Company policies in H2020 project – Do I need them?

If you are wondering whether you need company policies to implement your H2020 project, that is a good question… and we have answers for you!

The Grant Agreement doesn’t give much information on this issue. The only explicit reference can be found in Article 6.1:
The beneficiary may NOT increase the remuneration of its personnel, upgrade its travel policy or its purchasing rules because of the Commission/Agency support.”

Beyond that, there is no obligation to have any company policies; nevertheless, it’s advisable to have them to make your life easier in case of audit and in general for efficient company business.

We recommend dusting off your company policies and updating them to comply with the obligations of the Grant Agreement. In order to show auditors your H2020 compliance, we recommend the following set of policies:

Procurement policy

The procurement policy should describe the internal process with purchasing limits and approvals, criteria to ensure best value for money, payment methods, documentation to fill in and how to avoid conflict of interest.

Pro tip: his policy must comply with your applicable national law on public procurement.

Travel policy

The travel policy should define the travel approval process, who arranges the travel, amount limits and/or allowances for transportation, lodging and meals, which expenses are non-reimbursable and your company’s expense template.

Pro tip: gratuities such as tips which are not obligatory are not eligible in H2020.

Time recording policy

Article 18.1.2 of your Grant Agreement obligates you to record the hours spent by persons working on the project. Whether you use an electronic or pen-and-paper time-recording system, it’s best to lay out the rules in a document explaining how to fill in the time recording system, how to mark overtime and holidays.

Pro tip: the recording method must be in line with your national standards.

Salary and Bonus policy

The remuneration policy ensures transparency and gender equality. Establish a framework on salaries both fixed and variable components, wage supplements, salary review and payments for overtime. You can also add a bonus policy specifying to whom it applies, on what criteria/personal or organisational targets, the calculation and/or specific amounts. The gender dimension should also be present in these policies as Art 33.1 of your Grant Agreement requires the company to aim for gender equality. You could for instance list a transparent wage classification and grading of jobs.

Pro tip: you should pay in accordance with your national law, the collective labour agreement and the employment contract.

These are the principal company policies in H2020 we recommend, but there are more. You can at any time revise and include additional ones regarding remote working, sustainability, gender, conflict of interest avoidance, depreciation and whatever else you feel is needed.

You still have doubts or would like us to review your company policies, don’t hesitate to get in touch