Independent Contractor
Code of Ethics and Conduct Outline
Contents
Code of Ethics ................................................................................................................................. 1
Sexual Harassment Policy............................................................................................................... 6
Non-Harassment Policy .................................................................................................................. 7
Drug-Free and Alcohol-Free Work Environment ........................................................................... 8
Social Media Guidelines ................................................................................................................. 9
Recruiting Policies and Code of Conduct ..................................................................................... 10
Recruiting Territories .................................................................................................................... 10
Client Representation .................................................................................................................... 10
Servicing Clients and Candidates ................................................................................................. 10
Communication and Collaboration ............................................................................................... 11
Time Away from Your Business .................................................................................................. 11
Professional Environment and Attire ............................................................................................ 11
Diversity, Equity, and Inclusion ................................................................................................... 12
Summation .................................................................................................................................... 12
Code of Ethics
Build Trust and Credibility
The success of our business is dependent on the trust and confidence we earn from our employees,
independent contractors, and clients. We gain credibility by adhering to our commitments, displaying
honesty and integrity and reaching company goals solely through honorable conduct. It is easy to say
what we must do, but the proof is in our actions. Ultimately, we will be judged on what we do.
When considering any action, it is wise to ask: will this build trust and credibility for Goodwin Recruiting?
Will it help create a working environment in which Goodwin Recruiting can succeed over the long term?
Will this continue to support an environment of inclusion for all those I engage with? Is the commitment
I am making one I can follow through with? The only way we will maximize trust and credibility is by
answering “yes” to those questions and by working every day to build our trust and credibility.
Respect for the Individual
We all deserve to work in an environment where we are treated with dignity, respect, and equality.
Goodwin Recruiting is committed to creating such an environment because it brings out the full
potential in each of us, which, in turn, contributes directly to our business success. We cannot afford to
let anyone’s talents go to waste.
Goodwin Recruiting is an equal opportunity employment company and business partner and is
committed to providing a workplace that is free of discrimination of all types from abusive, offensive or
harassing behavior. Any employee who feels harassed or discriminated against should report the
incident to his or her manager or to a member of the leadership team.
Create a Culture of Open and Honest Communication
At Goodwin Recruiting, everyone should feel comfortable to speak his or her mind, particularly with
respect to ethics concerns. Leadership team members have a responsibility to create an open and
supportive environment where employees feel comfortable raising such questions. We all benefit
tremendously when members of the team exercise their power to prevent mistakes or wrongdoing by
asking the right questions at the right times.
Goodwin Recruiting will investigate all reported instances of questionable or unethical behavior. In
every instance where improper behavior is found to have occurred, the company will take appropriate
action. We will not tolerate retaliation against employees or other business partners who raise genuine
ethics concerns in good faith.
Goodwin Recruiting’s whistleblower policy is as follows:
A whistleblower as defined by this policy is an employee, independent contractor, or associate of
Goodwin Recruiting who reports an activity that he/she considers to be illegal or dishonest to one or
more of the parties specified in this policy. The whistleblower is not responsible for investigating the
activity or for determining fault or corrective measures; appropriate members of the leadership team
are charged with these responsibilities.
Examples of illegal or dishonest activities are violations of federal, state or local laws; billing for services
not performed or for goods not delivered, billing clients directly to circumvent Goodwin Recruiting
accounting procedures, and other fraudulent reporting of numbers.
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If an employee or independent contractor has knowledge of, or a concern of, illegal or dishonest
fraudulent activity, the employee or independent contractor is to contact his/her immediate supervisor
or a member of the leadership team. The employee or independent contractor must exercise sound
judgment to avoid baseless allegations. An employee or independent contractor who intentionally files a
false report of wrongdoing will be subject to discipline up to and including termination or dissolution of
the partnership.
Whistleblower protections are provided in two important areas: confidentiality and against retaliation.
Insofar as possible, the confidentiality of the whistleblower will be maintained. However, identity may
have to be disclosed to conduct a thorough investigation, to comply with the law and to provide accused
individuals their legal rights of defense. The firm will not retaliate against a whistleblower. This includes,
but is not limited to, protection from retaliation in the form of an adverse action such as termination or
partnership dissolution, compensation decreases, or poor work assignments and threats of physical
harm. Any whistleblower who believes he/she is being retaliated against must contact the owner
immediately. The right of a whistleblower for protection against retaliation does not include immunity
for any personal wrongdoing that is alleged and investigated.
All reports of illegal and dishonest activities will be promptly submitted to the owner and appropriate
members of the leadership team who are responsible for investigating and coordinating corrective
action.
Employees with any questions regarding this policy should contact Eric Goodwin.
Employees are encouraged, in the first instance, to address such issues with their managers or their
direct support in the leadership team, as most problems can be resolved swiftly. If for any reason that is
not possible or if an employee is not comfortable raising the issue with his or her manager or direct
support in the leadership team, Eric Goodwin does operate with an open-door policy.
Set Tone at the Top
Leadership has the added responsibility for demonstrating, through their actions, the importance of this
Code. In any business, ethical behavior does not simply happen; it is the product of clear and direct
communication of behavioral expectations, modeled from the top and demonstrated by example. Again,
ultimately, our actions are what matters.
To make our Code work, leadership team members must be responsible for promptly addressing ethical
questions or concerns raised by employees and for taking the appropriate steps to deal with such issues.
Leadership team members should not consider employees’ ethics concerns as threats or challenges to
their authority, but rather as another encouraged form of business communication. At Goodwin
Recruiting, we want the ethics dialogue to continue to be a natural part of daily work.
Uphold the Law
Goodwin Recruiting’s commitment to integrity begins with complying with laws, rules, and regulations
where we do business. Further, each of us must have an understanding of the company’s policies, laws,
rules, and regulations that apply to our specific roles. If we are unsure of whether a contemplated action
is permitted by law or Goodwin Recruiting policy, we should seek the advice from the resource expert.
We are responsible for preventing violations of law and for speaking up if we see possible violations.
Because of the nature of our business, some legal requirements warrant specific mention here.
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Goodwin Recruiting is an Equal Opportunity Employer that does not discriminate on the basis of actual
or perceived race, creed, color, religion, alienage or national origin, ancestry, citizenship status, age,
disability or handicap, sex, marital status, veteran status, sexual orientation, gender identity, genetic
information, arrest record, or any other characteristic protected by applicable federal, state or local
laws. Our leadership team is dedicated to this policy with respect to recruitment, hiring, placement,
promotion, transfer, training, compensation, benefits, employee activities and general treatment during
employment or partnership.
Competition
We are dedicated to ethical, fair and vigorous competition. We will sell Goodwin Recruiting products
and services based on their merit, superior quality, functionality and competitive pricing. We will make
independent pricing and marketing decisions and will not improperly cooperate or coordinate our
activities with our competitors. We will not offer or solicit improper payments or gratuities in
connection with the purchase of goods or services for Goodwin Recruiting or the sales of its products or
services. In addition, employees are prohibited from working for our competitors and must take care to
keep sensitive company information confidential.
Conflicts of Interest
We must avoid any relationship or activity that might impair, or even appear to impair, our ability to
make objective and fair decisions when performing our jobs. At times, we may be faced with situations
where the business actions we take on behalf of Goodwin Recruiting may conflict with our own personal
or family interests. We owe a duty to Goodwin Recruiting to advance its legitimate interests when the
opportunity to do so arises. We must never use Goodwin Recruiting property or information for
personal gain or personally take for ourselves any opportunity that is discovered through our position
with Goodwin Recruiting.
Determining whether a conflict of interest exists is not always easy to do. Employees with a conflict of
interest question should seek advice from their manager or a member of the leadership team. Before
engaging in any activity, transaction or relationship that might give rise to a conflict of interest,
employees must seek review from their managers or a member of the leadership team.
Offering Business Courtesies
Any employee who offers a business courtesy must assure that it cannot reasonably be interpreted as
an attempt to gain an unfair business advantage or otherwise reflect negatively upon Goodwin
Recruiting. Accounting for business courtesies must be done in accordance with approved company
procedures if someone chooses to expense a business courtesy.
Other than to our government customers, for whom special rules apply, we may provide nonmonetary
gifts (i.e., company logo apparel or similar promotional items) to our clients. Further, management may
approve other courtesies, including meals, refreshments or entertainment of reasonable value, provided
that it does not violate any laws or standards of conduct of Goodwin Recruiting or the recipient’s
organization’s policies.
Promote Substance Over Form
At times, we are all faced with decisions we would rather not have to make and issues we would prefer
to avoid. Sometimes, we hope that if we avoid confronting a problem, it will simply go away.
At Goodwin Recruiting, we must have the courage to tackle the tough decisions and make difficult
choices, secure in the knowledge that Goodwin Recruiting is committed to doing the right thing. At
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times this will mean doing more than simply what the law requires. Merely because we can pursue a
course of action does not mean we should do so.
Although Goodwin Recruiting’s guiding principles cannot address every issue or provide answers to
every dilemma, they can define the spirit in which we intend to do business and should guide us in our
daily conduct.
Accountability
Each of us is responsible for knowing and adhering to the values and standards set forth in this Code and
for raising questions if we are uncertain about company policy. If we are concerned whether the
standards are being met or are aware of violations of the Code, we must contact a member of the
leadership team.
Goodwin Recruiting takes seriously the standards set forth in the Code, and violations are cause for
disciplinary action up to and including termination of employment.
Use of Company Resources
Company resources, including time, material, equipment and information, are provided for company
business use. Nonetheless, occasional personal use is permissible as long as it does not affect job
performance or cause a disruption to the workplace.
Employees and those who represent Goodwin Recruiting are trusted to behave responsibly and use
good judgment to conserve company resources. Managers are responsible for the resources assigned to
their departments and are empowered to resolve issues concerning their proper use.
Generally, we will not use company equipment such as computers, copiers and phones in the conduct of
an outside business or in support of any religious, political or other outside daily activity, except for
company-requested support to nonprofit organizations. We will not solicit contributions nor distribute
non-work related materials during work hours.
In order to protect the interests of the Goodwin Recruiting network and our fellow employees, Goodwin
Recruiting reserves the right to monitor or review all data and information contained on an employee’s
company-paid for computer or electronic device and their use of the Internet. We will not tolerate the
use of company resources to create, access, store, print, solicit or send any materials that are harassing,
threatening, abusive, sexually explicit or otherwise offensive or inappropriate.
Questions about the proper use of company resources should be directed to a member of the leadership
team.
Media Inquiries
Goodwin Recruiting is a high-profile company in our community, and from time to time, employees may
be approached by reporters and other members of the media. In order to ensure that we speak with
one voice and provide accurate information about the company, we should direct all media inquiries to
Eric Goodwin. No one may issue a statement on behalf of the company without first consulting with Eric
Goodwin.
Do the Right Thing
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Several key questions can help identify situations that may be unethical, inappropriate or illegal. Ask
yourself:
 Does what I am doing comply with the Goodwin Recruiting guiding principles, Code of Ethics,
Core Values, and company policies?
 Have I been asked to misrepresent information or deviate from normal procedure?
 Would I feel comfortable describing my decision at a team meeting?
 How would it look if it made the headlines?
 Am I being loyal to my family, my company and myself?
 What would I tell my child to do?
 Is this the right thing to do?
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Sexual Harassment Policy
It is Goodwin Recruiting’s policy to prohibit harassment of any employee or contractor by any
Supervisor, employee, contractor, customer or vendor on the basis of sex or gender. The purpose of this
policy is not to regulate personal morality within the Company. It is to ensure that at the Company all
employees and contractors are free from sexual harassment. While it is not easy to define precisely
what types of conduct could constitute sexual harassment, examples of prohibited behavior include
unwelcome sexual advances, requests for sexual favors, obscene gestures, displaying sexually graphic
magazines, calendars or posters, sending sexually explicit e-mails, text messages and other verbal or
physical conduct of a sexual nature, such as uninvited touching of a sexual nature or sexually related
comments. Depending upon the circumstances, improper conduct also can include sexual joking, vulgar
or offensive conversation or jokes, commenting about an employee or contractor's physical appearance,
conversation about your own or someone else's sex life, or teasing or other conduct directed toward a
person because of his or her gender which is sufficiently severe or pervasive to create an unprofessional
and hostile working environment.
If you feel that you have been subjected to conduct which violates this policy, you should immediately
report the matter to a member of company leadership. If you are unable for any reason to contact a
member of company leadership, or if you have not received a satisfactory response within five (5)
business days after reporting any incident of what you perceive to be harassment, please contact the
company President. Note: If a member of company leadership or President is the person toward whom
the complaint is directed, you should contact another member of company leadership. Every report of
perceived harassment will be fully investigated and corrective action will be taken where appropriate.
Violation of this policy will result in disciplinary action, up to and including discharge. All complaints will
be kept confidential to the extent possible, but confidentiality cannot be guaranteed. In addition, the
Company will not allow any form of retaliation against individuals who report unwelcome conduct to
company leadership or who cooperate in the investigations of such reports in accordance with this
policy. Employees or contractors who make complaints in bad faith may be subject to disciplinary action,
up to and including discharge. All employees and contractors must cooperate with all investigations.
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Non-Harassment Policy
It is Goodwin Recruiting’s policy to prohibit intentional and unintentional harassment of any individual
by another person on the basis of any protected classification including, but not limited to, race, color,
national origin, disability, religion, marital status, veteran status, sexual orientation or age. The purpose
of this policy is not to regulate our employees' or contractors’ personal morality, but to ensure that in
the workplace, no one harasses another individual.
If you feel that you have been subjected to conduct which violates this policy, you should immediately
report the matter to a member of company leadership. If you are unable for any reason to contact this
person, or if you have not received a satisfactory response within five (5) business days after reporting
any incident of what you perceive to be harassment, please contact the company President. Note: If a
member of company leadership or the President is the person toward whom the complaint is directed,
you should contact another member of company leadership. Every report of perceived harassment will
be fully investigated and corrective action will be taken where appropriate. Violation of this policy will
result in disciplinary action, up to and including discharge. All complaints will be kept confidential to the
extent possible, but confidentiality cannot be guaranteed. In addition, the Company will not allow any
form of retaliation against individuals who report unwelcome conduct to company leadership or who
cooperate in the investigations of such reports in accordance with this policy. Employees or contractors
who make complaints in bad faith may be subject to disciplinary action, up to and including discharge.
All employees and contractors must cooperate with all investigations.
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Drug-Free and Alcohol-Free Work Environment
To help ensure a safe, healthy and productive work environment for our employees and contractors, to
protect Company property, and to ensure efficient operations, the Company has adopted a policy of
maintaining a workplace free of drugs and alcohol. This policy applies to all employees, contractors, and
other individuals who perform work for the Company.
The unlawful or unauthorized use, abuse, solicitation, theft, possession, transfer, purchase, sale or
distribution of controlled substances, drug paraphernalia or alcohol by an individual anywhere on
Company premises, while on Company business (whether or not on Company premises) or while
representing the Company, is strictly prohibited. Employees, contractors, and other individuals who
work for the Company or are partnered with the company also are prohibited from reporting to work or
working while they are using or under the influence of alcohol or any controlled substances, which may
impact an employee or contractor's ability to perform his or her job or otherwise pose safety concerns,
except when the use is pursuant to a licensed medical practitioner's instructions and the licensed
medical practitioner authorized the employee, contractor, or individual to report to work. However, this
does not extend any right to report to work under the influence of medical marijuana or to use medical
marijuana as a defense to a positive drug test, to the extent an employee or contractor is subject to any
drug testing requirement, to the extent permitted by and in accordance with applicable law.
Violation of this policy will result in disciplinary action, up to and including discharge.
The Company maintains a policy of non-discrimination and will endeavor to make reasonable
accommodations to assist individuals recovering from substance and alcohol dependencies, and those
who have a medical history which reflects treatment for substance abuse conditions. However,
employees or contractors may not request an accommodation to avoid discipline for a policy violation.
We encourage employees or contractors to seek assistance before their substance abuse or alcohol
misuse renders them unable to perform the essential functions of their jobs, or jeopardizes the health
and safety of any Company employee or contractor, including themselves.
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Social Media Guidelines
While all Goodwin Recruiting employees and 1099 contractors are welcome to participate in social
media, we expect everyone who participates in online commentary to understand and refer to these
simple but important guidelines. Please keep in mind that our overall goal is simple: to participate online
in a respectful, relevant way that protects the brand reputation and of course follows the letter and
spirit of the law. Should you have your personal accounts representative of your ties with Goodwin
Recruiting, it is a reasonable expectation that you will separate personal beliefs from those of the
company.
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Should you represent your professional role with Goodwin Recruiting in your personal social
media account, be clear about your role. If you are writing about Goodwin Recruiting or a
competitor, use your real name and identify that you work in partnership with Goodwin
Recruiting. If you have a vested interest in what you are discussing, be the first to say so.
Never represent yourself or Goodwin Recruiting in a false or misleading way. All statements
must be true and not misleading; all claims must be able to be substantiated.
Post meaningful, respectful comments — in other words, no spam and no remarks that are offtopic or offensive.
Use common sense, common courtesy, and maintain the same ethical standards that you do
with Goodwin Recruiting.
When disagreeing with others' opinions, keep it appropriate and polite. If you find yourself in a
situation online that looks as if it’s becoming antagonistic, try to wrap up the conversation as
quickly as possible.
Best Recommended Practices
 Appropriate profile picture – meaning nothing offensive or illegal
 Profile should be private – non-connections cannot access pictures
 Good judgement when liking others posts
 If you are expressing religious, political, or any controversial views, please keep separate from
Goodwin Recruiting related posts
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Recruiting Policies and Code of Conduct
Recruiting Territories
1. We believe in servicing our clients and candidates and therefore function with open territories.
An open territory is one where any partner may source candidates or prospective clients in any
geography.
Client Representation
1. An IC who establishes an agreement with a company based on their efforts will maintain that
client as long as the account remains active and productive. A client is defined as a company where an
active, weekly communication exists between IC and client, where send outs occur within 30 days,
where they hire people from Goodwin Recruiting, and where Goodwin Recruiting is paid by the client. It
is essential for each IC to manifest results by keeping in contact with clients. It is understood that not all
fee agreements result in long term relationships.
2. Client accounts belong to Goodwin Recruiting and accounts can be reassigned at the discretion
of Goodwin Recruiting leadership. Accounts will be reassigned in the hopes that stagnant or nonproducing accounts can be turned into sales and revenue for the company. A non revenue-producing
account does not benefit the company or the IC in any way. IC is encouraged to continually evaluate the
portfolio of clients they represent. However, if it is not a revenue productive account, it may be
reassigned at discretion of Goodwin Recruiting.
3. If a dispute exists as to what account belongs to whom, the fee agreement will prevail in the
event it is a producing client. Again, an IC may have obtained a fee agreement, but failed to
communicate or keep the account alive. If it is a dormant account, at the discretion of leadership, it may
be reassigned.
4. A review of fee agreements and clients will be done periodically to evaluate the status of
productive fee agreements, and at that time accounts may be reassigned to another IC in hopes of
turning the account to a producing client.
Servicing Clients and Candidates
1. Goodwin Recruiting requires adherence to all equal employment opportunity laws and
regulations. Recruiters must not discriminate in any way based on a client or applicant’s actual or
perceived race, creed, color, religion, alienage or national origin, ancestry, citizenship status, age,
disability or handicap, sex, marital status, veteran status, sexual orientation, gender identity, genetic
information, arrest record, or any other class protected by state or federal law. This includes any
interview questions or tactics that may elicit discriminatory information. If a client or applicant
expresses viewpoints that are not in adherence with EEO guidelines, you should immediately and
transparently remind them of the laws. Any member of our leadership team will offer advice on how to
handle this communication.
2. In accepting partnership with Goodwin Recruiting, the IC will be assessed on their
representation of Goodwin Brand Standards, including meeting required metrics, as sales are a direct
reflection of delivering the Goodwin Brand Standards to our clients and candidates.
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3. From an interview standpoint, we should be servicing our candidates’ needs by asking them to
visit the IC closest to them in person. Face to face interviews with candidates is always the goal,
followed by webcam interviews and lastly phone interviews if the only option.
4. If a candidate expresses dissatisfaction with a recruiter, the candidate may be reassigned at
Goodwin Recruiting Leadership discretion, in the best interests of the candidate.
5. An IC cannot direct recruit candidates out of any Goodwin Recruiting Clients. Direct Recruiting
includes calling a client’s place of business or direct outreach to a specific individual via email or social
media who is not on an active search. It does not include inbound applications, publicly posted current
resumes, mass emails, or referrals.
Communication and Collaboration
1. Goodwin Recruiting highly encourages the collaboration of recruiting partners while working
with clients and candidates. We ask that recruiting partners who choose to collaborate practice
congruent relationships with one another and communicate as efficiently with one another as possible.
2. Goodwin Recruiting also asks that while collaborating with other recruiting partners that all
recognize and appreciate the time that goes into sourcing a client and preparing a candidate for an
interview.
Time Away from Your Business
1. IC dictates their schedule individually as there is no company directive. As a courtesy and to
provide coverage assistance, it is requested you review the Out of Office resources to effectively
communicate your time away.
2. Should personal crisis occur that unexpectedly pulls you away from your business, there is an
expectation for timely communication with Goodwin Recruiting as your business partner. This is to
protect the brand from delays in communication with candidates, clients and other ICs. If there is a
failure in clear and timely communication, Goodwin Recruiting reserves the right to dissolve the
partnership and halt access to all provided resources.
Professional Environment and Attire
1. To keep consistent professional appearance between Goodwin Recruiting and any IC we partner
with, it is required you have a professional office space free from personal distractions, including people
or pets. This home office environment should be conducive to the goals of Goodwin Recruiting and
provides no distractions that would interfere with conducting business to the standard of Goodwin
Recruiting. Home office standards and environment should be identical to an outside office space in an
office building. As you will be on webcam throughout your day, it is expected that your backdrop has
appearance of a professional workspace. We recommend consideration of how your decorate your
office, realizing that religious, political or other polarizing décor may make candidates, potential clients,
clients, other Recruiting Partners or members of our Extensive Support team uncomfortable as it does
not relate to a business.
2. In addition, your personal appearance and attire should meet professional brand standards,
meaning appearing well groomed and wearing business casual attire to be prepared to interface with
candidates, potential clients, clients, other Recruiting Partners or members of our Extensive Support
team at a moments’ notice.
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Diversity, Equity, and Inclusion
Goodwin Recruiting is 100% committed to our Core Value: Dedicated to Diversity and Inclusion. We
maintain business partnerships with Recruiting Partners who are aligned with all of our Core Values. As
we act as conduits between candidates and clients in the hiring process, we are always striving to be
advocates for presenting diverse slates of candidates for all positions. We strictly follow EEO laws, but
more importantly, we want to guide our clients and candidates through an unbiased and equitable
recruiting process. We aim to open doors for our candidates and consult with our clients on how to
achieve workplace goals for diversification, equity and inclusion. All Goodwin Recruiting Partners should
be educated on EEO laws and protected classes and are strongly urged to take the Company’s provided
training on DEI recruiting.
The same follows suit for Goodwin internally. We are intentional in our pursuit of an unbiased,
equitable, and inclusive environment. We have a DEI Council dedicated to ongoing initiatives, ensuring
that we maintain our focus and accountability with our efforts in these endeavors. Our Recruiting
Partners are expected to treat one another, both personally and professionally, without discrimination,
and contribute to an environment of equity and inclusivity. In keeping with our Core Value of
Transparent Communication, we strongly encourage all partners to feel comfortable raising issues or
concerns at any time so we can learn, improve and experience growth. You can always speak freely with
our Director of Human Resources or reach out directly to a member of our DEI Council. We want
everyone entering a business partnership with Goodwin Recruiting to understand that we seek and
expect full alignment on this important aspect of our values and our culture.
Summation
All IC agreements are subject to annual renewal based on IC being a valuable and productive asset to
the Goodwin Recruiting team. Goodwin Recruiting and IC reserve the right to terminate this contract at
any time. If Goodwin Recruiting does not make changes to this contract annually but Goodwin
Recruiting and IC agree to continue their relationship this agreement will renew with the same terms.
Goodwin Recruiting reserves the right to make adjustments to the General Policies at any time.
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