Est1 Code of Ethics Company G

Patti BowenWestern Governors University| | Given Company Ethics Program A. INTRODUCTION Our Code of Ethics Program is designed to uphold the interests of every stakeholder of Given Company. Our mission is to uphold a high level of integrity by maintaining high company standards, values and principles to ensure the company meets its mission of being a good corporate citizen who is socially responsible.

Our program provides effective guidance for daily decision making for all levels of personnel in an effort to establish and promote long-term relationships within Given Company and with our customers and community. The overall goal of the program is to be diligent in establishing a culture built on trust and respect, both internally and externally. Our program serves as the moral compass for all business activity performed by Given Company and its employees. B. STANDARDS AND PROCEDURES

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Laws and Regulations Employees of Given Company are expected to comply with all applicable local, state, and federal laws and regulations. Violations resulting from employee activities, business or personal, will not be condoned. Employees are expected to conduct all business activities well above the minimum standards required by law. Employees are expected to communicate all situational uncertainty with their direct supervisor and/or human resources director to ensure proper guidance and clarification.

When in doubt, one should always waiver on the side of caution and seek advice, rather than make a choice that will leave a lasting impression on the reputation of the individual employee or the company as a whole. Employee Conduct In the course of all business activity, from the most routine, simple or mundane, to extremely complex, one must question the impact to the individual and the overall impact to the company and its stakeholders. Employees will be held responsible for their own conduct. Employees are expected to conduct themselves in a professional manner at all times while on company time.

Conduct that will not be tolerated includes, but not limited to, profanity, drinking or illicit drugs, illegal activity, dishonesty, and any activity that may be misconstrued as sexual misconduct or harassment. Company time consists of any time an employee is representing the company onsite or offsite. This includes times of business related travel, offsite business meetings, trainings, or entertainment related to business. Conflicts of Interest Employees must conduct all business activity in the best interest of Given Company and its stakeholders.

Employees cannot personally benefit from activities directly or indirectly resulting from business related relationships or activities. Employees are expected to disclose all potential conflicts of interest relating to relationships (family or friends), private security holdings or investments, or personal dealings in any capacity relating to existing or future customers. A conflict of interest will impair an employee’s ability to conduct business in the best interest of the company. Employees are required to report all potential conflict of interest. Confidentiality and Privacy

Given Company employees are obligated to protect the privacy and rights of all company stakeholders and its customers/clients. All business activity, records, documents, and references relating to Given Company and its customers/clients are considered confidential in nature and must be not be disclosed, except in accordance relative to specific job duties or as allowed by strict company policy. Company Funds, Transactions, Assets, Property, Records, and Communications All company resources or relative authorities provided to employees are strictly for the sole purpose of conducting business in the name of the company.

Personal use of company resources or misuse of authority will not be tolerated. Employees will be expected to uphold the highest level of honor and integrity concerning all company resources and authority. The company has a zero tolerance for misuse of company resources and authority. Examples include, but not limited to, funds, transactions, assets, credit, property, records, or communications. Gifts, Favors, Discounts, Entertainment, Kickbacks All business must be conducted in the best interest of Given Company.

Employees are not allowed to accept unsolicited gifts, favors, discounts, entertainment, and/or kickbacks, from any person or institution conducting business (active or future) with Given Company. All business activity must fall within the scope of routine business. Any activity that is for personal gain, personal motive, or would impair an employee’s judgment is strictly prohibited. Employees are expected to report any and all gifts, favors, discount, and/or entertainment as per company policy and regular business reporting practices set forth by the company.

Consequences for Employee Misconduct Violations of company standards, policies, procedures, and ethics program guidelines, could result in employee reprimand, probation, suspension, salary reduction, demotion, or dismissal. In addition, employees may be held responsible for damages and/or losses, or referred for criminal prosecution or civil action. C. ETHICS EDUCATION AND TRAINING The goal of Given Company is to ensure all employees understand and comply with the established mission, values and standards of the company as presented by the company’s ethics program and policies and procedures.

Given Company is committed to the necessary steps and actions to create and maintain a high level of integrity in the name of the company and its stakeholders. Each new employee will complete an in-person training detailing the company’s mission, standards, and ethics program within the first thirty days of employment, or prior to unsupervised business activity. Annually, Given Company will provide training intended to educate and update employees on company standards, policies, procedures, expectations, and changes to relevant laws and regulations.

Annual training will also afford employees the opportunity for team building, direct openness, and a time to redefine or improve the company’s ethics program. MONITOR, AUDIT AND REPORT SYSTEMS Given Company is fully committed to monitoring and auditing all business activity, direct and indirect, to ensure the highest level of integrity and social responsibility. Through consistent monitoring and auditing practices the company will evaluate all business activity in accordance to the ethics program, policies, procedures, or as deemed necessary by state, local and federal laws and regulations.

The company strongly encourages open communication between management and employees. All employees should ask questions, address concerns, or report suspected misuse or unethical behavior without hesitation or fear of reprisal. The company is fully committed to advising and educating employees based on questions, concerns, as well as promptly investigating any suspected misuse or abuse reported. The company has established the following resources to encourage open communication between the company and its employees: ·A company-wide open door policy.

Employees may meet with company leadership, management, and/or director of human resources. All communication will be considered confidential. ·Ethics Line – Employees may call 1-800-My Ethic (1-800-693-8442) to address questions, concerns, or report suspected misuse or unethical behavior. The line is secure and confidential. Anonymous information accepted. REVIEW AND IMPROVE Given Company considers its ethics program to be fluid – a program that is continually evolving to meet changes in business practices, in the demands of the ever-changing business world, or changes in laws and regulations.

Given Company has established and will maintain an ethics committee comprised of the human resources director, management, and individual employees. The team will meet regularly, based on an established schedule, but no less than once a quarter, to review the ethics program, discuss concerns, highlight successes, and ensure the company is meeting monitoring and auditing responsibilities. In addition, the team will be directly involved in developing and presenting the annual all employee ethics training program.

Following new hire training and annual review, each employee will complete a conflict of interest questionnaire and sign a form to acknowledge their understanding of the ethics program and confirm their commitment to uphold the company’s standards, values and principles. All documentation will be maintained in respective personnel files. Given Company understands its ethics program will not eliminate all unethical or fraudulent behavior, but understands the program will improve the likelihood of detecting, preventing and minimizing such activity.

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