Code of Ethical and Professional Standards Living Our Mission Through Ethics and Integrity Table of Contents Letter to Valued Employees 3 Living Our Mission Through Ethics and Integrity 4 Core Ethical Values 5 Ethics Begins With You 8 Core Code Provisions 9 Frequently Asked Questions 13 2 Dear Valued Employee, As you read this document, we would like for you to ponder and answer two vital questions: Whose responsibility is it to make sure our Credit Union adheres to the highest of ethical and professional standards? Why does it matter? The answer to the first question is very simple – all of us who represent Kinecta Federal Credit Union as valued employees. And why does it matter? Kinecta Federal Credit Union is known as an ethical and honest credit union, worthy of our members’ trust and support. Having this reputation affords us the opportunity to hire the very best employees, to gain new members and to give back to the communities where we reside. Our good name is vital for maintaining our ability to do business in the future. As the leadership of Kinecta Federal Credit Union, one of our most important duties is to provide the best possible workplace for everyone in the organization. Enjoying our jobs is the first step. However, all of us should also have the comfort of knowing we work in a safe, secure and ethical workplace. Only then can we all feel proud to work here, feel good about our jobs, and attain our vision to provide exceptional member service. Your cooperation is essential to ensure that we maintain a positive, productive workplace. This Code of Ethical and Professional Standards along with your employee handbook and other published policies and procedures should be carefully reviewed by you and followed. If you have any questions regarding this or any other polices, please contact your immediate supervisor or the Human Resources Department. Together, we can ensure that Kinecta Federal Credit Union remains the first choice for our members’ financial needs if each and every one of us continues to live our mission through ethics and integrity. Kind Regards, The Executive Team 3 Living Our Mission Through Ethics and Integrity Kinecta Federal Credit Union maintains certain policies to guide its employees with respect to standards of conduct expected in areas where improper activities could damage the reputation of the organization and otherwise result in serious adverse consequences to the credit union, our members, and to the employees involved. The purpose of Kinecta’s Code of Ethical and Professional Standards is to affirm, in a comprehensive statement, Kinecta’s commitment to live by the highest ethical and professional conduct and behaviors and to the required adherence to these standards by all employees. What is a Code of Ethical and Professional Standards? The Code of Ethical and Professional Standards is a formal statement of the core values and business practices that guides how Kinecta Federal Credit Union and its employees conduct themselves in delivering exceptional service to our members. Our employees, from the executive team to the line staff are required to comply with all ethical standards presented in various forms, including but not limited to, the Employee Handbook, Human Resources Policies and Procedures and departmental policies and procedures as well as this formal statement of ethical and professional standards. What is the Intent of the Code of Ethical and Professional Standards? To build respect, credibility and importance within our organization, with our members, the business community, and the communities in which we reside To assist the organization in achieving our goals and objectives To positively influence workplace and recruitment practices To encourage professional decision-making and responsibility This Code is available electronically on the Kinection. When updates to the Code are required, they will be made to the electronic version. You should always check the electronic version for the latest updates. This Code is intended to provide general guidance to be followed by all Kinecta Federal Credit Union Employees and representatives. Where conflicts exist with other policy or regulations, the requirement containing the higher standard of ethical conduct shall apply. Kinecta Federal Credit Union reserves the right to update or otherwise change this Code at any time. 4 Core Ethical Values Kinecta Federal Credit Union is committed to doing the right thing – all the time! One way we do this is by living our mission through ethics and integrity. This means making ethical choices in difficult situations. It means we do this even when no one else is watching. That is why we have created this Code of Ethical and Professional Standards. This code is specifically designed to promote honest and ethical conduct and to deter wrongdoing. Violations of the Code and any other policies and procedures of the Credit Union may result in disciplinary action, up to and including termination. The Code is also designed to be part of a total system to encourage ethical conduct that includes: Senior level commitment to ethics, a department completely devoted to ensuring that the credit union is in compliance with all state, federal and local regulations governing Kinecta, regular ethics training that starts on your very first day of employment and a formal process that allows you to confidentially raise ethical concerns as well as continuing communications about our commitment to the highest ethical standards. Our commitment to living our mission through ethics and integrity can be summed up in the following eight core ethical values. As you review specific policies and procedures that affect your daily work life at Kinecta, it is useful to have these core values in mind as a context for understanding what it means to do the right thing – all the time - and to live our mission. Put the Member First By making every effort to deliver high performance in our daily duties and responsibilities and to do everything in our power to positively impact our work units, we all contribute to the overall goal of delivering exceptional member service. It doesn’t matter if we have direct contact with the member or not; if we individually treat people well, and deliver our best – collectively we will contribute to the bottom line of the Credit Union. Honesty and Truthfulness It is difficult to meet any of our goals and objectives without honesty and truthfulness as the core foundation on which we build all of our ethical standards. To be honest is defined as not being deceptive; to be truthful; not fraudulent; genuine and of good repute. Each and every one of us is required to live up to that definition. By doing so, we can be assured that our members will trust us, and we will attract the very best applicants to join our team. 5 Integrity Integrity results from consistent decisions to act ethically in all situations, even the difficult ones. To have integrity is to uphold ethical principles and to fully live up to our obligations as a member of the Kinecta Team. Each of us should always be counted on to do what we say we will do, without fail – consistently and reliably. Without being told what to do, as Kinecta Employees, integrity will drive us to adhere not only to the letter of the law, but also to its spirit. Quality Kinecta Federal Credit Union is committed to the goal of delivering products and services that enhance the lives and well-being of our members and employees. Quality means more to us than the absence of defect. It speaks to our making every effort to deliver to the best of one’s ability and to strive to endeavor to meet all the needs of our members, fellow employees and the community at large. Providing top quality at a great value is our aim. Respect Others Respect can be described as regard for the inherent worth of each individual. To be respectful requires us to create an environment where people are treated well and are afforded all of the rights they are entitled to both under law and in line with Credit Union Policy. It goes without saying that a respectful workplace is safe and free from discrimination and harassment. In addition, it affords employees equal opportunity to pursue their goals and it always protects the privacy of personal information of our members and employees. Fairness Webster’s Dictionary describes a fair person as one who exhibits the attributes of impartiality, being just, objective and unbiased in their thinking. Fairness is closely related to a concern for how others are treated – ensuring that we treat them in a way we would wish to be treated in a similar situation. Fairness underlies our commitment to treat people ethically and to apply ethical standards and reasoning to all our decisions. Fairness must also govern how we treat our members, vendors, competitors and how we manage our working relationships. Be a Good Citizen A citizen is one who owes loyalty to and is offered protection from the place which they reside or belong. At a minimum good citizenship requires all of us to obey applicable laws and regulations. It also means that we must respect the environment, provide a safe and healthy workplace and give back to the communities we belong to. As an organization, we continue to be committed to equal employment opportunity and diversity of our Credit Union. We also give back to our communities through a variety of philanthropic endeavors and strive for an open, transparent business climate free from corruption and unlawful practices. 6 Be Responsible and Take Accountability Stepping up to our responsibility calls on us to accept the obligation to act in certain ways when called upon to do so, or when we see the need to take action. Accountability is the willingness to accept the consequences of our actions – good and bad! Together they are the foundation and cornerstone of mature, ethical conduct. As employees of Kinecta Federal Credit Union, we are both responsible and accountable for our actions. This includes, but is not limited to living up to the standards outlined in this document. 7 Ethics Begins With You In everyday life, we may be presented with the challenge to “do the right thing.” Kinecta Federal Credit Union recognizes that all employees may encounter ethical challenges in their work. If Kinecta is to live up to its mission with ethics and integrity, it takes each of us to do our part. Ethics at Kinecta begins with YOU! When you are faced with a business decision that seems to have ethical overtones, here are some questions you should ask yourself to determine your best course of action: 1. Am I adhering to not just the letter, but the spirit of any applicable law or Kinecta Policy? 2. Would I want my actions reported on the front page of the newspaper? 3. What would my family, friends or neighbors think of my action? 4. Could my actions lead to my termination or arrest? 5. Will there be any direct or indirect negative consequences for Kinecta due to my course of action? 6. Are my actions consistent with the overall values set forth in this Code and in other published Kinecta policies and procedures? If you are uncertain about the correct course of action to take, STOP and ask for help! If you prefer to remain anonymous, you can call the 1-800 Ethics Hotline or go online to the EthicsPoint System to report any possible wrongdoing or to ask for help and direction. Points of Contact It is your duty and responsibility to report any violation of this Code or any other Kinecta Policy. Your supervisor is generally the first person you should contact if you have questions about any policy or procedure or to report any violations that you have become aware of. In some cases you may feel more comfortable discussing the matter with someone other than your supervisor. In those cases, there are other means to report violations at Kinecta Federal Credit Union. You may contact any of the following on a confidential basis for the purpose of discussing any issue related to this Code or to report any other type of violation: Corporate Human Resources Manager Any member of the Executive Team Call the 1-800 Ethics Hotline or go online to Ethics Point 8 Core Code Provisions The following Core Code Provisions are intended to be a guide and reference for users in support of day-to-day decision making. They are meant to clarify the organization’s mission, values and principles, linking them with standards of professional conduct. The code is also designed to encourage discussion of ethics and to improve how employees deal with the ethical dilemmas and gray areas that are encountered in everyday work. These codes are meant to complement, not replace, other published and stated relevant standards, policies and rules of the credit union. The list of provisions is not exhaustive, and is not intended as a complete list of policies and procedures. Accuracy of Records Kinecta is committed to maintaining our employee and member records and information in a manner that protects the privacy and confidentiality of those records. Employees may not obtain, use or divert any Credit Union information for personal use or benefit. Employees may not remove, alter, or destroy records or information from any branch or department without appropriate permission. Conflicts of Interest All employees must avoid any conflict of interest interacting with members and vendors, both real and perceived. Kinecta Federal Credit Union respects employees’ rights to engage in activities outside of their jobs. These activities, however, should not put you in a position to be in direct conflict with the Credit Union and/or your position within the Credit Union. Avoiding actual or apparent conflicts of interest creates and sustains the trust of our members, employees, business partners and the community. Disclosure of Information Employees may not disclose financial, sensitive or otherwise confidential information about the Credit Union, its members or other parties to any third party unless specifically authorized to do so. E-mail, Internet and Information Technology Employees should exercise the same care, caution and etiquette in sending email messages as they would in a written business communication. The e-mail system is not entirely secure and may be susceptible to interception. All emails that are sent by employees should be professional and appropriate to the circumstances. Anyone provided a connection to the Internet is provided such connection primarily for business use. Employees should not abuse access to the Internet for personal purposes. Equal Opportunity At Kinecta Federal Credit Union, we believe in the intrinsic worth and dignity of every human being. This belief is evident in our commitment to equal opportunity. Therefore, 9 all employment decisions will be made on the basis of an individual’s qualifications as to the requirements of the position. We will not make employment-related decisions, including recruitment, hiring, transfer, promotion, down-grades and job assignments based on or influenced by an applicant’s or employee’s race, color, religion, sex, age, national origin, sexual orientation, disability, medical condition, martial status, or any other considerations made unlawful by federal, state or local law. Financial Activities Every employee is responsible for conducting all financial activities with honesty and integrity. Therefore, no employee of the Credit Union shall transact business on any account on which he/she is the owner or co-owner, or any account owned by a family member or other person with whom he/she has a close personal relationship. Frauds and Thefts All employees must ensure that our assets our protected against theft, loss or abuse. Assets include products, money, information, equipment and our reputation. These are highly valuable and should be safeguarded. Protection of Kinecta property is the responsibility of each employee. Gifts and Gratuities To avoid any conflict of interest interacting with members and vendors, both real and perceived, employees or their family members are not allowed to accept gifts of substantial? value from the Credit Union’s members or vendors. No gifts of any value should be accepted under any circumstances that may be used in exchange for favors or special handling outside Credit Union policies and procedures. Never cash – value limit of goods? Illegal Drugs and Alcohol The Credit Union is committed to maintaining a safe and healthful work environment for all its team members. Individuals who abuse the use of intoxicants affect productive and efficient job performance and potentially endanger themselves, co-workers and members. Substance abuse of any kind will not be tolerated. The Credit Union prohibits the use, sale, dispensing or possession illegal drugs and narcotics and alcohol while on Credit Union property. 10 Intellectual Property Patents, trademarks and copyrights prohibit the unlicensed use of a protected invention, identifier (such as our name or logo) or work (such as a photograph, printed materials or software). Internal Investigations From time to time, Kinecta conducts internal investigations of employee conduct. All employees are required to cooperate in these internal investigations. Employees who fail to cooperate or who obstruct these investigations are subject to discipline, up to and including termination. Outside Employment We understand that what you do on your own time is, within normal limits, your own business. However, if you are employed full-time with us, we expect your Credit Union position to be your primary employment. Therefore, you will be evaluated on the same performance standards and will be expected to meet our scheduling requirements, regardless of any secondary jobs. Additionally, you may not disclose any confidential, privileged or personal information acquired while being employed at the Credit Union to any other potential or current employer. Political Activities Good corporate citizens do not unfairly or illegally influence the political process in the communities in which they do business. Kinecta Federal Credit Union is committed to following all national, state, and local laws that govern elections and campaign contributions. Privacy and Confidentiality Kinecta Federal Credit Union is committed to protecting confidential and sensitive information. This commitment to confidentiality is critical to maintaining the trust and confidence of our membership and co-workers. In general, information obtained, retained or generated by the Credit Union is considered to be confidential. Any employee having access to financial, sensitive, and/or confidential information about the Credit Union, our members, or other third parties must use sound judgment and extreme discretion in matters of this nature. Credit Union information must not be discussed with family, friends, or in public surroundings. Public Statements It is important that Kinecta Federal Credit Union provide their members, as well as the public in large accurate and consistent information regarding our operations. Employees must not make public statements regarding issues or matters about which they are not authorized spokespersons. All media and other informational inquiries should be referred to the Senior Vice President of Marketing and Communications. Respect and Teamwork To ensure the success of all Credit Union team members and the continued growth and success of the Credit Union’s service to our members, we maintain high standards of 11 respect and teamwork. Kinecta will provide a respectful and team-oriented workplace. We require in return that you demonstrate respect for each other and practice good teamwork. Respect and teamwork will foster a fair, open, safe and secure work environment for you and your fellow team members and will ensure the success of our business operations. Workplace Harassment We are committed to providing you and all team members with a work environment free of harassment and discrimination. Actions or words that harass or intimidate fellow employees or members are expressly forbidden, and we will not tolerate them. This policy applies to all employees, regardless of status. 12 Frequently Asked Questions Business Trip Q: On a recent business trip, I stayed overnight with an old friend. Can I include the equivalent cost of a hotel room on my travel voucher since I took my friend and his wife out to dinner and paid for it myself? A: No. All vouchers, time cards and other Kinecta documents must always be completed in a correct, accurate and honest manner. It is never proper to knowingly create a false, misleading or erroneous Kinecta document or entry on an expense form. Conflict of Interest Q: Do the conflict of interest principles apply to relatives outside my household or to friends? A: Generally, the conflicts policy applies to members of your immediate family. However, if your relationship with a relative or friend is particularly close an you could lose your objectivity regarding Kinecta matters, than in certain circumstances, the conflict of interest policy would apply. If you have any doubts, you should disclose the relationship and discuss the matter with your supervisor. Q: A supplier/vendor offered me a five percent discount for my personal purchases. Is this okay? A: No, unless everyone at the Credit Union received such a discount, and then, the offer should be pre-approved by your department Senior Vice President before you agree to any such discount with the supplier or vendor. Q: I am involved with event planning. That means I frequently deal with hotels, restaurants and travel agents. One restaurant I often use for our meetings has offered me a free meal for my entire family. I would like to accept it. Am I doing anything wrong? A: Possibly. By accepting the free meal for non-business use, it may look as though the restaurant is attempting to sway your future business decisions. It is generally best to decline such offers. When in doubt, contact your Senior Vice President for pre-approval before accepting any such offers. 13 Q: My spouse has been offered a job with one of our suppliers. Is this a problem? A: Possibly. The answer depends in part upon whether you make decisions that affect our business relationship with that supplier. Contact your supervisor and fully explain the situation. E-mail and Internet Q: I have a number of friends who work at companies that provide them access to Internet e-mail. I find Internet e-mail a good way to stay in touch with these friends. May I send them e-mail from my office? A: This type of e-mail is discouraged. Providing you with a computer terminal and Internet access is an expense. Kinecta Federal Credit Union funds should properly be directed to Kinecta business and not to personal activities. Q: I received an e-mail chain letter. Can I send the letter to my friends at Kinecta? A: No. A Kinecta furnished computer and e-mail system should not be used to originate or forward non-business matters such as a chain letter. Intellectual Property Q: I would like to use one of the computer programs that we have at work on my home computer. Is that allowed? A: Probably not. Computer program licensing restrictions usually prohibit dual use. Check with your supervisor and the IT Department before you use any Kinecta furnished software program on your home computer. Political Activities Q: I am doing some volunteer work for the upcoming election for state attorney general. I would like to use the office fax machine to send out some press releases. Is this okay? A: No. By doing so, you would be using Kinecta resources for personal and political purpose. 14 Q: My manager’s spouse is running for city council. He has asked me to make a political contribution. What should I do? A: Contact the Human Resources Department or the Division Senior Vice President. Even if the request seems innocuous, the fact that this person is your manager means that the request could appear to be coercive or a conflict of interest. Workplace Practices Q: To whom should I direct questions or problems regarding ethical matters? A: In most cases, you should contact your supervisor. If that is not practical, you can contact the Corporate Human Resources Manager or call the 1-800 Ethics Hotline. Also available to you is the On-Line EthicsPoint System. Q: What should I do if I am faced with a situation where the correct ethical decision would mean that Kinecta loses money? A: Employees should always act ethically in every circumstances – even if it means that Kinecta will lose business or money. We value Kinecta’s long-term reputation. Employees should never compromise our long-term well being and reputation in order to meet short-term financial targets – even if asked to do so by your supervisor or manager. Q: I think my supervisor is discriminating against me. What should I do? A: Contact the Human Resources Department immediately. It is strictly against Kinecta’s policy to discriminate against employees for any reason. Q: I overheard a male manager tell a secretary that the dress she was wearing was “hot.” Is such a comment considered sexual harassment? A: Such a comment is inappropriate and may constitute sexual harassment. Comments concerning a co-worker’s attire or appearance that is in any way ambiguous or subject to misinterpretation should be avoided. 15