Adoption Resources of Wisconsin respects the value and dignity of every individual and serves our clients without regard to race, creed, color, ethnicity, national
origin, religion, sex, sexual orientation, gender orientation, gender expression, age, physical or
mental ability, veteran status, military obligations, or marital status.
This policy also applies to employment practice, internal promotions, training, opportunities
for advancement, terminations, outside vendors, members and customers, service
clients, use of contractors and consultants, and dealings with the general
public.
PRIVACY POLICY
We also respect your privacy and do
not share information about those individuals and families who come to us via
phone, email, Internet or in person with any other individual or organization
without express permission. Click here to see ARW’s formal policies on
non-discrimination and privacy.
CODE
OF BUSINESS CONDUCT
Adoption Resources of Wisconsin is
committed to conducting its organization with the highest ethical standards and
has adopted these principles and practices that govern our behavior.
INTRODUCTION
The ARW Code of Conduct (the "Code") is a statement of the basic
standards and principles of ARW for conducting its business in a legal and
ethical manner. The Code is reviewed annually for continued relevance and
is updated as appropriate.
The Code provides an accessible reference, and serves, like a
constitution, as the foundation for ARW ethics and compliance practices.
The Code applies to all of us as directors, employees and agents (for
example, contractors, brokers, suppliers) of Adoption Resources of
Wisconsin. Use of the term "we" throughout the Code is defined
to include all the parties and individuals mentioned above.
The policy of ARW is to prevent the occurrence of illegal or unethical
behavior, to detect and to halt any illegal or unethical behavior that may
occur as soon as reasonably possible after its discovery, to discipline
those who violate the Code, including individuals responsible for the
failure to exercise proper supervision and oversight to reasonably detect
and promptly report a violation by their subordinate employees, and to
promote honest, ethical conduct in our day-to-day business operations.
Discipline may, when appropriate, include dismissal.
COMPLIANCE
WITH THE LAW
ARW’s directors and employees are required to comply with all applicable
laws and regulations where we do business. Business demands or pressures
are not excuses for violating the local, state and federal law. Questions
relative to the legality of an action should be directed to your manager.
The United States anti-money laundering laws prohibit engaging in a
financial transaction if the person knows that the funds involved in the
transaction were derived from illegal activities. If any of us believes
that the other party to a business transaction is engaged in any illegal
activity or is using proceeds derived from an illegal activity, we should
consult with the Compliance Officer prior to proceeding.
ACCURACY
AND INTEGRITY OF COMPANY RECORDS
ARW requires honest and accurate recording and reporting of information in
order to be accountable to its clients, partners, donors and funders. This
information includes data such as quality, safety, client records, human
resources records, vouchers, bills, financial data, expense reports and
performance records. It is essential that all records are accurate and
complete.
All financial books, records and accounts must accurately reflect
transactions and events, and conform to required accounting principles.
False or misleading entries for either the amount and purpose of
transactions are prohibited. No undisclosed or unrecorded fund or asset
shall be established in any amount for any purpose. When a payment is
made, it can only be used for the purpose spelled out on the supporting
document. We may not allow transactions with a supplier, agent or customer
to be structured or recorded in a way that is not consistent with normal
business practice.
We will prepare and include full, fair, accurate, timely and
understandable disclosures in our reports and documents filed with or
submitted to appropriate regulatory authorities as well as in our other
public communications.
Employees are personally accountable for the proper use of any form of
organizational funds such as credit cards, tickets, cash and checks. Those
who authorize the use of funds must ensure that the organization has
received proper value in return. ARW may be obligated to notify
appropriate civil authorities should funds be used for any improper or
illegal purpose and will take appropriate disciplinary action as
appropriate.
AVOIDING
CONFLICTS OF INTEREST The best interests of ARW are
to be foremost in the minds of our directors, officers and employees as
they perform their duties. Business decisions and actions shall be based
on the best interests of ARW and shall not be motivated by personal
considerations or relationships.
Relationships with prospective or existing suppliers, contractors, clients
or competitors must not affect our independent and sound judgment to the
detriment of ARW. We shall deal with them and all other persons doing business
with our organization in a completely fair and objective manner without
favor or preference based upon personal gain.
PROTECTING
CONFIDENTIAL INFORMATION Protecting confidential
information about ARW’s clients, programs, activities, performance or
plans is of utmost importance in maintaining our good reputation. We will
protect and keep safe all confidential information by marking it
accordingly where appropriate, keeping it secured and prohibiting access
to it with the exception of those who have a need to know in order to do
their jobs. This specifically includes confidential information about
children and/or families received from other agencies.
Should there be any question as to whether certain information is
confidential, employees should consult their manager.
We shall promptly report to our manager any attempt by outsiders to obtain
confidential information or any unauthorized use or disclosure of
confidential information by others.
The use of confidential information for the personal gain of an employee
or anyone else is contrary to ARW policies and, in many cases unlawful.
If it is necessary to work at home with confidential information, in
either written or electronic form, permission must be obtained from your
manager and safeguards identified to maintain the confidentiality and
security of the information.
EQUAL OPPORTUNITY AND DIVERSITY We value and respect the
diversity of our employees, suppliers, clients and communities. We will
treat each other with respect and fairness at all times, just as we wish
to be treated ourselves. ARW is committed to providing equal opportunity
in all of our clients, employment and purchasing practices.
It is ARW’s policy to provide employment opportunities without regard to
race, religion, color, national origin, sex, age, ancestry, citizenship,
veteran status, marital status, sexual orientation, gender identification
or disability, or any other reason prohibited by law. Decisions as to
hiring, promotion and other aspects of the employment relationship shall
be based solely upon job-related qualifications.
We are committed to providing a workplace free of harassment or any other
behavior that diminishes a person's integrity and self esteem. We are
encouraged to speak out if we are approached with behavior that makes us
uncomfortable on the job, and to report harassment when it occurs.
Abusive, harassing or offensive conduct is unacceptable, whether verbal or
physical and will not be tolerated.
Sexual harassment includes but is not limited to, unwelcome sexual
advances, requests for sexual favors and other verbal or physical conduct
of a sexual nature in the work environment where:
Submission to the conduct is made explicitly or
implicitly a condition or term of employment;
Acceptance or rejection of the sexual behavior affects
an employment decision concerning the harassed person (e.g., pay,
benefits, advancement opportunities or threat of withholding thereof); or
The conduct or sexual behavior unreasonably interferes
with a person's work performance or creates an intimidating, hostile or
offensive work environment. Examples of improper conduct which constitute
a hostile or offensive work environment may include, but are not limited
to:
Verbal harassment: unwelcome offensive, lewd or
sexually suggestive language, sexually oriented jokes, e-mails, advances,
propositions, overt threats, conversations with sexual overtones, whether
written or spoken;
Physical harassment: unwelcome body contact through
touching; or
Visual harassment: unwelcome exposure to sexually
explicit gestures, pictures or objects (e.g., calendars, posters,
internet images, magazines, graffiti).
Other prohibited workplace
harassment includes the following behaviors, if based on race, gender,
religion, color, national origin, age, disability, veteran status, sexual
orientation, gender identification, marital status, ancestry, citizenship, or
any other reason prohibited by law:
Epithets, slurs, negative stereotyping or threatening,
intimidating or hostile acts that relate to such status; or
Written or graphic material that denigrates or shows
hostility or aversion to an individual because of such status and that is
placed on walls, bulletin boards, in electronic media or anywhere else in
the work environment, or is circulated in the work environment.
SAFETY AND HEALTH
The health and safety of all ARW employees is of utmost importance. We are
all responsible for maintaining a safe workplace by following safety and
health rules and practices. Our work processes and policies are designed
to minimize personal and organizational risk. We all must routinely review
and improve workplace conditions to ensure a safe and healthful workplace
and report unsafe working conditions to our manager immediately.
In order to protect the safety of all employees, each of us must report to
work free from the influence of any substance that could prevent us from
conducting work activities safely.
Threats of all kinds, violent behavior and physical intimidation are
prohibited and subject to discipline up to and including immediate
termination
RESPECT
FOR THE ENVIRONMENT
We respect the needs and concerns of the communities in which we live and
work. Sound waste management, recycling and energy conservation are legal,
ethical and business requirements.
REPORTING
DEFICIENCIES
Each of us has a right and responsibility to communicate concerns and ask
questions about issues that are not clear to us. ARW has an open door
policy that provides employees access to two-way, honest and respectful
communications. ARW is dedicated to fostering an environment that
encourages employees to voice concerns, express doubts, discuss problems,
ask questions, make observations and offer suggestions about workplace
issues. Each employee should feel comfortable approaching his or her
manager, any other manager, any human resources representative, corporate
leadership or any other organizational resource.
ARW is committed to providing quality programs and services that meet or
exceed the expectations of our clients and funders. Actions that put the
financial security of our Company at risk or, more importantly, threaten
the physical well-being of any person, should be reported immediately to
management. Deficiencies may involve service quality, safety, design, or
processes relative to equipment.
PROTECTING
ARW ASSETS
ARW trusts its employees with information about organizational activities
and with ARW property. We have the responsibility to protect these assets
entrusted to us from loss, damage, misuse or theft. ARW assets, such as
funds, keys, passwords, credit cards, rental cars, products or computers,
may only be used for business purposes and other purposes approved by
management. ARW assets may never be used for illegal or illicit purposes.
PROPER USE OF ELECTRONIC DATA
Electronic commerce, electronic mail and other internet-related systems
are intended to be used for organizational business. Additionally, all
information on ARW computer systems, including electronic mail, is the
property of ARW. Therefore, to ensure that computing resources are used in
accordance with policy, ARW may monitor your use of its electronic media
at any time and may inspect and disclose the contents of electronic
messages at any time.
Additionally, employees may not store organizational records or data on
their personal or home computers without permission of a senior manager.
Confidential information can be best secured on ARW computer systems and
is considered at risk on an employee's personal computer.
ARW is careful to ensure that all employees, clients, suppliers and the
public in general are treated with dignity and respect. We shall not use
our electronic media for any purposes which violate federal, state or
local laws, or ARW standards including the transmission of threatening,
obscene or harassing materials. Employees who engage in social networking,
whether on duty or on their personal time and who disparage the
organization, discuss confidential or protected information, use the
internet to access sites that contain offensive materials or who otherwise
violate these prohibitions, will be subject to discipline up to and
including discharge.
HOW
WE IMPLEMENT THE CODE
The Chief Operating Officer is responsible for the oversight and
implementation of the elements of our compliance program, including the
Code. The COO makes periodic reports on compliance matters to the Chief
Executive Officer and the Board of Directors.
Questions Regarding the Code
Each director and employee of ARW is expected to carry out his or her work
in accordance with the Code. The Code of Business Conduct is not
all-encompassing, and conduct and ethics situations may occur that are not
covered in the Code. When in doubt, please consult with your manager or
the COO.
Reporting Violations
Employees are expected to report violations of the code to their managers
or the COO. Any employee who suspects that a violation of the Code of
Business Conduct has occurred is obligated to report it immediately. All
employees shall be protected from retaliation for such reporting of actual
or possible violations of the Code.
Investigating Violations
All reported violations of the Code will be promptly reviewed and
investigated, as appropriate by the COO or an appropriate designee and
will be treated confidentially to the extent possible and consistent with
ARW’s legal obligations. We are expected to cooperate in the investigation
of an alleged violation of the Code. If the result of the investigation
indicates that corrective action is required, ARW will decide what steps
it should take including, when appropriate, legal proceedings, to rectify
the problem and avoid the likelihood of its recurrence.
Discipline for Violations
Disciplinary actions shall be taken as appropriate for:
Authorization or participation in actions that violate
the Code.
Failure to report a violation of the Code.
Refusal to cooperate in the investigation of a
violation of the Code.
Failure by a violator's supervisor(s) to detect and
report a violation of the Code, if such failure reflects inadequate
supervision or lack of oversight.
Retaliation against an individual for reporting a
violation of the Code.
Disciplinary action shall, when
appropriate, include dismissal. With respect to disciplinary action, principles
of fairness, proportionality, and consistency will apply. All disciplinary
actions shall be appropriately documented.
Personal Accountability
Directors and employees should be aware that these standards are greater than
those that may be required by local law. Adherence to these standards is a
condition of engagement with ARW. Violations are serious matters and could
result for employees in disciplinary action and for board members in removal.
Managers are responsible for distributing copies of the Code of Business
Conduct to employees and directors and for making them aware of the importance
and specific requirements of the policy.
ARW
CODE OF BUSINESS CONDUCT VERIFICATION AND DISCLOSURE STATEMENT
ARW requires that directors and employees working at ARW sign an annual
acknowledgement confirming that he or she has received and read the Code
and the Disclosure Policy, understands the expectations and is complying
with them. Additionally, both directors and employees are asked to
disclose potential conflicts of interest at the same time.
Further contractors and agents working for/or with ARW for an extended
period are required to read, sign and comply with this code.
