Contract analysis

1. Engagement Background and Investigation Scope

2. Methodology and Timeline of Key Events

3. Summary of Evidence Collected

4. Findings by Category: Retaliation, Hostile Work Environment, Safety-Protocol Violations, Falsification of Records

5. Parallel EHS Audit Results (Haverford Safety Consulting Group)

6. Institutional Exposure Analysis — Legal, Regulatory, and Financial

7. Recommended Corrective Actions

8. Next Steps and Implementation Priorities

9. Questions [slide 3] Engagement Background Between August 12 and September 4, 2024, five TMRI employees filed formal written grievances under Employee Handbook § 7.3 alleging misconduct by Dr. Marcus Ellender, Director of Biomedical Engineering Laboratories VP-HR Grace Okenwa escalated the matter to General Counsel Elena Graff on September 3, 2024, recommending outside counsel given the severity and volume of alleg

1. Retaliation against employees who reported safety concerns — M.G.L. c. 149, § 185 (Massachusetts Whistleblower Protection Act); TMRI Policy HR-2021-009

2. Hostile work environment — verbal intimidation, discriminatory scheduling, punitive assignments — M.G.L. c. 151B, § 4; Title VII of the Civil Rights Act of 1964; TMRI Respectful Workplace Policy HR-2021-005

3. Safety-protocol violations — directed circumvention of OSHA-mandated PPE requirements (29 C.F.R. § 1910.132 et seq.); biohazard-containment protocols (NIH Guidelines for Recombinant or Synthetic Nucleic Acid Molecules)

4. Falsification or alteration of records — safety-incident reports (IR-2024-031, IR-2024-038) and lab-notebook entries [slide 5] The Complainants Dr. Yuna Sakata — Senior Research Scientist, Lab B-2 (since March 2019): Retaliation following chemical-spill report; reassignment from NIH-funded project without justification — Filed August 12, 2024 Trevor Hollins — Lab Technician III, Lab B-3 (since June 2020): Hostile

1. Terminate Dr. Ellender's employment for cause under TMRI Employee Handbook § 9.2 — supported by substantiated findings across all four categories of misconduct

2. Refer safety violations to TMRI's Institutional Biosafety Committee (IBC) and to OSHA if required under mandatory-reporting thresholds

3. Notify NIH Grants Management regarding PI change for active grants 5R01-EB029174 and 1R01-EB034851 (combined remaining funds ~$3.1M) — identify successor PI candidates immediately

4. Implement mandatory anti-retaliation and supervisory-conduct training for all lab directors and supervisors (~18 individuals) within 90 days

5. Revise TMRI's safety-incident reporting process to include an anonymous-reporting option and independent EHS review of all incident reports

6. Provide individual remediation for affected complainants — restore Dr. Sakata to NIH grant role; correct performance records for Dr. Chandrasekaran and Trevor Hollins [slide 17] Implementation Priorities and Next Steps Immediate (within 5 business days): — Board authorization of termination for cause (Committee recommendation to full Board if required) — Elena Graff and Grace Okenwa to execute termination process