Code of Ethics - National Geographic Society

Code of Ethics - National Geographic Society Code of Ethics The policy and legal requirements that govern how the National Geographic Society conducts business. A Message from Our Chief Executive Officer At the Society, we are guided by our mission to use the power of science, exploration, and storytelling to illuminate and protect the wonder of the world. Every day, our work touches the lives of people around the world–a great privilege and a great responsibility. Achieving our ambitious mission hinges on cultivating a culture that’s grounded in honesty, fairness, transparency, respect, dignity, and sensitivity. These values are among the many reasons that the National Geographic Society is one of the most recognized and trusted brands in the world. As we continue to grow, innovate, and accelerate our impact-driven work as a nonprofit organization with global reach, it’s our duty to ourselves and our global community–our Explorers, Trustees, donors, partners, and others–to maintain this trust by upholding the highest standard of ethical conduct in all that we do. Our Code of Ethics is fundamental to this commitment. The Society’s Code of Ethics is our working guide to ensure that we clearly understand the Society’s expectations for ethical behavior and put them into practice. The Code outlines our principles, standards, and key policies relating to ethical matters in a transparent way that makes it easier to apply them in our day-to-day work. Given the complexities of the world in which we live and work, the Code is designed to equip you with the information you need when you encounter a challenging situation. It is easy to say what we must do, but the proof is in our actions. All of us at the Society have a responsibility to review the Code of Ethics and commit ourselves to these principles. I strongly encourage you to ask questions if you are unsure or have concerns about any business practice or conduct you think may be inconsistent with the Society’s values or Code. We have several resources available to answer any questions you have or address issues that arise. Undoubtedly, one of the best parts of the National Geographic Society is our community. You play a key role in building a world-class organization driven by purpose, passion, and excellence. Thank you for your commitment to upholding the highest standards of ethical conduct at the Society, and for everything you do to support our mission! Best regards, Jill Tiefenthaler Chief Executive Officer National Geographic Society Introduction The National Geographic Society’s success is built on the foundation of each staff member acting according to the highest standard of ethical behavior, including by demonstrating a commitment to honesty, fairness and transparency. Our Code of Ethics establishes this commitment as the fundamental requirement for everything you do on behalf of the Society. The Code also serves as a roadmap to put the Society’s ethical standards into practice. It offers links to additional information (including underlying policies) and contacts to help answer any questions you might have, or resolve difficult situations you might face. Reading the Code of Ethics is not a substitute for reading and familiarizing yourself with the National Geographic Society’s policies. You are responsible for understanding and following all Society policies that apply to your position. If you are unclear about those policies, or how to comply with them, it is your responsibility to ask for help.There are many resources available to support you, including your manager, Human Resources, Legal and Business Affairs (LBA) and the Society’s Ethics lead. Contact information is available on the last page of the Code. Everyone acting on behalf of the Society must comply with this Code, as well as all applicable laws, rules, regulations, and Society policies. We also expect third parties and partners with whom we do business to conduct themselves in ways that are consistent with our Code. Maintain the Highest Standards of Ethical Conduct You must exercise the highest standard of ethical decision making, and sound professional judgment regardless of where or when you are doing business on the National Geographic Society’s behalf. There are two basic principles that must guide your actions: Conduct every aspect of your business in a fair, lawful and ethical manner; Encourage and expect everyone you work with to do the same. We are deeply committed to performing our mission in a manner that earns the respect of everyone, including: charitable donors, business associates, third party representatives, Society members, our staff, Explorers, fellows, grantees and the general public. We believe that the consistent application of our standard of ethical conduct is the best way to do it. In your work with us, you are responsible for promoting the Society’s mission in a fair, ethical and professional manner. The professionalism you demonstrate in your work helps us sustain and enhance the Society’s reputation. It’s also what makes the Society a great place to work. Avoid Conflicts of Interest As an employee, you must always act in the best interest of the National Geographic Society. This includes being sensitive to situations where it might appear your responsibility to the Society is compromised and avoiding conflicts of interest. Here are some ways a conflict of interest might arise: Having a personal, family, or financial interest in any Society transaction; Engaging in a personal intimate relationships, including romantic and/or sexual, with another member of the NGS community, whether another employee, constituent, or otherwise; Acting as an employee, consultant (or providing any other assistance) to a competitor; Having a financial interest in a competitor, supplier, contractor, grantee or fellow; consultant, or other business partner; Hiring or supervising, directly or indirectly, a family member or person with whom you have a close relationship; Accepting gifts, discounts, services beyond policy limits from anyone doing (or seeking) business with the National Geographic Society. If you have a potential conflict, you must report it to your manager – before you engage in any activity related to the situation. Your manager, in consultation with you, Human Resources and LBA, will determine what measures should be taken to resolve it appropriately. Such measures typically include recusing yourself from any decision relating to the matter. If you are unsure, but have questions, get help from your manager, Human Resources, or LBA immediately. Gifts and Gratuities Staff members may not receive any gift worth more than $100 from any person or organization  doing business with the National Geographic Society. Staff members involved in purchasing  decisions must take extra care to avoid any gifts that might affect,or appear to affect, their  decision-making responsibilities on behalf of the National Geographic Society. Corruption and Bribery - Strictly Prohibited Every country we work in has laws against corruption and bribery. We take compliance with these laws seriously. As a U.S.-based organization, the National Geographic Society focuses particular attention on the anti-bribery standards of the U.S. Foreign Corrupt Practices Act. We may not offer, promise, pay, give or approve any bribe, kickback or other inducement in the  form of cash or anything else of value (such as gifts, travel, entertainment, charitable contributions) to any person or organization, with the intent to exert improper influence over the  recipient, induce the recipient to violate their duty of loyalty, secure an improper advantage for  the National Geographic Society, or improperly reward the recipient for past conduct. Nor may we allow any third-party representative (such as customs clearance brokers, independent contractors, consultants, business partners) or anyone else to do so on our behalf. Our Anti-Corruption policy sets processes and procedures that must be followed in our relationships with Explorers, Fellows, Grantees, Third-Party Representatives, Field Workers (“fixers”), Exhibitors and recipients of charitable donations. Additionally, there are special standards that apply to our interactions with foreign government officials (including travel, accommodations, meals and entertainment). Demonstrate Business and Financial Integrity RESPONSIBLE USE OF ASSETS AND EXPENDITURES The responsible expenditure of financial resources, and use of the National Geographic Society’s assets, is essential to the Society’s sound management, maintenance of our reputation, and the continuing confidence of our donors and partners. To ensure that our financial statements properly reflect our assets, liabilities and transactions, the financial records each staff member submits must be complete, accurate and understandable. This includes the information each of us provides in payroll documents, time cards, travel and expense reports, purchasing, and every other National Geographic Society financial record. The key principles you must follow in your business dealings, expenditures and record keeping include: Act ethically, professionally and responsibly at all times handling NGS resources (funds, trademarks and other property). Be conservative when spending the National Geographic Society’s money. Be accurate, thorough and truthful in your business records. RESPONSIBLE BUSINESS CONDUCT All contracts with third parties (such as independent contractors, consultants, vendors, suppliers, business partners and others) must be reviewed by LBA in advance of the National Geographic Society doing business with the third party, and a contract must be in place before work begins. No contractual agreement will be considered valid and enforceable by the National Geographic Society in the absence of approval. Respect for intellectual property, including copyrights and trademarks owned by the National Geographic Society and others, is critically important to us. Each of us is responsible for ensuring that these rights are upheld. You must contact LBA in order to obtain a license, or other appropriate clearance, prior to using any intellectual property in your work on behalf of the Society. We comply with all U.S. government trade sanctions. These sanctions may prohibit or restrict travel to certain countries, business activities (such as grants, contracts,collaborations) Professional & Respectful Conduct We are proud of our professional and congenial work environment. We are firmly committed to ensuring it remains productive, engaging and respectful. The Society will not tolerate unprofessional behavior, harassment, bullying or mistreatment in the workplace. This expectation extends to events, social outings, field work, and other activities, including online. Use I.T. Systems Responsibly Each of us is responsible for protecting the National Geographic Society’s information technology  systems (including our computer network, hardware, software and all related applications). We must do our part to protect these systems from damage, alteration, theft, fraud, misuse and unauthorized access. Media Inquiries and Social Media The Communications Team is exclusively responsible for handling all media inquiries concerning the Society as well as overseeing the creation and use of National Geographic  Society sponsored social media. Lobbying and Political Activities The National Geographic Society may engage in specific, limited lobbying in the U.S., and  internationally, in support of our mission. The Society must document its lobbying activities and  confine them to acceptable levels in order to maintain the Society’s status as a tax exempt, not-for-profit organization. Before engaging in any activity that could be considered lobbying as part of your work with the Society, you must first contact LBA for approval to do so. The Society may not engage in any type of political campaign activity, and likewise you may not engage in political campaign activity as part of your work with the Society. Addressing Concerns and Reporting Violations OPEN DOOR We recognize that there are situations in which making the right decision can be challenging. By  raising concerns, sooner rather than later, you give the National Geographic Society the  opportunity to resolve issues that might otherwise be damaging to our mission and reputation. Many of these issues can best be resolved in consultation with your manager, or the next higher level of your management. All managers are responsible for maintaining an “open door” to staff. Alternatively, you may contact Human Resources, LBA or your Senior Leader. We are here to support you doing the right thing. REPORTING POTENTIAL VIOLATIONS If you believe that a violation of law, our Code, or our policies may have occurred, or is going to occur, you are affirmatively obligated to report it immediately. While we hope you feel comfortable discussing it with your manager, we recognize that there may be times when you prefer to use another avenue for addressing an issue. You should feel comfortable reporting the issue to any one of the following: your next level manager, Human Resources, LBA, your senior leader, or any member of the Board of Trustees. As an additional avenue for reporting actual and potential violations, the National Geographic  Society offers an external helpline available to you 24 hours a day, 7 days a week. The helpline is administered by an independent third party (Mitratech) and all reports are directly routed to the NGS Ethics team within LBA. You may submit an email, web-based or automated phone  report, and you have the option of speaking to a trained Mitratech customer service  representative who will listen to your concern. You may contact the external helpline at  (888) 647-0647 (888-NGS-0-NGS), or EthicsNGS@getintouch.com, or https://report.syntrio.com/ngs. Reports to the helpline can be made anonymously, but we strongly encourage you to identify yourself. This helps ensure your concern is thoroughly considered and appropriately addressed. You can arrange to receive and respond to follow up communications through the helpline even if you choose to be anonymous. We ask that  you make these arrangements in order for us to communicate with you about the issue. Reports are referred to the Society’s ethics lead for appropriate handling. Please note that many of the National Geographic-branded media and/or consumer lines of business (such as the National Geographic magazine, the National Geographic shows and movies on television or Disney+, and National Geographic Expeditions travel) are operated by The Walt Disney Company. If you have questions or concerns related to those products, please contact The Walt Disney Company directly. INVESTIGATION AND RESOLUTION All reported violations of law, our Code or our policies will be investigated promptly, objectively and thoroughly. The National Geographic Society treats these as confidential internal matters. Information about them is shared only to the extent necessary to investigate and take any corrective action the National Geographic Society deems appropriate for resolving the matter  consistent with our standards and the law. Staff members found to have committed violations are subject to disciplinary action up to and  including termination of employment and possible legal action depending on the violation. Similarly, third party representatives, and others acting on our behalf, are subject to having their  business relationship with National Geographic Society terminated, and potentially other penalties, for violations. WE DO NOT RETALIATE Retaliation against any staff member who reports misconduct is strictly prohibited and will not be  tolerated. Staff members are expected to seek advice, raise concerns, report potential misconduct in good faith and cooperate with the investigative process. This is critical because silence hurts us when it comes to ethics and compliance. If you feel you have been retaliated against for making a good faith report, be sure to contact one of the resources listed on the last page of the Code. Additional Expectations for Managers Managers have a special responsibility to model our Code of Ethics with words backed up by actions that set a strong example for all to follow, including: Never ignore illegal behavior, Code violations, policy violations or other conduct that does not meet our high expectations for ethical and lawful conduct; Ensure that the staff you manage are familiar with our Code, and understand the importance of our strong ethical and compliant culture; Create a work environment where staff feel comfortable discussing our Code, and speaking up when they have concerns; Promptly escalate any concern about a potential violation of law, our Code or policies to LBA. Never retaliate against a staff member who reports a concern about suspected or actual misconduct, or tolerate retaliation by anyone else. Certification National Geographic Society requires all staff members and Trustees to certify compliance with the Code of Ethics, annually. Contact Information HUMAN RESOURCES Mara Dell, Chief Human Resources Officer 202-807-3922 mdell@ngs.org Yvonne Perry, Vice President 202-807-3253 yperry@ngs.org LEGAL & BUSINESS AFFAIRS Sumeet Seam, Chief Legal Officer 202-807-3154 sseam@ngs.org Sarah Stephens, Sr. Director & Associate General Counsel (Ethics and Employment) 202-807-3117 sstephens@ngs.org Jennifer Dill, Sr. Director & Associate General Counsel (Anti-Corruption and Lobbying) jdill@ngs.org FINANCE Mougeh Kowkabi, VP, Shared Services & Risk Management Mkowkabi@ngs.org ETHICS HELPLINE (888) 647-0647 (NGS-0-NGS) standard-reports@mitratech.com The National Geographic Society Code of Ethics is a guide to policy and legal requirements that govern how we conduct business. It is a general reference tool for our staff and business partners everywhere. It does not describe all applicable laws or National  Geographic Society policies, or give full details on any individual law or policy. It is intended for informational use only. National Geographic Society reserves the right to modify, revise, or alter its Code of Ethics and its policies. Nothing in it should be construed  as a contract of employment. Photo credits: Rainer von Brandis, Mark Thiessen