H-GAC as a Metropolitan Planning Organization for the eight-county Houston-Galveston region, provides a forum for cooperative decision-making for transportation plans and programs. H-GAC receives Federal Congestion Mitigation and Air Quality, Surface Transportation Program-Metropolitan Mobility, and other Texas Department of Transportation (TxDOT) funding for the planning activities needed for the implementation of regional transportation improvements and other operations initiatives. Title 43 of the Texas Administrative Code requires specific state and federal fund recipients to adopt and enforce an internal and ethics compliance program.

TxDOT required H-GAC to provide Internal Program Certification to meet the funding requirements. The certification requires the entities receiving the state funds to have a written internal ethics and compliance program that includes items from 43 Texas Administrative Code 10.51, and enforce the compliance of employees with the program. TxDOT’s evaluation of H-GAC’s Personnel Policies identified some areas of clarification including internal ethics and compliance. H-GAC staff has prepared the attached policies to be added to the H-GAC’s Personnel Policies - Section 3 (Employee Responsibilities) to meet TxDOT’s internal and ethics compliance program requirements.