Our Standards of

Professional Conduct
 Leadership Message
CONTENTS
Dear Colleagues:

I am pleased to share with you

Leadership Message . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
The IRC Way: Our Standards for Professional Conduct.
Our Values. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

Guiding Principles. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 The IRC Way has long stood as our Code of Conduct, describing our four core values of

Our Shared Responsibilities in Upholding This Code. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 Integrity, Service, Accountability and Equality and the undertakings that flow from them.
These values and undertakings unite IRC staff around the world and keep our programs firmly di-
Our Commitments to Our Colleagues. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
rected toward the well-being of our clients while meeting the expectations of our donors as respon-
Our Commitments to Our Clients. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 sible stewards of their resources.
Our Commitments to Our Donors. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
The aim of this document is to ensure that we carry out our work following the ethical and moral
Our Commitments to Our Suppliers. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
principles that support our humanitarian calling. Policies alone are not enough if they cannot be
Our Commitments to Our Partners. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 translated into action. That’s why our Code has been expanded to include practical steps you can take
Our Commitments to Our Organization. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 to follow the IRC Way, and examples of concerns that should be escalated for proper response.

Our Commitments to Society. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

The Code is not intended to make you an expert on every issue, but rather to help you spot risks,
Getting Help. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18
obtain guidance, and make good choices. We must constantly be alert to gaps between policies and
How to Spot Ethical Dilemmas. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 practices and work to close them. This document is designed for staff but should also be shared with
Your Duty to Speak Up . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 partners, donors and other supporters, so they can see the standards to which we are committed.

Channels for Raising Concerns. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19

Please join me in affirming our commitment to the IRC Way, and in promoting the values of the
How to Raise Concerns. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20 IRC in all that we do.
Ethics and Compliance Hotline. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21

Anonymity and Confidentiality. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21

Sincerely,
Anti-Retaliation Policy. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22

Responsiveness. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22

Enforcement. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23 David Miliband

President and CEO

THE IRC WAY | 1

 Our Values Our Shared Responsibilities
Integrity
in Upholding This Code
We are open, honest and trustworthy in dealing with Upholding this Code is a responsibility shared by all involved in delivering on the IRC’s mission. It applies
clients, partners, co-workers, donors, funders and the to all IRC directors, officers, employees, interns, volunteers, incentive staff and partners who work on behalf
communities we affect. of the IRC.
Service
We are responsible to the people we serve and the
Individual Responsibilities
donors who enable our service.

Accountability You are responsible for becoming familiar with the standards of conduct that apply to your job. You will be
We are accountable—individually and collectively—for doing your part when you:
our behaviors, actions and results.
lS
 tay informed by learning the standards of conduct that apply to your role and participating
Equality in ethics and compliance training sessions.
We strive for equal outcomes for all clients and col-
leagues by promoting equitable access to opportuni- l Seek guidance and consult with others when the appropriate course of action is unclear.
ties and services
lS
 tand firm by resisting pressure to compromise our standards or cut ethical corners to meet
GUIDING PRINCIPLES an objective.

l Raise concerns if something doesn’t seem right.

We endorse the Code of Conduct for the International Red Cross and Red Crescent Movement and NGOs in
Disaster Relief. We are guided by its core humanitarian principles, including humanity, impartiality, neutrality, and
independence. As such: Manager Responsibilities

If you manage or supervise others, you have been

lT
 he prime motivation for our response to disaster is to alleviate human suffering amongst
placed in a position of trust. To maintain that trust,
the most vulnerable members of society. We recognize our obligation to provide humanitarian
assistance wherever it is needed; you should always:

lL
 ead by example and be a positive role
l Our aid is given regardless of the race, creed or nationality of the recipient, and without ad-
model to others.
verse distinction of any kind. Aid priorities are calculated on the basis of need;

lP
 romote awareness of the IRC’s standards
lO
 ur aid will not be used to further a particular political or religious standpoint, nor will we tie
and make sure those you supervise are equipped
the promise, delivery, or distribution of assistance to the embracing or acceptance of a particu-
with the knowledge and resources they need
lar political or religious creed; and
to comply with them.
lW
 e shall endeavor not to act as instruments of government policy. We will never allow
ourselves to be used to gather information of a political, military, or economically sensitive lM
 onitor conduct of those you supervise
nature for government or other bodies that may serve purposes other than those which are and take responsibility for activities that
strictly humanitarian. occur under your supervision.

We also affirm and enforce human rights consistent with the U.N. Universal Declaration of Human Rights, the lB
 e responsive to anyone who raises an ethics
Convention on the Rights of the Child, and the UN Secretary General’s Bulletin on the Protection from Sexual or compliance concern and make sure matters
Exploitation and Abuse of Beneficiaries. are resolved in a fair and appropriate manner.

2 | THE IRC WAY THE IRC WAY | 3

 Q&A
Our Commitments QUESTION: I have heard a colleague of mine speak very disrespectfully about the women
we work with. He only does this when there are no women around, and he’s just joking around, but
to Our Colleagues he does it frequently. It makes me uncomfortable. What should I do?

The IRC is committed to ensuring safe and secure conditions ANSWER: If you feel comfortable doing so, take the person aside and explain that you feel
for all workers, regardless of position or location, and to his words are offensive. If you don’t feel safe doing that, or if he doesn’t change his behavior after
maintaining a work environment that promotes staff well-being, you speak with him, follow the procedures outlined in the “Getting Help” section of this Code.
resilience, health and productivity.

QUESTION: Last week, our manager asked us to make a field visit to a particular location.
When I told her that security has designated the area off-limits due to safety concerns, she suggested
You Uphold the IRC Way When You:
we go anyway because there are clients there in need. What should I do?

4 Treat all colleagues with dignity and respect.

ANSWER: The safety of our staff is paramount, and security establishes local protocols
4M
 ake employment decisions based on an individual’s abilities and merits, not personal with this in mind. If you are feeling pressured to compromise safety standards, follow the procedures
characteristics unrelated to the job.
outlined in the “Getting Help” section of this Code.
4 Respect the rights of all individuals.

4 Provide reasonable accommodations for persons with disabilities or special needs.

4 Reject any form of violence or abuse of power.

4S
 tay aware of safety and security concerns, follow local security protocols, and stop
any work that becomes unsafe.

4 Safeguard the confidentiality of personal information.

Relevant IRC Policies

You Should Avoid: and Guidance:
7 Judging individuals based on factors unrelated to work.
lR
 espect at Work Policy
7 Off-color jokes, offensive comments, derogatory e-mails, or sexually explicit images.
lE
 qual Employment
7 Working while impaired by alcohol or illegal substances.
Opportunity Policy
7 Inappropriately disclosing employees’ information, including personal information.
lH
 arassment Free
Workplace Policy

You Should Report: l Accommodation Policy

lS
 ubstance Use in the
s Unwanted, inappropriate or disrespectful sexual advances or harassment.
Workplace Policy
s Bullying, perceived threats, intimidation, favoritism, belittlement, verbal or physical outrages.
l Workplace Violence Policy
s Situations that threaten the safety, security or well-being of staff.
l I RC Global Safety and
sH
 ostility to individuals due to race, religion, gender, gender identity, sexual orientation, Security Policy
disability, veteran status or other characteristic protected by law.
l Confidentiality Policy

l Security and safety protocols

4 | THE IRC WAY THE IRC WAY | 5

 Q&A
Our Commitments QUESTION: I like to support refugee owned businesses so I am using one of our client’s
home-based child care. Is this okay?
to Our Clients ANSWER: It would normally be acceptable for staff to patronize legitimate businesses
owned by clients if they choose. However, the terms/prices offered to IRC staff should be the same
The IRC helps people whose lives and livelihoods are as those offered to the wider public.
shattered by conflict and disaster to survive, recover and gain
control of their future. This requires our commitment to further
their well-being and act with honor in carrying out the vital
humanitarian role that has been entrusted to us. QUESTION: I happen to know that a client is using false information to gain refugee status.
While she does not qualify as a refugee, I know she is fleeing a very difficult life at home. Do I need to
say anything?

ANSWER: Yes, you should raise your concern as outlined in the “Getting Help” section of this
Code. While it may feel tempting to “look the other way,” this would not be the right thing to do.
You Uphold the IRC Way When You:

4 Respect the dignity, values, history, religion and culture of those we serve.
4S
 elect clients according to need, in line with program specifications, without regard to race, QUESTION: We were on a field trip last week, spending the night away from home. I have
creed, nationality or other distinction. good reason to believe one of my colleagues hired a prostitute during the trip. What should I do?

4P
 rotect clients from all forms of abuse, including sexual exploitation and human ANSWER: This would be a violation of the IRC’s standards, and you should follow the proce-
trafficking activities. dures outlined in the “Getting Help” section of this Code.
4 Exercise special care to safeguard children.
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 espect confidentiality, abide by data-protection protocols, and share personal information
about clients on a need-to-know basis in line with donor rules.
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 ortray clients as dignified human beings in any images used in IRC communications, and use
images only of individuals who have provided informed consent.
4 Ensure IRC research involving human subjects is properly approved before it begins.

Relevant IRC Policies Further

You Should Avoid:
and Guidance: Reading:
7 Recruiting clients to work for IRC staff in a personal capacity (e.g., as domestic workers).
7 Engaging in any forms of intimidating, humiliating, degrading or aggressive behavior towards clients. lB
 eneficiary Protection l Code of Conduct for
7 Physically punishing or disciplining clients. from Exploitation and the International Red Cross
Abuse Policy and Red Crescent Movement
7 Sexual activity or intimate relationships of any kind with clients of any age.
lC
 hild Safeguarding Policy and NGOs in Disaster Relief
7 Transactional sex regardless of local laws that may permit it.
lC
 ombatting Trafficking in l U.N. Universal Declaration
7 Coercing clients to sell or relinquish relief items.
Persons Policy of Human Rights, the
Convention on the Rights
lC
 onfidentiality Policy of the Child
You Should Report:
lO
 pen Information Policy l U.N. Secretary General’s
sE
 xploitation of clients in any form. Bulletin on the Protection
l I nstitutional Review
sC
 orrupt or biased decisions to include or exclude clients. Board Procedures Guide from Sexual Exploitation
sA
 buse of power or position in the delivery of humanitarian assistance. for Researchers and Abuse of Beneficiaries.

s Inappropriate disclosure of confidential information related to clients.

6 | THE IRC WAY THE IRC WAY | 7

 Q&A
Our Commitments to Our Donors QUESTION: I know certain costs, like alcohol or entertainment costs, are unallowable on
grants. Can I code them to “sundry” so it will not stand out on the financial report?

Our donors provide the resources that make our work possible, and we must be responsible stewards of those ANSWER: No, you may not misclassify an expense so that it can be paid from a remaining
resources. We are committed to following the regulations and terms established by our institutional donors, as well budget line or charge any unallowable cost to any budget line item. Unallowable costs incurred by
as the expectations of all donors that the funding they provide serves clients efficiently and effectively. the office should be charged to unrestricted funds only.

You Uphold the IRC Way When You:

QUESTION: It is close to the end of a grant and I’ve just received significant purchase re-
4U
 nderstand donor rules that apply to performance and accountability. quests for computer equipment to spend out the remaining budget. Should I sign off on the purchases
in order to submit a fully spent grant report?
4E
 nsure time sheets, expense reports, advance liquidations and other financial documents
are accurate. ANSWER: No, you should not make major purchases at the end of a grant so that they can be
4S
 elect partners able to deliver the best outcomes for clients and monitor their work appropriately paid for from a remaining budget line.
in line with donor rules.
4S
 afeguard the confidential and proprietary information of institutional donors and the personal
privacy data of individual ones. QUESTION: The program I work with has a target of reaching 50 percent women. The team is
4 Inform donors of any errors in reported information, and strive for transparency. registering women as clients to make the numbers look good in reports, but in practice we are delivering
program services to their husbands, not directly to the purported female clients. What can I do?
4C
 onduct grant writing, fundraising, solicitation and marketing activities honestly and with integrity,
in compliance with all applicable laws. ANSWER: You should raise this concern as described in the “Getting Help” section of this
4B
 e truthful and forthcoming in all statements about the IRC and its performance. Code.

You Should Avoid:

7N
 oncompliance with grant requirements or improper use of funding.
7F
 alse time and effort, expense, or cost reporting.
Relevant IRC Policies
7U
 sing existing grant funds to cover the expense of soliciting other grants without donor approval.
and Guidance:
7 Exaggerating or distorting program needs, costs, client numbers or results.
7 Manipulating the selection, unauthorized use or inadequate monitoring of local partners.
l Confidentiality Policy
7 Distorting claims about another organization’s services in comparison to our own.
l Fiscal Integrity Policy
7G
 athering political, military or economically sensitive information on behalf of any donor for
purposes other than humanitarian. lO
 rganizational Gift Solicitation
and Acceptance Policy
7 Accepting gifts from donors derived from or associated with illegal, criminal or fraudulent activity.
l Open Information Policy

l I RC program manuals, standard

You Should Report: operating procedures, and
other guidance documents as
s Falsification of time, expense or cost reports.
relevant to duties
s Fraudulent registration of clients.
lS
 upply Chain standard
s Theft or diversion of aid or resources.
operating procedures
s Improper fundraising practices.
l IT policies governing equipment
and data protection

l Finance manuals

8 | THE IRC WAY THE IRC WAY | 9

 Q&A
Our Commitments to Our Suppliers QUESTION: A potential IRC supplier just invited me to dinner. Can I go?

ANSWER: Yes, accepting meals from suppliers is usually acceptable provided those meals:
Achieving good value for our purchases requires high integrity throughout our supply chain. We are committed to free and 1) could not reasonably be seen as lavish or an attempt to influence a particular decision or action;
fair competition among suppliers, to the support of suppliers who share our adherence to ethical and responsible practices, 2) occur infrequently (e.g., no more than twice per year); 3) take place in respectable venues; 4) do
and to the eradication of fraudulent or corrupt practices by those seeking improper gain from aid intended for clients. not violate any laws; and 5) would not embarrass the IRC if publicly disclosed.

You Uphold the IRC Way When You:

4 Disclose any actual or perceived “conflicts of interest” in a procurement—that is, when personal
interest may interfere with the promotion of the IRC’s interests.
QUESTION: We’ve just gone through the supplier qualification process but we skipped the
site visits to vendors. My colleague made up the information that we submitted on that part of the
4 Ensure good value when designing programs and buying goods and services. forms. What should I do?
4 Follow procurement policies, including policies related to purchase requests, bid notices, bid
analysis, contracting and supplier due diligence.
ANSWER: Falsifying information about supplier due diligence is not acceptable. You should
follow the procedures outlined in the “Getting Help” section of this Code.
4 Treat qualified suppliers and their representatives fairly and equally.
4 Observe strict confidentiality with supplier information, prices, terms and conditions.
4 Provide suppliers with full and clear explanations when rejecting bids.
QUESTION: The product we received from a supplier uses a much lower quality of material than
4 Maintain segregation of duties related to the request, approval and verification of purchases. what we ordered. There doesn’t seem to be a good reason for it, but someone must have authorized it.
4 Discuss relevant procurement policies established by government or institutional donors at Should I just ignore this?
grant meetings.
ANSWER: No, you should raise this concern as described in the “Getting Help” section of this Code.
4 Determine whether export licenses are required or restrictions apply before procuring any While the product may be different for valid reasons, we never condone substitution with an inferior product.
good, software or technology that is governmentally controlled or connected to a country
where exports and imports are regulated.

You Should Avoid:

7 Sharing information unequally to suppliers during the bidding process.
7 Revealing confidential information of one supplier with another supplier.
7A
 ccepting offers of anything of value (including gifts, favors, entertainment, bribes or kickbacks)
Relevant IRC Policies Further
that create or appear to create improper influence or unfair advantage.
and Guidance: Reading:
7 Accepting inferior or substitute goods or services that do not meet specifications.

l Fiscal Integrity Policy l USAID Office of Inspector

You Should Report: General Publication: Fraud
lG
 lobal Mandatory Document
s Biased tender specifications, bidding documents or supplier pre-qualification. Indicators
Retention Policy
s Bid rigging, collusion or other unfair practices among suppliers. l USAID Office of Inspector
l Procurement manuals
s Inadequate supplier due diligence. General Publication: Fraud
Prevention and Compliance—
sT
 ransactions with parties involved in terrorist activities, child labor exploitation, human rights
A Pocket Guide for the
abuses, unsafe or unreasonable working conditions, or the illegal manufacture, supply or
Humanitarian Middle East
transportation of weapons.
Crisis Response
s Requests to make a payment to a name other than the contracted party.

10 | THE IRC WAY THE IRC WAY | 11

 Q&A
Our Commitments QUESTION: The head of a partner organization has asked to see a copy of the prime
awardee budget under which they are funded as a sub-awardee. Can I share it?
to Our Partners ANSWER: You should consult with the IRC manager responsible for administering the IRC’s
confidentiality obligations to the donor, or with the Office of General Counsel to determine whether
Working in partnership with local, national and international civil sharing the information would be permissible.
society organizations, as well as state and private-sector enti-
ties, is fundamental to the IRC’s mission. We are committed to
promoting effective partnerships that enable the IRC to pursue
its strategic goals, resulting in more effective, responsive and
durable assistance that reaches more people.

You Uphold the IRC Way When You: Relevant IRC Policies Further
and Guidance: Reading:
4 Promote partnerships based on accountability, transparency, respect, equity and inclusion.
4 Select partners capable of responsible implementation and ensure that they receive the
l Fiscal Integrity Policy l Code of Conduct for the
support necessary to meet established performance standards.
International Red Cross and
l IRC Global Safety and Security Policy
4 Give partners full credit for the role they play in achieving program outcomes. Red Crescent Movement and
lB
 eneficiary Protection from Exploitation NGOs in Disaster Relief
4 Support partners to avoid and mitigate, as far as is reasonably practical, foreseeable safety
and Abuse Policy
and security risks.
lC
 onflict of Interest Policy
4 Ensure clear, open and respectful two-way communication on performance.
for Employees
4 Take appropriate steps to ensure that IRC funds are used in accordance with applicable laws,
donors’ requirements and IRC standards. l Open Information Policy

4 Involve local partners in the planning, design, implementation and review of IRC programs lS
 ub-Award Partnership Management System
whenever possible.
l Finance manuals

You Should Avoid:

7 Condescending or disrespectful behavior toward partner organizations and their staffs.
7 Any form of abuse of power in partner relationships.
7 Misrepresentation of a partner’s work as that of the IRC.

You Should Report:

s Actual or perceived “conflicts of interest” in partner relationships.
s Corrupt or biased decisions with respect to partner organizations.
s Fraudulent selection of partners.
s Theft or diversion of aid or resources by partners.
s Lax or inadequate monitoring of partner performance or effectiveness.

12 | THE IRC WAY THE IRC WAY | 13

 Q&A
Our Commitments to Our Organization QUESTION: My brother-in-law’s company provides a service that the IRC hopes to procure.
Can I tell my brother-in-law about the opportunity?

The IRC transforms donor contributions into humanitarian aid for clients. To do this, the IRC must remain uncompromised ANSWER: If the opportunity has already been announced publicly, then you may tell your
and efficient in carrying out its work. We must safeguard IRC’s assets and put the interests of the organization first. brother-in-law about it. However, you should not say or do anything that could be seen as giving
your brother-in-law an unfair advantage over other potential suppliers. For example, you should not
share any non-public information about the IRC or the particular opportunity. Finally, you must dis-
You Uphold the IRC Way When You: close your relationship to the procurement department, and you cannot be part of the decision-mak-
ing process for the opportunity.
4A
 void and disclose to your supervisor actual or perceived “conflicts of interest”—that is, situations
when personal interest in outcomes may interfere or conflict with IRC interests.
4U
 se IRC resources responsibly and lawfully and secure them from theft, fraud, waste, abuse or harm
(without endangering yourself or others). QUESTION: How do I know If something contains “confidential information” that cannot be
4M
 aintain accurate books and records. disclosed without authorization?
4O
 bserve proper controls and maintain segregation of duties related to the request, approval and
verification of purchases. ANSWER: Confidentiality is often determined on a case-by-case basis. Be cautious and
assume that all IRC information is proprietary. Not all confidential documents will be marked
4M
 onitor expense reports, vendor payments, payroll figures and budget variances for unusual activity. “confidential.” If you are unsure about any particular document, seek direction from your manager
4P
 rotect confidential and proprietary information from unauthorized access or disclosure. or the Office of General Counsel before making any disclosures.
4R
 etain and discard documents in accordance with document retention policies.
4C
 ooperate fully when asked to provide information to an IRC auditor or investigator.

You Should Avoid:

7 Using IRC position or information for personal gain.
7 Using IRC time or property to perform work for another employer. Relevant IRC Policies
7P
 articipating, without disclosure, in hiring or contracting decisions that involve individuals or entities and Guidance:
with whom you have more than a professional working relationship.
7S
 eeking, accepting or offering anything of value (including gifts, favors, entertainment, bribes or
kickbacks) that create or may appear to create improper influence or unfair advantage. l Conflict of Interest Policy for
Employees
7F
 alsifying records or reports (including receipts, time sheets, inventories, financial statements,
program data, etc.). l Fiscal Integrity Policy
7 Improperly circumventing or overriding internal controls. l Confidentiality Policy
7 Installing unauthorized IT hardware or software.
l Information Technology
7 Destroying records that are responsive to an active or anticipated audit, investigation, lawsuit or
Acceptable Use Policy
claim.
7P
 roviding false, misleading or incomplete responses to information requests by IRC auditors l Global Mandatory Document
or investigators. Retention Policy

l Media and Social Media Policies

You Should Report: and Guidelines

l Other IT policies governing IT

s Fraud, theft, kickbacks or embezzlement.
equipment and data protection
sU
 se of IRC IT materials for personal benefit, political activity, unsolicited advertising, or the
solicitation or performance of prohibited activities. l USP guidance on lobbying

s Actions that may discredit the IRC’s reputation or harm its public image.

14 | THE IRC WAY THE IRC WAY | 15

 Q&A
Our Commitments QUESTION: A customs official tells me that it will take six weeks for our computers to clear.
He also hinted that it could be a much faster process if we just provided a little financial “incentive” for
to Society him. We really need these computers and it’s just a small amount that he’s asked for. Can I pay him?

ANSWER: Definitely not. Unless the amount being requested is a government-authorized,

The IRC is committed to being a responsible global citizen. government-collected and transparent fee for legitimately expediting the clearance, this is an example
Our interactions with governments, regulators, the media and of a prohibited payment. The IRC will not engage in improper acts, even if it means that our operations
local communities must be grounded on honesty, trust and are slowed down or negatively impacted as a result.
fairness. We support the legitimate rule of law and will do our
part to promote high ethical standards in the countries and
communities where we work.
QUESTION: A local politician who believes in policies that would benefit the IRC’s work is
running for office. Can we supply the paper and use our copier to make fliers for her campaign?

You Uphold the IRC Way When You: ANSWER: No, the use of the IRC’s time, equipment or property for political activities is not allowed.

4P
 rovide truthful and complete information when interacting with donors, the media, auditors,
regulatory agencies or investigators.
4C
 onnect our work to larger initiatives that bring protection, stability and inclusion to
displaced populations.
QUESTION: I just saw a posting on social media that claims the IRC knowingly discriminates
against a certain tribal community. Is it okay if I set the record straight?
4M
 inimize and mitigate any adverse environmental impacts caused by our operations.
4E
 nsure your activities are consistent with the standards contained in this Code when identifying ANSWER: You should not take it upon yourself to engage in social debates on behalf of
yourself as a member of the IRC on social media. the IRC. You should report the matter to your manager or to the IRC Communications team who will
determine how best to address the matter.
4S
 eek guidance from the Office of General Counsel when dealing with countries under economic
sanctions or when presented with boycott requests.
4S
 eek guidance from Global Communications for all media outreach, responses, interviews and
public advocacy inquiries.
4S
 eek guidance from the Advocacy Department for all lobbying activities.

You Should Avoid: Relevant IRC Policies

7 Giving or receiving anything of value to anyone (including a government official) in order to and Guidance:
influence decisions or to secure unfair advantage.
7 Providing false, misleading or incomplete responses to valid requests for information by l Anti-Bribery Policy
government agencies.
l Anti-Money Laundering Policy
7 Pressuring colleagues to make political or charitable contributions.
l Fiscal Integrity Policy
7 Lobbying for legislative action or participating in any political campaign on behalf of the IRC
without involvement from the Advocacy Department. lE
 conomic Sanctions and
7 Affiliations that could interfere with your impartiality (or appearance of impartiality) in carrying Anti-Terrorism Compliance Policy
out IRC work or that could harm the IRC’s reputation.
l Export Control Policy

l Anti-Boycott Policy
You Should Report:
l Environmental Policy
s Requests to cooperate with an unsanctioned boycott.
l Procurement manuals
s Situations that endanger health, safety or the environment.

16 | THE IRC WAY THE IRC WAY | 17

 Getting Help Channels for Raising Concerns:

This section describes resources available for the proper implementation The IRC has several channels of communication for staff seeking advice or wishing to report con-
of the Code of Conduct throughout the IRC. cerns. You should choose the channel you feel most comfortable with, but note that colleagues
closest to the situation—your supervisor or local management—are often in the best position to help.
How to Spot Ethical Dilemmas: Available resources, listed in context of “sample issues,” include:

Before making a decision or pursuing a course of action, consider its potential ethical
dimensions by asking yourself:

l Does the decision or action meet the letter and spirit of the IRC’s Code
and external obligations?
SAMPLE ISSUES RESOURCES TO CONSIDER
l Who might be affected by the decision?

l Would additional advice or expertise help? Local operational matters Supervisor/Local Managers
l If this decision was made public, would I feel comfortable explaining it to
colleagues or investigators?
Workplace disagreements (job assignments, Human Resources (HR)
l Is my judgment impartial, or do I have a personal stake in the outcome that performance appraisals, compensation,
makes me less objective? benefits, conflicts with supervisors or
co-workers)
Your Duty to Speak Up:
One of the most tragic aspects of wrongdoing is when people look the other way. Safety of IRC personnel and resources Security
In addition to knowing the ethical and legal obligations that apply to your job, you
are expected to speak up if: Financial reporting, accounting, tax Finance
l You are ever unsure about the proper course of action and need advice. reporting, books and records
l Particular actions or decisions make you uncomfortable.

l You know or suspect that any of the following parties have been, or are about to Fundraising or compliance with donor or Awards Management Unit
be, engaged in illegal or unethical activity in connection with the IRC’s work: grant requirements
– IRC managers, staff, incentive workers or volunteers
– Suppliers
Procurement or supply chain matters Global Supply Chain
– Partners or subcontractors
– Agents, consultants or intermediaries acting on the IRC’s behalf.
Legal matters or policy interpretations Office of General Counsel

Code of Conduct matters unspecified Ethics and Compliance Unit

above, or matters that remain unresolved
after initial consultations

Note that all resources are responsible for coordinating with the Ethics and Compliance Unit if a received concern re-
flects a potential violation of the IRC’s Code of Conduct.

18 | THE IRC WAY THE IRC WAY | 19

 HOW TO RAISE CONCERNS Integrity@rescue.org
This is an email box monitored by the ECU in New York. You can email questions and concerns to this address.

Ethics and Compliance Hotline

EthicsPoint can be reached by
The Ethics and Compliance Hotline is available when:
telephone or online:
lY
 ou feel uncomfortable using another channel
Do you feel comfortable of communication.
SPEAK TO YOUR
speaking to your supervisor lO
 ther channels prove ineffective or appear unresponsive.
YES SUPERVISOR OR LOCAL TELEPHONE
or local manager about Outside the U.S:
MANAGER l You wish to report your concern anonymously.
your concern? +1 (503) 352-8177
The Hotline is administered by EthicsPoint, which is an independent (call collect)
NO third party that does not log or identify telephone numbers or
computer IP addresses. It is available 24 hours a day, seven days a Inside the U.S:
week, in multiple languages. It is available for use by anyone involved (866) 654-6461
with the IRC (including staff, clients, suppliers or partners).
ONLINE
Can you speak with another If you use the phone option, a trained specialist from EthicsPoint Visit irc.ethicspoint.com
YES SPEAK WITH
will make a detailed summary of your question or concern. The
local or regional manager? ANOTHER MANAGER and follow instructions
details will be forwarded to the IRC’s Ethics and Compliance Unit
for further response.
NO

Anonymity and Confidentiality

You are encouraged to provide your name when raising a concern. This allows those who are
Can you contact a relevant
support function (e.g., HR, YES CONTACT
responding to your concern to contact you if additional information is needed to look into your
concern thoroughly. Providing your name also helps us ensure that you do not experience retaliation
Security, Finance, Office of SUPPORT FUNCTION
for making a good faith report. (There may be unique circumstances when disclosing your identity is
General Counsel, etc.)?
required by law or is necessary to fully investigate and address your concerns.)

If you choose to identify yourself when using the Hotline, the IRC will endeavor to keep your information confidential,
NO
sharing it only on a need-to-know basis among those directly handling or overseeing the issues you reported.

If you make a report anonymously, it is important to provide detailed information. EthicsPoint will assign you with a
case number and you should regularly check the site to respond to information requests from the investigation team.
Email integrity@rescue.org Cases that lack enough information for investigators to pursue may be closed.
YES
or use the Ethics and (SEE NEXT PAGE)
Compliance Hotline The IRC recognizes that individuals may wish to raise concerns anonymously, but do not use the Hotline in bad faith
(e.g., to file fabricated complaints for ulterior reasons). Anonymous reports made in bad faith undermine the integrity
of the Hotline for everybody.

20 | THE IRC WAY THE IRC WAY | 21

 Anti-Retaliation Policy Enforcement
The IRC will not tolerate retaliation against anyone who, in good faith, reports a concern or participates in an inves- Anyone who violates the IRC’s Code or its underlying policies, regardless of position or tenure,
tigation, even if the allegation ultimately is not substantiated. may be subject to disciplinary action, including termination. The following are examples of
conduct that may result in disciplinary action:
Anyone, regardless of position or tenure, found to have engaged in retaliatory conduct against someone who has
raised an ethics or compliance concern will be subject to disciplinary action, and possibly termination. If you feel you lV
 iolating the Code
have been subjected to retaliation, you should contact the Hotline for assistance. lD
 irecting or encouraging others to violate the Code

lF
 ailing to report known or suspected violations of the Code
The IRC encourages managers and employees to self-report violations and, depending on the specific
circumstances, may treat self-reporting as a mitigating factor when assessing any disciplinary measures. l Interfering with an audit or investigation

lB
 eing uncooperative or untruthful during an audit or investigation

Responsiveness lR
 etaliating against others for raising a concern

The IRC takes all concerns seriously and acts on all reports no matter the option. Out of respect for the privacy of Violations of laws or regulations can trigger legal action against you, your colleagues, the IRC or its partners
individuals who may be affected by your report, the IRC may be unable to provide you with detailed results of our or suppliers that could result in:
investigation, or tell you what actions were taken in response. Whenever possible, we will provide you with status
updates so you know that your concern is receiving an appropriate response. Members of senior management lF
 ines
and the Audit Committee of the IRC’s Board of Directors also monitor the resolution of cases.
lS
 uspension

lD
 ebarment

l Imprisonment

Those people who work on behalf of the IRC will be asked to sign a statement certifying that they understand and
will abide by this code. Each person will sign the statement when they begin working for the IRC, and each year
thereafter where allowed by law.
Q&A

QUESTION: : I am pretty sure that I observed a violation of the IRC Way, but I am
not completely certain. I don’t want to report something if it turns out that I am wrong.
What should I do?

ANSWER: You should report your concern promptly even if you do not have all the
facts so that the appropriate personnel can look into the issue and determine whether a
violation occurred. As long as you reasonably believe that a violation occurred, you are
reporting in good faith and you are doing the right thing.

22 | THE IRC WAY THE IRC WAY | 23

 NOTES

24 | THE IRC WAY THE IRC WAY | 25

 International Headquarters
122 East 42nd Street
New York, New York 10168-1289
USA
Phone: + 1 212 551 3000
Fax: + 1 212 551 3179