For Directors, Officers, Volunteers and Employees
The Board of Directors (“Board”) of the Lupus Foundation of Colorado, Inc. (“Foundation”) has adopted the following Code of Ethics (“Code”) to apply to the Foundation’s directors, officers, volunteers and employees. This Code is intended to focus directors, officers, volunteers and employees on areas of ethical risk, provide guidance to help them recognize and deal with ethical issues, provide mechanisms to report unethical conduct, foster a culture of honesty and accountability, deter wrongdoing and promote fair and accurate disclosure and financial reporting.
No code or policy can anticipate every situation that may arise. Accordingly, this Code is intended to serve as a source of guiding principles.
Each director, officer, volunteer and employee is expected to adhere to a high standard of ethical conduct. The good name of the Foundation depends on the way directors, officers, volunteers and employees conduct business and the way the public perceives that conduct. Unethical actions, or the appearance of unethical actions, are not acceptable. Directors, officers, volunteers and employees are expected to be guided by the following principles in carrying out their responsibilities:
- Loyalty. Directors, officers, volunteers and employees should not be, or appear to be subject to influences, interests or relationships what conflict with the interests of the Foundation.
- Compliance with Applicable Laws. Directors, officers, volunteers and employees are expected to comply with all laws, rules and regulations applicable to the Foundation’s and that individual’s activities.
- Observance of Ethical Standards. Directors, officers, volunteers and employees must adhere to high ethical standards in the conduct of their duties. These include honesty and fairness. The Foundation does not permit any activity that fails to stand the closest possible public scrutiny. All business conduct should be well above the minimum standards required by law.
Integrity of Records and Public Reporting
Directors, officers, volunteers and employees should promote the accurate and reliable preparation and maintenance of the Foundation’s financial and other records. Diligence in accurately preparing and maintaining the Foundation’s records allows the Foundation to fulfill its reporting obligations and to provide donors, governmental authorities and the general public with full, fair, accurate, timely and understandable disclosure. In this regard, directors, officers, volunteers and employees (where applicable) should: (a) accurately document and account for transactions on the books and records of the Foundation; and (b) diligently maintain reports, vouchers, bills, invoices, payroll and service records, business measurement and performance records and other essential data. Senior financial officers also are responsible for establishing and maintaining adequate disclosure controls and procedures and internal controls and procedures, including procedures designed to promote full, fair, accurate, timely and understandable disclosure in reports filed with the Internal Revenue Service, the State of Colorado and other public communications.
Conflict of Interest
Directors, officers, volunteers and employees must avoid any conflicts of interest between themselves and the Foundation. Each director, officer, volunteer and employee must sign the Conflict of Interest Statement, and thereby acknowledge understanding and acceptance of the Conflict of Interest Policy of the Foundation.
Directors, officers, volunteers and employees are prohibited from: (a) taking for themselves personally opportunities related to the Foundation’s business; (b) using the Foundation’s property, information or position for personal gain; or (c) competing with the Foundation for business opportunities.
Directors, officers, volunteers and employees should maintain the confidentiality of information entrusted to them by the Foundation and any other confidential information about the Foundation, its business, customers or suppliers, that comes to them, from whatever source, except when disclosure is authorized or legally mandated. For purposes of this Code, “confidential information” includes all non-public information relating to the Foundation, its business, customers, suppliers or employees.
Compliance with Laws, Rules and Regulations
Directors, officers, volunteers and employees shall comply with all state and federal laws, rules and regulations applicable to the Foundation.
Compliance with Code of Conduct
If you know of or suspect a violation of applicable laws, rules or regulations or this Code, you must immediately report that information pursuant to the Whistleblower Policy. Violations of this Code may result in disciplinary action, up to and including discharge. The Board shall determine, or shall designate appropriate persons to determine, appropriate action in response to violations of this Code.
Open Door Policy
The Foundation’s managers, directors and officers shall be available for any employee who knows of, or suspects a violation of, applicable laws, rules, regulations or this Code. Employees should share their questions, concerns, suggestions or complaints with someone who can address them properly.
The Board must approve any waivers of this Code. Adopted November 8, 2005