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| We respect the privacy of our donors and do NOT sell or trade our donor list. |
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Conflict of Interest Policy |
Employees and/or Board Members have an obligation to conduct business within
guidelines that avoid actual or potential conflicts of interest. This policy establishes only
the framework within which The Foundation wishes the business to operate. The
purpose of these guidelines is to provide general direction so that employees or Board
Members can seek further clarification on issues related to the subject of acceptable
standards of operation. Contact Human Resources for more information or questions
about conflicts of interest.
An actual or potential conflict of interest occurs when an employee or Board Member is
in a position to influence a decision that may result in a personal gain for that employee,
Board Member or for a relative as a result of The Foundation’s business dealings. For
the purposes of this policy, a relative is any person who is related by blood or marriage,
or whose relationship with the employee is similar to that of persons who are related
by blood or marriage.
No “presumption of guilt” is created by the mere existence of a relationship with
outside firms. However, if employees and/or board members have any influence on
transactions involving purchases, contracts, or leases, it is imperative that they disclose,
as soon as possible, the existence of any actual or potential conflict of interest so that
safeguards can be established to protect all parties.
Personal gain may result not only in cases where an employee, Board Member or
relative has a significant ownership in a firm with which The Foundation does business,
but also when an employee, Board Member, or relative receives any kickback, bribe,
substantial gift, or special consideration as a result of any transaction or business
dealings involving The Foundation. |
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General
The International Community Foundation (“the Foundation”) Code of Ethics and
Conduct (“Code”) requires all employees to observe the highest standard of business
and personal ethics in the conduct of their duties and responsibilities. As representatives
of the Foundation, employees must practice honesty and integrity in fulfilling
responsibilities and comply with all applicable laws and regulations. |
Reporting Responsibility
It is the responsibility of all employees to comply with the Code and to report violations
or suspected violations in accordance with this Whistleblower Policy. |
No Retaliation
No employee who in good faith reports a violation of the Code shall suffer harassment
or retaliation, nor will he or she suffer an adverse employment consequence. An
employee who retaliates against someone who has reported a violation in good faith is
subject to discipline up to and including termination of employment. This Whistleblower
Policy is intended to encourage and enable employees and others to raise serious
concerns within the Foundation prior to seeking resolution outside the Foundation. |
Reporting Violations
The Code addresses the Foundation’s open door policy and suggests that employees
share their questions, concerns, suggestions or complaints with someone who can
address them properly. In most cases, an employee’s supervisor is in the best position
to address an area of concern. However, if an employee is not comfortable speaking
with his or her supervisor, or is not satisfied with the supervisor’s response, the
employee is encouraged to speak with anyone in management or the Board of
Governors that he or she is comfortable in approaching. Supervisors and managers are
required to report suspected violations of the Code to the Foundation’s Outside Legal
Counsel, who acts in a “Compliance Officer” capacity for the foundation. The
“Compliance Officer” has specific and exclusive responsibility to investigate all reported
violations. For suspected fraud, or if an employee is either not satisfied or
uncomfortable even after following the Foundation’s open door policy, the employee
should contact the Foundation’s “Compliance Officer” directly. |
Compliance Officer
The Foundation’s Compliance Officer, currently the Outside Legal Counsel, is
responsible for investigating and resolving all reported complaints and allegations
concerning violations of the Code and, at his or her discretion, for advising the
President/CEO and/or the Executive Committee. |
Accounting and Auditing Matters
The Executive Committee shall delegate action relating to concerns and complaints
regarding the Foundation’s accounting practices, internal controls and auditing to the
Audit Committee. The Compliance Officer shall work with the Audit Committee until
the matter is resolved. |
Acting in Good Faith
Anyone filing a complaint concerning a violation or suspected violation of the Code
must be acting in good faith and have reasonable grounds for believing that the
information disclosed indicates a violation of the Code. Any allegations that prove to be
false or unsubstantiated, and which prove to have been made maliciously or knowingly,
will be viewed as a serious offense requiring disciplinary action. |
Confidentiality
Violations or suspected violations may be submitted on a confidential basis by the
complainant or may be submitted anonymously. Reports of violations or suspected
violations will be kept confidential to the extent possible, consistent with the need to
conduct an adequate investigation. |
Handling of Reported Violations
The Compliance Officer will notify the sender and acknowledge receipt of the reported
violation or suspected violation within five business days. All reports will be promptly
investigated and appropriate corrective action will be taken if warranted by the
investigation. |
Current Outside Legal Counsel
Michelle Graham
General Counsel
Luce Forward
11988 El Camino Real, Suite 200
San Diego, Ca. 92130-2594
Tel: (858) 720-6300
mgraham@luce.com |
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Policy for Funding Religious Institutions |
| Organizations with religious affiliations will be considered for grants if their programs seek to address the needs of the wider community without regard to religious beliefs. Similarly, individuals applying for scholarship and fellowship programs and wishing to pursue work with organizations having religious affiliations may be considered so long as the nature of the work is of a non- religious nature (e.g. support to day care facilities, orphanages, retirement homes, community development, etc.). Recognizing the importance of religion in culture, individual studies of religions, including comparative religious studies, may be considered for funding except in those instances where the applicant has the intent to proselytize. |
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