APPENDIX G
SAMPLE ETHICS POLICY

ETHICS POLICY OF

[_______________]

The highest standard of ethical conduct and fair dealing is expected of each employee, director, volunteer and all others associated with the [Employer]. Our reputation is a most valuable asset, and we must continually earn the trust, confidence and respect of our suppliers, our members, [our clients, our volunteers, etc.] and our community.

This Policy provides general guidance on the ethical principles that we all must follow, but no guideline can anticipate all situations. We must all depend on the basic honesty and good judgment of every individual, and sensitivity to the way others see us and may interpret our actions.

If you have any questions about this Policy, it is your responsibility to consult your supervisor or the [Executive Director]. Exceptions to this Policy may be made only by the [Executive Director] or the [Chair of the Board of Directors].

Everyone is expected to promptly disclose to the management of the [____] anything that may actually or potentially be in violation of this Policy. We will not tolerate retaliation or retribution against anyone who brings violations to management's attention.

I. Compliance with Laws and Regulations

All our activities are to be conducted in compliance with the letter and spirit of all laws and regulations. You are charged with the responsibility of understanding the applicable laws, to recognize potential dangers, and to know when to seek legal advice.

II. Conflicts of Interest

You must avoid any interest, influence, or relationship which might conflict, or appear to conflict, with the best interests of the [____], or which might affect your judgment or loyalty. You must avoid any situation in which your loyalty may be divided, and to promptly disclose any situation where an actual or potential conflict may exist. Examples of potential conflict situations include:

- Direct or indirect ownership or a significant financial interest in, or other relationship with, a supplier to the [____].

- Having a financial interest in any business transaction with the [____], either directly or through a third party.

- Accepting gifts, entertainment, or other benefit of more than a nominal value from a supplier to the [____].

If you are concerned that a conflict may have arisen, you should promptly review the situation with management. Anyone with a conflict must disclose the conflicting interest, using the attached Certificate, and remove themselves from negotiations, deliberations or votes involving the conflict. You may, however, state your position and answer questions when your knowledge may be of assistance.

III. Giving and Receiving Gifts

You may not give or receive money or any gift to or from a supplier, governmental official, or other organization. Exceptions may be made for gifts that are customary and lawful, are of nominal value, and are authorized in advance.

You may accept meals and refreshments if they are infrequent, are of nominal value, and are in connection with business discussions.

You should inform anyone doing or desiring to do business with the [____] that all gifts other than advertising novelties are discouraged. If you do receive a gift or a benefit of more than nominal value, you should report it promptly. It will be returned or donated to a suitable charity.

IV. Political Activity

The [____] recognizes that employees, in their individual capacity, may participate in the political process by supporting political parties, candidates, or causes. However, the [____] is a tax-exempt organization that is prohibited from directly or indirectly participating in any political campaign of or support or opposition to any candidate. The [____] may not contribute anything of value, including employee's time, to political campaigns, publish or distribute materials on behalf of any candidate or party, or engage in any other activity which may be considered in support of or in opposition to any candidate.

You may personally contribute to a candidate or party of your choice. However, you may not be compensated or reimbursed by the [____] for your personal contribution. Any efforts devoted to political activity must be outside working hours. Unless authorized by [the Executive Director], it must also be clear that any statements on public issues are not those of the [____].

V. Personal Conduct

We strive to provide all employees, directors, volunteers and members a healthy, safe and positive environment. The climate at the [____] must be free from discrimination and harassment based on race, color, religion, sex, sexual orientation, age, national origin, disability, veteran status, or any other factors unrelated to the [____]'s legitimate interests.⁴²⁴

We will not tolerate sexual advances or comments, or any other conduct that creates, in the opinion of the management of the [____], an intimidating or otherwise offensive environment. Similarly, the use of racial or religious slurs, or any other remarks, jokes or conduct that encourages or permits an offensive environment will not be tolerated.

If you believe you are subject to improper conduct, or become aware of the improper conduct of others, you should bring this to the attention of the Executive Director or the Chairman of the Board of Directors. All complaints will be investigated promptly.

Other activities that are prohibited because they are not conducive to a good environment are threats or violent behavior or possession of a weapon. Also prohibited are the use, distribution, sale or possession of alcohol, drugs or any controlled substance on the [____]'s premises or while on [____] business. You may not be on [____] premises if you are under the influence of controlled substances, illegal drugs, or alcohol.

VI. Employee Privacy and Other Confidential Information

You must protect the confidentiality of employee, client, and third-party confidential and proprietary information and records. The only personal information about employees that the [____] collects is that which relates to their employment. Access to this information is limited to people with a need to know and any release of the information to others must be authorized in advance by the Executive Director or the Chair of the Board of Directors. Personal information is released outside the [____] only with employee approval, except to verify employment or to satisfy legitimate investigatory or legal requirements.

If you have access to any [____] confidential information, including private employee information, you are responsible for acting with integrity. Unauthorized disclosure or inappropriate use of confidential information will not be tolerated.

VII. Use and Protection of [___] Assets

You have a duty to preserve the [____]'s assets. Because we are a charitable, non-profit organization, it is imperative that everyone demonstrates cost control and follows vigorous procurement standards. Acquisitions of goods and services must be at the best possible price and quality.

You may not use [____] employees, materials, equipment or other assets for any unauthorized purpose. Assets must be periodically tracked and inventoried, with appropriate action taken if there are any losses.

VIII. Accounting and Financial Reports

You must record and report information accurately. Reimbursable business expenses must be reasonable, accurately reported, and supported by receipts.

The [____]'s financial statements, and all books and record on which they are based, must accurately reflect all of the organization's transactions. All disbursements and receipts of funds must be properly authorized and recorded. No undisclosed or unreported fund may be established for any purpose.

Those responsible for the handling or disbursal of funds must assure that all transactions are executed as authorized and recorded to permit financial statements in accordance with Generally Accepted Accounting Principles.

IX. Compliance

Failure to comply with this Policy will result in disciplinary action that may include reimbursement of the [____] for any losses or damages, termination of employment, and referral for criminal prosecution. Action will also be taken against supervisors or others who fail to report a violation or withhold relevant information concerning a violation of this Ethics Policy. All directors and employees must sign the attached Certification.

Adopted by the Board of Directors, (DATE)

Certification

I have read and understand the Ethics Policy of the [_______________] and I agree to abide by this Policy in all dealings for and with the [____]. I state that I have no interests that conflict or may conflict with my service for the [____] except as set forth below.

____________________________

Signature Date

If you wish this disclosure to be treated in confidence, please indicate here. _____

This certificate should be returned to:

[Executive Director]

[_______________]

424 In New York City, add "alienage or citizenship." In Westchester County, add "familial status." In Connecticut, add "history of past or present mental disorder, mental retardation, learning disability, or physical disability including but not limited to blindness."