Please see below all of our current policies that were officially adopted and publically published after the GAAPP Board of Directors Strategic Meeting of 2023: Delete publicly (note spelling) as published implies this:
Purpose, scope, and responsibility
The Anti-bribery and corruption policy establishes principles that must govern our conduct in order to: a) conform to the U.S. Foreign Corrupt Practices Act (FCPA), the U.K. Bribery Act, and similar anti-corruption laws worldwide and b) more broadly, reinforce our intention and obligation to act honestly and ethically in all of our business dealings.
This policy applies to all employees of GAAPP, its consultants, students, volunteers and contractors representing or working on behalf of GAAPP.
Bribery and corruption are not only against our organization’s values; they are illegal and can expose the employee and the organization to fines and penalties, including imprisonment and reputational damage.
At GAAPP, bribery is never permitted. We will not seek to influence others, either directly or indirectly, by offering, paying, or receiving bribes or kickbacks or by any other means that is considered unethical, illegal, or harmful to our reputation of honesty and integrity. Employees and representatives of the organization are expected to decline any opportunity which would place our ethical principles and reputation at risk. While certain laws apply only to bribes to government officials (domestic and foreign), this policy also applies to non-government business partners.
What are bribery and corruption?
People want to work with organizations they can trust. GAAPP has built a strong reputation for being an ethical, trustworthy organization. Each of us is responsible for protecting that reputation by demonstrating honesty and integrity as we interact with customers, business partners, and each other.
Bribery is offering, giving, or receiving anything of value to induce a person to act or reward a person for having acted. This includes kickbacks—giving payment to someone who helps facilitate a transaction. It’s important to understand that a corrupt act has occurred even if:
- A bribe fails.
- A person authorizes or provides direction for a bribe, but no bribe is ultimately offered or paid.
- “Anything of value” includes, but is not limited to:
- Cash, cash equivalents (such as gift certificates/cards), stock, personal property, and assumption or forgiveness of a debt.
- Gifts, meals, entertainment, and travel—any corporate travel, gifts, entertainment, and meals must be proportionate to the occasion and comply with the gift & entertainment policy/standards applicable to your location.
Charitable contributions made to a charity at the direct request of a government official or private business partner could be considered an indirect bribe made to obtain or retain business or to secure other improper business advantages.
Job offers or internship awards to government officials (or their relatives) can present a risk of violating anti-bribery or anti-corruption laws and regulations. CEO or Human Resources lead (if present) must be consulted before making such offers.
Corruption is dishonest or fraudulent conduct, typically involving bribery.
REPORTING AND INVESTIGATING BRIBERY and CORRUPTION
If you believe that you have witnessed conduct that violates this policy, you should immediately report such conduct to a company manager or officer. Senior officers who receive ABAC Policy complaints learn of, or suspect violations of this policy should immediately report them to the designated contact for such complaints at your company (including the GAAPP Board).
All reports will be investigated promptly, thoroughly, objectively, and as confidentially as possible in a manner that provides all parties with due process and reaches reasonable conclusions based on the evidence collected. All GAAPP representatives are expected to cooperate fully in any investigation. Upon completion of the investigation, its conclusion will be communicated as soon as practicable. If the investigation substantiates that a policy violation has occurred, your company will take appropriate corrective action, up to and including termination of employment. Your company will also take appropriate action to address violation by contractors or consultants. If it is determined that prohibited conduct has occurred, the appropriate corrective action, up to and including termination of employment of the offending employee or contractors/consultants, will be taken by your company along with any additional steps necessary to prevent further violations of this policy.
Employees and/or Contractors who violate this policy will face disciplinary action that may result in termination of employment.
Members of the GAAPP will observe and promote the highest standards of ethical conduct, respecting and honoring the views of others in the performance of their duties. They accept this Code as a minimum guideline and shall:
- Faithfully abide by the policies of the organization and its funding partners (where applicable).
- Exercise care, good faith and due diligence in organizational affairs.
- Fully disclose, at the earliest opportunity, information or fact that would have significance in board or leadership decision-making.
- Exercise prudent fiscal management and fiduciary accountability.
- Fully disclose, at the earliest opportunity, information that may result in a perceived or actual conflict of interest.
- Exercise the powers invested for the good of all members of the organization rather than for his or her personal benefit, or that of the nonprofit they represent.
- Ensure the right of all constituents to appropriate and effective services without discrimination.
- Ensure the organization’s board, staff, and volunteer make-up involves no discrimination in respect to gender, sexual orientation, national origin, race, religion, age, political affiliation or disability, in accordance with all applicable legal and regulatory requirements.
- Respect the confidentiality of sensitive information known due to GAAPP service.
- Decline to speak officially on behalf of the organization unless authorized to do so.
Collaboration and Cooperation
- Maintain a level of courtesy, respect, and objectivity in all of the organizations’ activities, respecting the views of fellow GAAPP members, staff, and the organization’s community.
- Listen carefully to the diversity of opinions expressed or acted upon by GAAPP, committees and membership, and formally register dissent as appropriate in a respectful manner.
- Honor decisions officially determined by majority vote of the Board.
- Promote collaboration, cooperation, and partnership in the community.
- Strive to uphold those practices and assist other members of the organization in upholding the highest standards of conduct
Board Interaction with Staff and Contractors
- Remember that it is the chief executive, not the Board, who is responsible for delineating staff responsibilities, assigning tasks, and assessing performance.
Direct any requests for staff tasks and assignments through the chief executive or his or her designee.
I. Purpose and Overview
As a nonprofit, charitable organization, GAAPP is accountable to government agencies and public members for the responsible and proper use of its resources. Directors, officers, and employees have a duty to act in the GAAPP’s best interests and may not use their positions for their own financial or personal benefit.
Conflicts of interest must be taken very seriously since they can damage GAAPP’s reputation and expose both the GAAPP and affiliated individuals to legal liability if not handled appropriately. Even the appearance of a conflict of interest should be avoided, as it could undermine public support for the GAAPP.
To whom does the policy apply?
This policy applies to all Board directors, officers, and key persons representing the GAAPP (“you”)
Definition of “interest”: A person shall be deemed interested if a person has a direct or indirect (through business, investment, or family*):
- Real or potential ownership or investment interest (including stock ownership) in any entity with which the organization has or is negotiating a transaction or arrangement.
- Real or potential compensation arrangement (including direct or indirect remuneration as well as gifts or favors that are substantial in nature) with the organization or with any entity or individual with which the organization has or is negotiating a transaction or arrangement.
- A position as an officer or board member, employee (current or former) of any entity with which the organization has or is negotiating a transaction or arrangement.
- Membership on a scientific advisory panel or other standing scientific/medical committees of another organization.
- Grants or research support from a company/organization whose products or services are directly related to the subject matter in a manuscript or presentation.
*Family is any person who is related by blood or marriage.
GAAPP Staff, Contractors and Board of directors sign this policy annually. If you wish to receive a copy of the COI of any of our staff or Board, don’t hesitate to get in touch with us at firstname.lastname@example.org
For any questions or inquiries, please get in touch with us at email@example.com.