CODE OF ETHICS

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CODE OF ETHICS
LOCAL INITIATIVES SUPPORT CORPORATION
Overview
This Code of Ethics of Local Initiatives Support Corporation (“LISC”), is intended to
encapsulate the key ethical principles that govern the activities of LISC, and the conduct
of LISC’s Directors and staff in carrying out those activities. This Code is intended to
complement the Conflict of Interest policies applicable to the Board of Directors. It also
complements, but does not replace, the LISC Personnel Policies, Practices and
Procedures (the “LISC Personnel Guide”) for its employees, including, but not limited to,
the Conflict of Interest provisions of the LISC Personnel Guide.
As LISC enters its 25th year of operations, the Board and management have recognized
the value of documenting and communicating within LISC our core ethical standards.
The following Code of Ethics is intended to provide guidance in those areas. The basic
message of these policies is that all of us at LISC are expected to conduct ourselves
with integrity and good faith, in furtherance of LISC’s charitable mission and with
respect to its tax-exempt status.
Above all else, LISC depends on its good reputation in order to establish and solidify its
relationships with the CDC community, donors, governmental entities, and others with
whom we do business. Carrying out our work with integrity and professionalism is a
crucial ingredient in protecting our reputation and strengthening our ability to continue
doing our work.
This Code addresses certain areas but cannot, as a practical matter, discuss every
situation in which ethical considerations may arise. In considering how to conduct
ourselves while at LISC, or representing LISC, the basic message is that integrity is one
of LISC’s core values. The formulation and distribution of this Code of Ethics is
intended to help us communicate that message.
These principles apply to all Directors and employees of LISC.
I.
Personal and Professional Integrity
All LISC staff and Board members shall act with honesty, integrity and openness in all
their dealings as LISC representatives. LISC promotes a working environment that
values respect, fairness and integrity.
II.
Mission
LISC’s mission is to help “resident-led, community-based development organizations
transform distressed communities and neighborhoods into healthy ones-- good places
to live, do business, work and raise families. By providing capital, technical expertise,
training and information, LISC supports the development of local leadership and the
creation of affordable housing, commercial, industrial and community facilities,
businesses and jobs. We help neighbors build communities.” This mission is at the core
of why LISC was formed and how it does its business today. In carrying out their
responsibilities, LISC Directors and staff should be cognizant of LISC’s mission.
III.
Conflicts of Interest
All Directors and employees of LISC should be scrupulous in avoiding a conflict of
interest with regard to LISC interests, and should also be sensitive to those situations in
which there could be an appearance of a conflict of interest. Although more specific
guidance is available in the Board of Directors Conflict of Interest Policy, and in the
Conflict of Interest section of the LISC Personnel Guide, the following general concepts
should help all of us be more aware of this area:
A “conflict of interest” exists whenever an individual’s private interest interferes or
conflicts in any way with the interest of LISC. A conflict situation can arise when an
employee takes actions or has interests that may make it difficult to perform his or her
LISC work objectively and effectively or, in the case of a Director, to serve objectively
and effectively on the LISC Board. Conflicts of interest may also arise when an
employee, or members of his or her family, receives improper personal benefits as a
result of his/her position at LISC, whether received from LISC or a third party.
If a Director or an employee has any questions about whether a particular situation may
present a conflict of interest, he or she should contact the General Counsel or the
Deputy General Counsel of LISC to discuss the situation.
IV.
Confidentiality
Directors and employees of LISC must maintain the confidentiality of information
entrusted to them in their official capacity at LISC, except when the President and CEO
of LISC otherwise authorizes its disclosure, or as otherwise required by laws,
regulations or legal proceedings. A violation of this trust is a serious matter. Whenever
feasible, Directors and employees should consult the General Counsel if they believe
they have a question as to whether information they wish to disclose is of a confidential
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nature, or if they have a legal obligation to disclose confidential information. As a
general concept, confidential information includes all non-public information that might
be of use to competitors or the disclosure of which might otherwise be harmful to LISC
or its customers.
V.
Legal Compliance
All employees of LISC should respect and comply with all of the laws, rules and
regulations of the United States, states, counties, cities and jurisdictions in which LISC
conducts its business and the laws, rules, and regulations which are applicable to LISC.
No employee shall knowingly participate in any transaction or activity which they have
reasonable cause to believe may violate, or may aid others to violate any such law, rule
or regulation. This Code of Ethics does not summarize all laws, rules and regulations
and policies applicable to LISC and it employees. Please consult the Vice President for
Human Resources or the General Counsel for questions on specific laws, rules and
regulations.
VI.
Governance

The Board is responsible for setting the mission and strategic direction of the
organization and oversight of the finances, operations, and policies of the
organization.

The Board ensures that its members have the requisite skills and experience to
carry out their duties and that all members understand and fulfill their governance
duties acting for the benefit of the organization and its public purpose.

LISC has adopted Conflict of Interest policies for its Board and its staff. Those
policies are attached to this Code of Ethics. The Board Conflict of Interest policy is
intended to insure appropriate disclosure of financial relationships between any
organization of which a LISC Board member is an employee or director, and sets
forth the procedures to be following in the event of these or any other conflicts of
interest or potential conflicts of interest.

The Board is responsible for the hiring, firing, and regular review of the performance
of the Chief Executive Officer, and ensures that the compensation of the Chief
Executive Officer, and other members of senior management, is reasonable, and
appropriate. The Board also reviews and approves the compensation of other LISC
officers, and the compensation policies for the organization as a whole, in the
context of the compensation structure approved by the Board.

The Chief Executive Officer and appropriate staff shall provide the Board and its
Committees with timely and comprehensive information so that the Board and the
respective Committees can effectively carry out their responsibilities.
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VII.
Responsible Stewardship
LISC manages its funds, and those it receives from donors and lenders, responsibly
and prudently. Its management of such funds takes into account the following
considerations:

Spending a reasonable percentage of its annual budget on programs in pursuance
of its mission;

Spending an adequate amount on administrative expenses to ensure effective
accounting systems, internal controls, competent staff, and other expenditures
critical to professional management; and

Ensuring that all spending practices and policies are fair, reasonable and
appropriate to fulfill the mission of the organization.
All financial reports shall be factually accurate and complete in all material respects. All
financial reports and records, including timesheets, expense reports, income
statements, etc. must be accurate, timely and prepared in accordance with the law. All
employees are expected to follow the required procedures, within the appropriate time
periods, to allow for the maintenance of accurate and complete financial records and
the timely production of accurate and complete financial reports.
VIII.
Openness and Disclosure
LISC shall provide comprehensive and timely information to the public and stakeholders
as appropriate. Basic informational data about the organization, such as the Form 990
and audited financial statements are available to the public as required by law. All
solicitation materials shall accurately represent the organization’s policies and practices
and respect the dignity of program beneficiaries. All financial, organizational, and
program reports should be accurate in all material respects.
IX.
Reporting Illegal or Unethical Behavior
Reporting Illegal or Unethical Behavior
Employees and Directors who suspect or know of violations of this Code or illegal or
unethical business or workplace conduct by employees or Directors have an obligation
to contact the appropriate supervisor, Vice President for Human Resources, General
Counsel, or President and CEO, as appropriate to the circumstance.
Accounting Complaints
The policy of LISC is to comply with all applicable financial reporting and accounting
regulations. If any Director or employee of LISC has unresolved concerns or complaints
regarding questionable accounting or auditing matters of the Company, then he or she
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is encouraged to submit those concerns or complaints to the CFO and / or Chairman of
LISC’s Audit Committee, as appropriate. Subject to its legal duties, the Audit
Committee and the Board will treat such submissions confidentially.
Non-Retaliation
LISC prohibits retaliation of any kind against individuals who have made good faith
reports or complaints of violations of this Code or other known or suspected illegal or
unethical conduct.
Employees are encouraged to talk to supervisors or other appropriate personnel about
observed illegal or unethical behavior and, when in doubt, about the best course of
action in a particular situation. Employees should report violations of this Code of Ethics
in accordance with the Complaint Procedure outlined in this code.
Discipline for Violation by Employee
Failure to comply with the Code will subject an employee, no matter how senior, to
discipline that may include counseling, suspension or immediate termination.
Disciplinary measures will depend on the circumstances of the violation and will be
applied after consultation with the Vice President for Human Resources, General
Counsel and President and CEO. Consideration will be given to whether or not a
violation is intentional, as well as to the level of good faith shown by an employee in
reporting the violation or in cooperating with any resulting investigation or corrective
action.
X.
Program Evaluation
The organization regularly reviews program effectiveness and has mechanisms
designed to incorporate lessons learned into future programs. The organization is
committed to improving program and organizational effectiveness and develops
mechanisms to promote learning from its activities and the field. The organization is
responsive to changes in its field of activity and is responsive to the needs of its
constituencies.
XI.
Inclusiveness and Diversity
LISC shall be fair and inclusive in its hiring and promotion policies and practices.
LISC’s diversity policy is set forth more fully in the LISC Personnel Guide. LISC strives
for broad representation on its own board and staff, recognizing that without such
diversity, the corporation's ability to achieve excellence in its programs would be
seriously constrained. LISC is aware diversity benefits everyone and is not only
compatible with, but actually promotes, community development success.
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XII.
Fundraising
LISC is truthful in its solicitation materials. LISC respects the privacy concerns of
individual donors and expend funds consistent with donor intent.
In raising funds from the public, LISC respects the right of donors:

To be informed of our mission, the way resources will be used and our capacity to
use donations effectively for their intended purposes;

To be informed of the identity of those serving on LISC’s governing board and to
expect the board to exercise prudent judgment in its stewardship responsibilities;

To have access to LISC’s most recent financial reports;

To receive appropriate acknowledgment and recognition;

To be assured that information about their donations is handled with respect and
with confidentiality to the extent required by the donor or provided by law; and

To feel free to ask questions when making a donation and to receive prompt, truthful
and forthright answers.
XIII.
Record Retention
Records should always be retained or destroyed according to applicable requirements.
If any employee is aware of an imminent or ongoing investigation, audit, or examination
initiated by LISC, by our auditors or attorneys, or by any governmental agency, that
employee should retain all documents (including computer records) in his/her custody or
control relating to the matter under review. The destruction or falsification of a
document in order to impede a governmental investigation, audit or examination may
lead to prosecution for obstruction of justice. If an employee is not sure if a document
should be retained, or if that employee has any questions on the retention of records,
please contact your supervisor or LISC’s General Counsel.
XIV.
General Guidelines in Providing Grants, Loans or other Financial or
Technical Assistance
As a provider of financial and technical assistance, LISC has a particular responsibility
to carry out these activities in an ethical manner. This includes the following:

Having constructive relations with organizations seeking LISC assistance, based on
mutual respect and shared goals;

Communicating clearly and on a timely basis with potential recipients of LISC
assistance;
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
Treating fairly organizations applying for, and organizations receiving, assistance
from LISC;

Respecting the expertise of organizations with which it does business;

Seeking to understand and respect the organizational capacity and needs of
organizations seeking assistance from LISC; and

Respecting the missions of the organizations seeking its assistance.
XV.
Amendment and Modification
This Code may be amended or modified at any time and without prior notice by LISC
within its discretion.
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