Definition of Policy: A series of principles and requirements that regulate AUI’s organizational affairs and document key decisions of AUI’s leadership. AUI policies are implemented through well-considered procedures and communications involving the relevant stakeholders, and govern activities at both AUI and its research centers.
Order of Precedence:
- AUI Charter
- AUI Policies
- Research Center Policies
Development of AUI Corporate Policies:
Policies may be created and amended for entirely internal reasons, but they are also often mapped to laws, regulations and standards. Both the speed of organizational change and the always-evolving regulatory landscape provoke the need for policy development. The development of AUI Corporate policy habitually requires the following steps in order to ensure their compliance with relevant laws and regulations, and their effective implementation.
- Assess the need for the policy and ensure the subject matter of the policy is broadly applicable to a significant portion of the organization’s management, operational and/or programmatic activities.
- Collect existing policies to identify potential overlap or conflicts. This includes AUI policies that govern policies at the research centers.
- Review any applicable compliance requirements contained in agreements with the sponsoring organization, as well as the AUI Compliance Matrix.
- Make use of both AUI and research center subject matter experts to develop the policy.
- Consult with AUI and research center leadership early in the process about the scope and expected impact of the proposed changes, including the circulation of draft changes among staff responsible for those topic areas before submitting to senior AUI or research center development leadership. This will both guide the development process and smooth the final approval process.
- Where appropriate, utilize benchmarking or industry research to identify best practice examples of policies utilized by other similar organizations.
- Ensure AUI’s legal counsel is consulted on the proposed policy change, as and when appropriate.
- Consider including measurable goals or performance standards in policies where doing so will facilitate tracking for compliance and/or evaluation purposes.
- Assess any implications of the proposed changes, including cost and resource requirements, documentation requirements, and compliance implications.
- Policy owners with the responsibility for stewardship of each policy need to be identified for all policies. The policy owners must be skilled in the relevant area, and be conversant with their responsibilities towards the upholding of the policies, and know whom to turn to in the event of observed policy compliance or policy management weaknesses. The responsibilities for policies will normally reflect the subject matter responsibilities for the cooperative agreement requirements, as outlined in AUI’s Compliance Matrix.
- Consider developing materials needed to both enable and inform the operation of the policy:
- Enabling documents: May include operational procedures, forms, delegations of authority, business process diagrams, and related documents
- Informing documents: May include guidelines, FAQs, templates, and related documents.
- Provide applicable AUI and research center staff impacted by and/or responsible for the policy’s topic area an opportunity to review and comment on the proposed policy.
- AUI Policies: Discuss internally at AUI, and, in a timely manner, with any research center staff that would be directly impacted.
- Center Policies: Discuss internally within the research center, and in a timely manner, with appropriate AUI staff to ensure conformance with AUI policy.
- Ensure all policy owners and relevant stakeholders have reviewed the proposed changes before submitting the policy for final approval.
- Develop, as appropriate, communications, implementation, and training plans before submitting for approval.
Approval of AUI Corporate Policies and Procedures:
- Policy Approvals:
- All AUI policies
- Must be submitted for approval to the AUI President. The President may either approve the policy, or refer the policy to the AUI Board of Trustees (or applicable Board Committee) for approval.
- As applicable, must document consultation with the research center staff responsible for that topic area.
- All research center policies:
- Must document approval and (as appropriate) consultation with AUI staff responsible for that topic area.
- Must be approved by the research center Director.
- As necessary, must be submitted to the research center’s sponsoring organization for review and approval.
- All AUI policies
- Publication: AUI and research center policies should be stored electronically, and made available in a central location. Some policies may be confidential in nature and have access restricted to authorized staff or other stakeholders.
- Policy Review Schedule: Both AUI and research center policies must be formally reviewed by persons designated respectively by the AUI President & research center Director at least once every five years. For research centers, a review must also occur each time a new cooperative agreement or similar award is negotiated with AUI for managing the research center. If such reviews finds that no changes are needed, a short policy memo documenting that fact should be developed.
Making Observations and/or Recommending Changes to AUI Policies
Any employee may make observations about existing policies, or policy management, and/or recommend a new or revised policy or the elimination of an existing policy, via the normal channels (e.g. speaking to a supervisor, raising the matter at management and/or oversight meetings and so forth). All suggestions will be reviewed and, as appropriate, will proceed through the development and approval process described above.
Reminder regarding Ethics & Integrity Line: AUI has established several methods for employees to report their concerns, which they are encouraged to use, and policy matters may be among those matters of concern. The channels for reporting concerns include reporting issues to their supervisor, using Safety Action Reports to notify of safety concerns, communicating with site Ombuds personnel or utilizing the Grievance Process. Should an employee feel, however, that none of the above would be an appropriate method to raise an issue or resolve their concern, s/he is encouraged to contact the AUI Ethics & Integrity Line.