Code of Conduct

The foundation’s Code of Conduct establishes the framework for how we conduct ourselves and our operations. It sets out four principles that all trustees, officers, and staff of the foundation are expected to follow in carrying out the affairs of the foundation.

We comply with law.

We require ourselves to comply with the many laws that apply to us, including the Internal Revenue Code, the laws governing workplace behavior and the laws of the countries where we operate.

We comply with our policies.

We adopt and require ourselves to comply with policies designed to help us avoid conflicts of interest, protect our assets, report accurately our activities and financial position and carry out our philanthropic activities in furtherance of our mission and vision.

We report misconduct and concerns.

We pay attention to our conduct and speak up when we have concerns. We are required to report conduct or activities that violate the law or foundation policy and we are encouraged to report any concerns. We provide procedures for prompt investigation and prohibit retaliation against those who raise issues and hold us accountable.

We look to our mission, vision and values in making decisions.

We recognize that not every situation is covered by law or foundation policy. We expect ourselves always to be guided by our mission, vision and values of impact, integrity, disciplined approach and collaboration in making decisions, taking actions and interacting with others. In addition to law and foundation policy, which must be followed, we develop internal guidance that reflects our learning which may be drawn upon.

This Code of Conduct is intended to be implemented through various internal policies, including our Conflicts of Interest Policy, Open Door Policy, Records Retention Policy, policies for legal compliance and grantmaking and employment policies as defined in our Grantmaking Handbook and Employee Handbook.

Violations of this Code of Conduct will be subject to appropriate disciplinary and corrective action, up to and including dismissal from employment.