the MBL always take precedence. MBL has
established policies to assist Trustees and staff in identifying conflicts that might arise and the reporting
mechanisms for these conflicts. Reference MBL polices A.1.6 Trustee Conflict of Interest and K.1.3
Conflict of Interest Policy.
2.4 Scientific Integrity: Any action or conduct on the part of its staff or personnel or those engaged in
MBL-sponsored activities that would compromise scientific integrity is against policy. Specifically, a
compromise of scientific integrity—also referred to as “misconduct in science”— means fabrication or
falsification of data or other documentation, plagiarism, or other unethical practices that seriously deviate
from those practices that are commonly accepted within the scientific community for proposing,
conducting or reporting research. Honest error or honest differences in interpretations or judgments of
data does not constitute a compromise of scientific integrity. Guidelines on Scientific Integrity are found
in MBL policy K.1.2 Scientific Integrity.
2.5 Stewardship of Property and Funds: Resources and records, including time, intellectual property,
material, equipment and information, are provided for MBL business use. Nonetheless, occasional
personal use is permissible as long as it does not affect job performance or cause a disruption to the
Employees and those who represent MBL are trusted to behave responsibly and use good judgment to
conserve institutional resources. Managers are responsible for the resources assigned to their departments
and are empowered to resolve issues concerning their proper use.
Generally, use of MBL equipment such as computers, copiers and fax machines in the conduct of an
outside business or in support of any religious, political or other outside daily activity is not appropriate.
Questions about the proper use of company resources should be directed to individual managers.
The MBL wishes to foster new knowledge and secure the benefits for the long-term health of the
institution. At the same time there is an obligation to keep MBL information confidential as well as the
confidential information shared with the MBL community by other institutions. As a result steps to
safeguard the intellectual property of the MBL are also necessary. Guidelines for this are found in MBL
policy K.1.1 Intellectual Property Policy and Procedures.
2.6 Recording, Allocating, and Charging Costs and Efforts: The accuracy and reliability of financial and
effort reports is of utmost importance to the business operations of the institution. At all times, staff must
record, allocate, and charge costs & effort accurately and maintain supporting documentation as required
by established policies and procedures. Guidelines are found in MBL policy E.1 Grants Accounting,
Policies and Procedures Manual.
2.7 Internal Controls: Internal controls provide the keystone of sound business practices. These controls
include adequate segregation of duties, diligent application of preventive and detective control systems,
and conscientious compliance with authorization, reporting, and other established processes. Internal
controls are critical to ensuring efficient operations, responsible financial management, accurate financial
reporting, careful protections of assets, and satisfactory compliance with applicable laws and regulations.
2.8 Mutual Respect for Others: The MBL is committed to recognizing and acknowledging the dignity of
its workers and visitors. As a result discrimination or harassment along sexual, racial, political, or
religious lines has no place in our community. Guidelines regarding this are found in the MBL policies
A.2 EEO Policies.
3.0 Obligation to Report Suspected Violations
It is the obligation of all members of the MBL community to exercise sound judgment and seek advice
when appropriate, and report any concerns or complaints regarding what they see as violations of law,
ethical standards, or MBL policies. Members of the MBL community may choose to seek advice, express
concerns, or report suspected violations regarding ethical conduct, legal requirements or MBL policy by
contacting either their immediate manager, a department head, the Human Resources Office, or the
Compliance Coordinator. Several MBL policies list appropriate reporting mechanisms in the context of
each policy. Additionally, Addendum A provides a list of responsible persons/departments for a variety of
questions/issues that might arise.
3.1 If it is not clear to whom a question or concern should be directed, the Human Resources office is
readily available for consultation.
3.2 If a material violation of MBL policy or a law/regulation is suspected, it should be reported,
referencing the guidelines in MBL policy G.1.20 Allegations of Misconduct. Please keep in mind that it is
not appropriate for employees to undertake their own investigation of concerns. Their obligation is to
raise the concern appropriately.
3.3 Reporting individuals can be assured that there will be no reprisals or retaliation of any kind for
reporting any type of suspected problem or possible violation if the report is made in good faith.
3.4 The Compliance Coordinator will oversee an independent investigation of the suspected violations of
law and any resulting corrective action that may be deemed necessary.
4.0 Media Contact
The MBL is a high-profile organization in our community, and from time to time, employees may be
approached by reporters and other members of the media. To ensure that we speak with one voice and
provide accurate information about the MBL, all media inquiries should be directed to the Director of
Communications. No one may communicate with the media or issue a press release without first
consulting with the Director of Communications.
5.0 Reputation Risk
When not on MBL premises or representing the MBL, the personal conduct of its officers, employees,
scientific or administrative staff and others acting on the MBL’s behalf is his or her own to regulate.
However, if such a member of the MBL community engages in behavior that discredits the MBL, it may
be appropriate to review that individual’s responsibilities at the MBL. Any such review will be conducted
by the Director of Human Resources at the request of a department head or manager. The Director of
Human Resources will make a report of findings and any recommendation to the MBL Director and Audit
6.0 Consequences of Violation
MBL takes seriously the standards set forth in this Code of Ethical Conduct. Failure to adhere to
professional and ethical standards of conduct, or engaging in behavior contrary to the interests of the
MBL or that interfere improperly with the rights of other persons, their property, or the rights/property of
the MBL may be subject to disciplinary action up to and including discharge.
7.0 Policy Clarification and Updates
Policy clarification and updates are available from the Human Resources Office. The MBL reserves the
right to amend this and any underlying policy at anytime. Also note that this does not represent an
employment contract between the MBL and any Trustee, Officer, or employee. Any exceptions to this
policy must be approved by the Audit Committee.
(Print Name)
, hereby acknowledge and declare that:
_________I confirm that I have received, read, and understand the “Unlawful Harassment Policy and the
disciplinary measures for noncompliance.
_________I confirm that I have received, read, and understand the Code of Conduct Policy and the
disciplinary measures for noncompliance
_________I agree to conduct myself and my activities in accordance with the MBL’s policies and
understand that breaching these standards may result in disciplinary action.
________I am aware that MBLs policies are available to me on the intranet, and upon request by the
Human Resources Department. It is my responsibility to familiarize myself with these policies
Alcohol Policy
_______ I acknowledge that I understand that alcohol on Marine Biological Laboratory property is
limited to Beer and Wine consumed at scheduled Mixers/ Reception and Dinners. Alcohol is not allowed
in any housing common areas, including lounges, corridors, stairwells, and the like. All local, state and
federal laws concerning the use, possession, and distribution of drugs and alcohol are always in effect in
all MBL facilities. Illegal drugs are not permitted.
Participant Liability Waiver
_______ I agree to assume all risks and responsibilities surrounding my participation in the Event, and I
hereby release, waive and discharge Marine Biological Laboratory, its affiliates, and their respective
trustees, officers, agents and employees from any and all liability, harm, claims, damages and losses
arising out of or in connection with the Event, including, without limitation, any loss, damage or injury
arising while traveling to and from the Event.
(Course/Program Name)
(Todays Date)
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