Conflict of interest policy

William and Flora Hewlett established the foundation exclusively to advance charitable purposes for the public good. The board honors the founders’ values by requiring the highest ethical standards of the directors, advisors, and staff; by using the foundation’s assets efficiently for the foundation’s philanthropic objectives; and by taking measures to assure that decisions are not influenced by self-interest. The conflict of interest policy is intended to provide guidance on how to deal appropriately with situations that involve, or may appear to involve, conflicts of interest, and to comply with federal and state laws concerning conflicts of interest.

View the full policy: Conflict of Interest Policy [PDF]


Equal employment opportunity and policy against harassment

Consistent with our Guiding Principles, the foundation is firmly committed to diversity in staffing and the maintenance of an environment free of discrimination.  We provide opportunities to all employees based on merit, qualifications, and job requirements. The foundation is committed to a policy of nondiscrimination and equal opportunity in all aspects of employment to all persons without regard to gender, pregnancy, age, color, race, national origin, ancestry, marital status, religion, physical or mental disability, sexual orientation, gender identity, gender expression, medical condition, veteran status, or any other legally protected category.

This policy governs all aspects of employment at the foundation, including hiring, assignments, training, promotions, compensation, employee benefits, discipline, and discharge.

Also consistent with our values and the law, the foundation is committed to providing and maintaining a workplace that is free of sexual harassment and any form of harassment based upon a legally protected characteristic. The foundation absolutely will not tolerate unlawful harassment against our employees, applicants or contractors by any employee or other third party.

View the full policy: Equal Employment Opportunity Policies (PDF)


Commitment to open licensing

As part of our commitment to openness and transparency, the Hewlett Foundation has long supported open licensing—a replacement for traditional copyright that encourages sharing intellectual property. Open licenses, such as those developed by our longtime grantee Creative Commons, protect authors’ rights while explicitly permitting others to freely use, distribute, and build upon their work. The benefits are substantial: open licensing increases the chances that good ideas get a hearing, that others develop them further, and, ultimately, that they have their greatest impact.

The Hewlett Foundation makes information related to our grantmaking available under an open license so that others may learn from our experience. In 2014, we extended this commitment to open licensing to include, in appropriate circumstances, materials created with our grant dollars. More specifically, the Hewlett Foundation now requires that grantees receiving project-based grants—those made for a specific purpose—openly license the final materials created with those grants (reports, videos, white papers, and the like) under the most recent Creative Commons Attribution license. We also will require that the materials be made easily accessible to the public, such as by posting them to a grantee’s website. These requirements will not apply to grants made for general operating support of an organization or a program or center within an organization because they are incompatible with the nature of general support. We very much hope however, that the positive experience of openly licensing materials created with project-based grants will encourage grantees to do so for all their work.

The Attribution license is the most open license offered by Creative Commons. It gives others permission, free of charge and in advance, to acquire and make licensed work available, and even to incorporate it into new work—to “remix, transform and build upon” the work, in Creative Commons’ phrase. This includes a right to sell the licensed work, so long as the original author is credited for his or her contribution.

We will not enforce this new requirement thoughtlessly. If our default open license does not make sense for a particular project—such as if the work contains sensitive information or if revenue generated by its sale is critical to an organization’s financial well-being—we will work with the grantee to determine the most appropriate license. Our commitment to open licensing is meant to help, not harm, grantees, and we will administer it accordingly.

We believe that open licensing of the Hewlett Foundation’s own work and of work created with funding from us will make our grant dollars go further and so increase our ability to contribute to the common good. It allows others more easily to find, use, respond to, and build upon ideas that can help people build better lives.


Social investment policy

The Hewlett Foundation’s broad purpose is to promote the well-being of humanity. Alternatively stated, our objective is to generate maximum social benefit from our financial and human resources. The Board believes that the Foundation creates substantial social benefit through its grants and related philanthropic activities.

View our social investment policy: Social Investment Policy [PDF]


Policy on indirect costs for project or program grants

The Hewlett Foundation is committed to working with grantees in a collaborative fashion—treating them as partners and seeking to facilitate rather than dictate what they do. As part of that commitment, we provide long-term, general operating support whenever possible and fund grantees’ true costs when making restricted project or program grants. Our policy on indirect costs is intended to provide greater clarity for organizations submitting proposal applications and budgets for project or program grants.

The Hewlett Foundation does not employ a fixed minimum or maximum rate for indirect costs. When proposals require grantees to submit budgets with indirect costs estimates, we want the proposals to reflect the prospective grantees’ actual indirect costs for the project or program in question. Grant budgets that do not fully cover the indirect costs needed to support a grantee’s work—whether submitted because the grantee does not know the true costs, or because of an assumption that funders won’t pay them—give rise to what has been aptly named the non-profit starvation cycle. That cycle is aggravated when funders accept these unrealistically low estimates at face value, refuse to pay indirect costs, or impose arbitrary caps on what costs can be recovered. We want to avoid this pernicious cycle with our grantees.

We recognize that every grant has a unique purpose and structure and that costs vary depending on many factors. We set each grant’s total amount in the context of our overall grantmaking budget and funding priorities, and through a consultative process with the grantee. As part of that process, we intend for grantees to take the lead in determining how best to allocate those grant dollars to direct and indirect costs.

In our policy, we provide guidance for specific types of organizations and special cases, but we encourage grantees and potential grantees who have questions to consult with their Program Officer at any time.

View the full policy: Policy on Indirect Costs for Project or Program Grants (PDF) I View in Spanish, French


Whistleblower Policy: Reporting concerns, complaints, or violations and protection for whistleblowers

The William and Flora Hewlett Foundation expects its directors, officers, and employees to act honestly and with integrity, in accordance with high ethical standards, and to comply with applicable laws, regulations, and foundation policies in the conduct of their duties. The foundation is committed to facilitating open and honest communications in all matters pertaining to its governance, finances, and compliance with applicable laws, regulations, and policies, and encourages the reporting of good faith concerns, complaints, and violations.

Any director, officer, or employee who violates or suspects any violation of the law, regulations, foundation policies, or accounting, auditing, and financial reporting controls must report such activity as soon as possible by submitting a report under this policy. It is important that the foundation be apprised about unlawful or improper behavior including, but not limited to, any of the following conduct:

  • theft;
  • financial reporting that is intentionally misleading;
  • improper or undocumented financial transactions;
  • destroying or tampering with any record or document with the intent to obstruct a pending or contemplated audit, review or investigation;
  • improper use of foundation assets;
  • corruption or bribery;
  • insider trading;
  • payment for services or goods that are not rendered or delivered;
  • violations of the foundation’s Conflict of Interest Policy; and
  • any other improper occurrence regarding cash, financial procedures, or financial reporting;
  • other illegal activities.

For more information on our policy and reporting options, view our full Whistleblower Policy (PDF).

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