A Matter of Trust: Boys & Girls Clubs of America Code of Ethics for Employees

Updated January 2, 2020

The purpose of “A Matter of Trust: Our Code of Ethics for Employees” is to help ensure that all employees of Boys & Girls Clubs of America (BGCA) and its subsidiaries adhere to proper ethical standards, abide by the law, and preserve the mission, purpose, integrity, reputation, and professional and business relationships of BGCA.

Boys & Girls Clubs of America expects all employees to conduct themselves in a manner that exemplifies the highest standards of ethics and propriety in any endeavor or activity that could impact or reflect upon the mission, purpose, integrity, reputation, and professional and business relationships of BGCA.  

Recognizing that it is not possible to address all ways in which ethical issues may arise, the following principles are intended as a guide in making sound judgments and decisions on behalf of BGCA and its mission, not as a comprehensive list of potential concerns.

Pledge of Personal and Professional Conduct

• Integrity -- We are authentic, honest, and transparent; we strive to do the right thing every day, every time.


• Collaboration -- We work efficiently within and across teams; with engaged and empowered people to accomplish our goals; we celebrate successes together.


• Accountability -- We do what we say and hold each other to the highest standards; we are impeccable stewards of all our resources. 


• Respect -- We honor diversity and inclusion, treat others with respect, and express gratitude; we embrace alternative ways of thinking.


• Excellence -- We excel in service delivery, rigorously measure impact, and work to continuously improve ourselves and our organization; we are innovative.

Professional Practices

While the above values outline general principles guiding our ethical conduct, the following points illustrate important applications that are relevant to our every day work.  The points below are not intended to be all-inclusive and the examples given at the end of each section are meant to demonstrate some but certainly not all improper conduct.  Employees are expected to utilize good judgment in maintaining the highest standards of ethics.  

I. Conflicts of Interest:

• I will not place my personal interest in conflict with the mission, purpose, vision, or interests of BGCA, and will avoid any conduct that may impair my judgment with respect to BGCA.
• I will not take any actions or make any promises related to a third party that conflict with the mission, purpose, vision, or interests of BGCA.
• I will not exploit or personally benefit from any donor or funding relationship, volunteer relationship, vendor relationship or organizational committee relationship.  
• I will not use any funding or promise of funding received by any source to improperly influence or coerce any constituencies of BGCA or any third party.  
• I will not use my position with BGCA to obtain special advantage or gain to myself, any person related to me or any other related party. 
• I will not enter into business transactions on behalf of BGCA that are not in the best interests of BGCA and its mission, and that, in any way, conflict with, compromise, or detract from BGCA’s mission, purpose, or interests.
• I will not, directly or indirectly, benefit improperly from my position or from any sale, purchase, contract or other activity of the organization or cause a benefit to any person related to me or any other related party. 
• I will not make any payment or provide anything of value to any public official in exchange for or because of any official act performed or to be performed (that is, provide any bribe or unlawful gratuity to anyone).
• I will not ask for, accept from or give to any past, current or potential supplier, advisor, vendors, speaker, customer, competitor, or donor any payment, service, gift, or favor other than gifts of a value less than $100 or that amount allowed by law unless explicitly approved by the President. All gifts; offered, accepted or given; must be reported to the Ethics Officers via electronic mail.  Failure to do so could result in disciplinary action.  
• I will not unduly influence any personnel decisions of Member Organizations, State Alliances or any other interested third parties in the performance of my regular duties for BGCA.
• I will avoid any outside business relationships with donors, vendor other businesses or competitors if that relationship creates a conflict of interest by influencing decisions made by me in the performance of my regular duties for BGCA or benefiting any person related to me or raises a reasonable inference or appearance of influencing decisions made by me.  I will disclose any and all such relationships prior to entering into that outside relationship.  
• I will ensure that travel, entertainment and related expenses are incurred on a basis consistent with the mission of BGCA and not for personal gain or interests or benefit any other related party. 
• I will reveal to the Ethics Officers, described below, any perceived, potential or actual conflicts of interest.

Examples of improper conduct:  1)  Contracting with a vendor in which you have a financial stake; 2) Accepting a paid vacation from a vendor or donor;  3)  Contracting with a vendor that is owned by one of your relatives; or 4) Influencing a Club to hire a friend or a relative. 


II. Assets, Financial Reporting and Transactions:

• I will do my part to ensure that BGCA complies with prescribed accounting polices and procedures at all times.
• I will do my part to ensure that organizational assets and transactions are handled with the strictest integrity, and that each transaction is executed in accordance with applicable procedures, authorization and documentation. 
• I will not make false or misleading entries in any books, records or reports, invoices, timesheets, expense reports or aid others in doing so.
• I will not use, directly or indirectly, the organizational name or logo, organizational funds, property, computer connectivity, equipment, assets, copyrighted material or other organizational resources for any unlawful, unethical, or inappropriate purpose.

Examples of improper conduct:  1) Forging a signature on a check request; 2) Not adhering to IT Security policies; or 3) Excessive personal Internet use during working hours. 


III. Fundraising:

• I will be truthful in communicating with others, including donors and other contributors and will seek to provide factually correct, current and accurate information. 
• If I determine that I have provided others with factually inaccurate information of a significant, relevant, and material nature, I will promptly provide the factually accurate information to the interested person. 
• I will enthusiastically promote genuine voluntary giving and prevent or inhibit any solicitations made under duress or coercion.
• I will be accurate and truthful in our fundraising activities.
• I will respect the informed choices of our donors by fairly and truthfully reporting our fundraising costs and overhead.
• I will be clear about how donated resources will be utilized.
• I will honor our promises by using donated resources in the manner in which they were intended or transparently informing donors of any important alterations in the planned use of the funds. 

Examples of improper conduct:  1) Exaggerating a contribution by one donor to influence another donor; 2) Using donated funds to pay for expenses not related to the grant without donor’s permission; or 3) Misrepresenting overhead costs to a donor. 


IV. Professional Conduct:

• I will treat fellow employees, volunteers, donors, vendors, the public we serve, and other stakeholders with fairness, honesty and respect.  This includes refraining from gender, racial or other bias, or sexual or other harassment.  
• I will conduct myself in a professional manner at any BGCA related function in which I might be considered a representative of BGCA.  This includes avoidance of excessive alcohol consumption, inappropriate conversations and promiscuous actions. 
• I will always uphold the law while working at BGCA.  This includes, for example, obeying all state and local laws governing nonprofits.  I understand that illegal drug use, fraud, theft, embezzlement, price-fixing, bid-rigging, or any other illicit activities are grounds for immediate termination and possible prosecution by public authorities. 
• I will focus on BGCA duties and responsibilities during working hours, keeping personal time to a minimum and will not engage in business unrelated to BGCA. 
• I will not abuse my computer usage, including but not limited to improper internet activities; i.e. pornography, online dating or excessive non work related communications or browsing. 
• I will advocate within BGCA, adherence to all applicable laws and regulations.
• I will bring credit to BGCA by my public and online demeanor.
• I will inspire others through my own sense of dedication and high purpose.
• I will avoid even the appearance of any criminal offense or professional misconduct.
• I will encourage colleagues to embrace and practice these ethical principles and standards of professional practice. 
• I will not exceed my limits of authority. 
• I will be alert for and report any conduct described above or any other conduct unbecoming to BGCA by other employees.  

Examples of improper conduct:  1) Witnessing sexual harassment but not reporting it; 2) Becoming intoxicated at a BGC event; 3) Disparaging or embarrassing the organization in anyway; or 4) Signing a contract for which you are not authorized.  


V. Confidential and Proprietary Information:

• I will not release business information that has not been made public to private individuals, organizations, or government bodies unless demanded by legal process.
• I will not request confidential or proprietary information from another organization for use in my work with Boys & Girls Clubs of America. 
• I will not use confidential information obtained in the course of my employment or affiliation with BGCA for the purpose of advancing any private interest or otherwise for personal gain.  
• I will refer all references or requests for information about present or former employees of the organization to the Human Resources department for handling.
• I will refer requests for confidential or sensitive information to the Ethics Officers. 
• I will refer requests for information from the media to the Vice President of Marketing & Communications. 
• I will comply with the organization’s document retention policy. 
• I will not unlawfully or improperly copy or release any material that has copyright or trademark protection. 

Examples of improper conduct:  1) Forwarding a confidential internal email to a third party related to BGCA business; or 2) Making an unauthorized statement to the press related to the organization. 


VI. Political Activities:

• I will not use any organizational financial resources to improperly influence any political figure or candidate.
• I will not make - or create the appearance of making - any contributions to any candidate for public office or political committee on behalf of BGCA. I will not use – or create the appearance of using - any organizational financial resources to endorse or oppose a candidate for public office.
• I will clearly communicate that I am not acting on behalf of the organization, if identified as an employee of BGCA, while engaging in political activities in an individual capacity.
• I will engage in personal political activities on my own time and at my own expense.

Examples of improper conduct:  1) Hosting a BGCA event at which a political candidate is endorsed; 2) Conducting a BGCA fundraising event for a politician; or 3) Wearing a BGCA shirt to a political fundraising event. 


VII. Government Relations:

• I will be truthful in communicating with others, including public officials and with other interested persons and will seek to provide factually correct, current and accurate information. 
• If I determine that I have provided others with factually inaccurate information of a significant, relevant, and material nature, I shall promptly provide the factually accurate information to the interested person.
• If applicable to my job, I will be familiar with laws, regulations and rules applicable to the government relations profession and its relationship to lobbying and will not engage in any violation of such laws, regulations and rules.  I will keep abreast of any change in the law and recognize the impact of such laws or litigation involving important public policy.  
• I will be familiar with and strictly adhere to all laws, regulations and rules governing the receipt of gratuities, bribes, fees or any other benefit by me or any person related to me. 
• I will not make any payment or provide anything of value to any public official in exchange for or because of any official act performed or to be performed (that is, provide any bribe or unlawful gratuity to anyone).
• I will not ask for, accept from or give to any public official any payment, service, gift, or favor other than that amount allowed by law. 
• I will not cause a public official or other interested person to violate any law, regulation or rule applicable to such public official or interested person.
• I will value the privacy, freedom of choice and interests of all those affected by my actions.
• If applicable to my job, I will monitor the activity of lobbyists representing BGCA to ensure compliance with the Code of Ethics. 

Examples of improper conduct:  1) Recommending or advancing funding as a result of a personal relationship; 2) Hiring a lobbyist who does not subscribe to the BGCA Code of Ethics for Lobbyists. 

Reporting and Investigation

Condition of Employment:

• Upon receipt of the Code of Ethics, each employee will agree in writing to comply with the Code of Ethics (certificate on page 8).
• Compliance with the Code of Ethics is a condition of employment for all employees.

Whistleblower Compliance

• This Code of Ethics will adhere to Whistleblowing policy requirements.  It is intended to encourage and enable employees and others to raise concerns internally so that Boys & Girls Clubs of America can address and correct inappropriate conduct and actions. It is the responsibility of employees to report concerns about violations of this Code of Ethics or suspected violations of law or regulations that govern BGCA operations.  Such reports can be anonymous but if not, the identity of the reporting employee will be kept confidential unless it must be revealed in order to fully enforce this Code of Ethics or comply with legal obligations.


• It is contrary to the Whistleblowing policy and the values of Boys & Girls Clubs of America for anyone to retaliate against any employee who in good faith reports an ethics violation, or a suspected violation of law.  No employee who in good faith reports a violation of the Code shall suffer harassment, retaliation or adverse employment consequence.  Any employee who retaliates against someone who has reported a violation in good faith is subject to discipline up to and including termination of employment.

Questions and Reporting:

• Any questions regarding the Code of Ethics, its’ interpretation or application will be directed to the General Counsel.
• All gifts offered, accepted or given will be reported to the Ethics Officers via electronic mail.
• Consensual relationships with co-workers should be disclosed pursuant to the BGCA Employee Handbook guidelines. 
• If an employee knows of a violation of the Code of Ethics, he/she will immediately report it to one of the Ethics Officers in person and should not engage in any fact-finding related to the violation. 
• In the alternative, an employee can utilize the confidential Ethics Hotline to report a violation of the Code of Ethics via the telephone or the Internet.  That number is  1-866-295-3701 and the reporting link is www.ethicspoint.com.    
• When reviewing the Code of Ethics, ask yourself the following questions:  1) Have I ever conducted myself in that manner?  2) Have I ever witnessed others conducting themselves in that manner?  3) Is there anything else that I am doing or have witnessed that makes me uncomfortable from an ethical standpoint?
• If an employee is concerned that he/she may not be in compliance with the Code of Ethics, he/she will complete the appropriate Disclosure Statement and the Ethics Officers will provide a   written response. 
• Any supervisor or department head receiving such a report must immediately advise one of the organization’s Ethics Officers.
• BGCA’s Ethics Officers will promptly investigate all alleged Code of Ethics violations of BGCA employees and will take whatever corrective action is required.  Employees are expected to cooperate in the investigation.

Disciplinary Action for Violations:
Disciplinary action may be taken for the following violations, and may include dismissal, when appropriate.

• Authorizing or directly participating in actions that violate the Code of Ethics.
• Not reporting offered, accepted or given gifts.
• Concealing a violation of the Code of Ethics.
• Failing to report an employees’ violation of the Code of Ethics.
• Refusing to cooperate in the investigation of a violation of the Code of Ethics;
• Retaliating, directly or indirectly, against an individual for reporting a violation of the Code of Ethics.
• Other violations of law not outlined in this Code of Ethics but that may impact an employee’s job performance. 

Alliance Board members

• If you are a member of an Alliance board, please note that the above Code of Ethics requirements apply to your work on the Alliance board.  Any questions or reporting can go to the above listed Ethics officers or the Board Chair of the Alliance.