Advocacy, Rehabilitation, and Empowerment for All

Greg Health Care Foundation (GHCF) Policies and Procedures for Code of Conduct, Conflict of Interest, Confidential Information and Intellectual Property

A. Code of Conduct (Policy)

In order to ensure the successful mission and protect the reputation of GHCF, it is imperative that GHCF employees and volunteers (“GHCF Staff”) engage in behavior that is ethically sound and legally compliant. Our reputation for integrity and excellence requires careful observance of the spirit and letter of all applicable laws and regulations and the avoidance of even the appearance of improper behavior or impropriety, as well as a scrupulous regard for the highest standards of conduct and personal integrity. The continued success of GHCF is dependent upon our donors and partners’ trust and we are dedicated to preserving that trust. GHCF Staff owe a duty to GHCF and its donors and partners to conduct all activities in a manner that will merit continued trust and confidence.

GHCF, pursuant to its documents of incorporation, and within the confines of its bylaws, has a mission “to lobby and advocate for enabling environment that promotes human rights and democratic principles especially among the marginalized groups of people. How GHCF performs its mission is as important as the mission itself. GHCF must at all times perform its operations in a manner that increases and evinces integrity, accountability, responsibility and transparency.

In connection with all operations, GHCF Staff are required to comply with all internal policies, procedures and directives as well as with all applicable laws and regulations. All GHCF Staff members are required to conduct business in accordance with the letter, spirit, and intent of all relevant laws and regulations and to refrain from any illegal, dishonest, or unethical conduct. Additional direction may be found in the Employee Handbook or other company policies. The Employee Handbook and policies are in addition to the Code of conduct.

GHCF Staff, in delivering services and in all other GHCF activities, agree to meet the following

Code of Conduct
NO GHCF Staff shall:

  • Accept, or seek on behalf of any person, any financial advantage or gain of other than nominal value offered as a result of the GHCF Staff’s affiliation with GHCF (Private Benefit).
  • Knowingly take any action or make any statement intended to influence the conduct of GHCF in such a way as to confer any financial benefit on any person, corporation or entity in which the Individual has a significant interest or affiliation (Private Inurnment) by the Board of Directors on March 22, 2015. Contractors are bound by the contract signed with GHCF
  • Publicly use its GHCF affiliation in connection with the promotion of partisan politics, religious matters, or positions on any issues not in conformity with GHCF‘s vision and beliefs.
  • Disclose or use any confidential GHCF information that is available solely as a result of the affiliation with GHCF, to or with any person not authorized by GHCF to receive such information, or to use any GHCF information to the disadvantage of GHCF (see Confidentiality Policy).
  • Authorize the use of the GHCF name or logo, GHCF funds, GHCF Trademarks, services or property of GHCF for personal gain, or for the benefit or advantage of any person except in conformance with GHCF policy.
  • Operate in any manner contrary to the best interests of GHCF.
  • Operate or act in a manner that creates a conflict with the interests of GHCF (see Conflict of Interest Policy).
  • Officers, directors, and employees are prohibited from using organization contact (s) to advance their private business or personal interest at the expense of the organization, it’s clients or affiliates. In case of any interest (s), these interests MUST be made clear through signed off agreements or MoUs (Refer to “Code of Ethics Policy” and “The Whistleblower Policy”).

In general, the use of good judgment, based on high ethical principles, will guide GHCF Staff with respect to lines of acceptable conduct. If a situation arises wherein it is difficult to determine the proper course of action, GHCF Staff must seek advice and counsel from their managers or supervisors and, if appropriate, from the TOP MANAGEMENT .

Reporting unethical conduct like sexual harassment, illegal behavior, fraud, abuse or waste is a mandatory obligation of all GHCF Staff members (please refer to the Whistle Blower Policy for details). If you have knowledge of conduct that could potentially harm GHCF you are obligated to report such conduct to the General Counsel or your manager or supervisor. By not reporting such conduct, GHCF Staff would be acting contrary to the best interests of GHCF, which is a violation of the Code of Conduct.

To do this, we must also maintain at all times an environment where GHCF Staff feel free to call attention to legal or policy violations and to investigate impartially the related concerns. GHCF will not retaliate against any individual for reporting suspected violations of laws, regulations or GHCF policies in good faith. In addition, we will not tolerate retaliation against GHCF Staff for such reporting. GHCF Staff are expected to cooperate in internal investigations of misconduct.

We have a history of succeeding through honest business activities. We do not seek the furtherance of our mission through illegal or unethical business practices but rather seek to achieve successes fairly and honestly. GHCF Staff should endeavor to deal fairly with all individuals and entities. GHCF Staff should not take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or any unfair dealing practice.

GHCF is an equal opportunity employer, which does not discriminate against applicants, employees or volunteers based on race, colour, religion, sex, national origin, citizenship, age, handicap or disability, veteran status, or any other characteristic protected by law. Our policy applies to all personnel transactions, terms, and conditions of employment. GHCF will make reasonable accommodations where and when required because of an individual’s disability or religion.

All GHCF Staff should strive to preserve and protect GHCF’s assets and ensure their efficient use. All GHCF assets may only be used for legitimate GHCF business purposes. Please remember that the materials, products, photographs, designs, plans, ideas and data of this organization (including those created by GHCF Staff using GHCF time, resources, or opportunity) are the property of GHCF, and may not be given to anyone except through normal channels and with appropriate authorization by GHCF. Assets also include, without limitation, proprietary information and intellectual property rights, computer systems and the data on these systems, including, without limitation, passwords allowing access to the data on the systems.

Compliance with proper business ethics and conduct is the responsibility of every GHCF Staff member. Sometimes the line between personal and GHCF benefits is difficult to draw, and sometimes both personal and GHCF benefits may be derived from certain activities. In such situations, GHCF Staff must take measures to ensure that any use of GHCF property or services that is not solely for the benefit of GHCF’s mission is approved beforehand by a manager, supervisor, management or the General Counsel.

Contact the General Counsel for more information or questions about the Code of Conduct.
Disregarding or failing to comply with this Code of Conduct could lead to disciplinary action, up to and
including termination of employment.

B. GHCF Staff Conflict of Interest Policy

GHCF Staff must ensure that they at all times conduct GHCF business in such a manner as to avoid a potential or actual conflict of interest. In general, a conflict of interest arises when a person’s personal, professional, or financial interests compete or conflict with his or her responsibilities to GHCF (a potential or actual “Conflict of Interest”). Such a Conflict of Interest can exist whether or not money is involved, and whether the conflict is actual or only perceived.

“Conflict of Interest” is defined as:

A situation where a person’s competing interests and loyalties between his or her personal, business or other interests and the interests of GHCF make it difficult to fulfil his or her duties to GHCF impartially; or

2. Any financial or other interest which conflicts with the obligations of the individual to GHCF because
a) could impair the individual’s objectivity, or
b) could create an unfair advantage for any person or organization

There may be times when the GHCF Staff member’s personal interests conflict with, or appear to conflict with, the best interests of GHCF. A conflict could be a financial interest (such as owning a financial interest in a company that does business with GHCF) or a situation in which a relative1 owns or works for a competitor, supplier, or partner of GHCF.

A potential conflict also arises when a GHCF Staff member or relative receives any remuneration, gift of more than de minimis value (i.e., in excess of $2), or special consideration as a result of any transaction or business dealings involving GHCF. Even if there is no evidence of improper conduct, a conflict of interest can create an appearance of impropriety that can undermine confidence in the ability of that person to conduct his or her duties with proper ethics.

If any GHCF Staff member is, or will be serving as, a director or officer of an organization that is a partner, supplier or competitor of GHCF, a potential conflict may exist. When a GHCF Staff member acts as a director of a partner, he or she has an affirmative obligation to act in a fiduciary or similar capacity regarding actions of the partner. These obligations may conflict with GHCF’s best interest and require both disclosure and prior approval by the Executive Leadership Team.

Employees may not hold outside jobs or engage in activities that are in competition with GHCF, or that interfere with their duties with GHCF, without the express written consent of the Executive Director under the guidance of the Legal counsel.

All GHCF Staff members are obligated to promptly disclose any actual or potential conflict of interest arising between his or her personal, business or financial interests and the interests of GHCF. For
example, a non-exhaustive list of the types of situations that require disclosure and prior approval,
a. any interest (or any interest held by an immediate family member) in any Recipient of GHCF
funds or in any organization or entity furnishing property or services to GHCF or otherwise
entering into a transaction with GHCF.
b. any transaction involving GHCF that would benefit the person or his or her immediate family, or
any organization in which he or she (or his or her immediate family) has an interest
c. any opportunity within the scope of GHCF’s activities that a person (or his or her immediate
family) wishes to exploit for personal benefit
d. the receipt (including receipt by the person’s immediate family) of any gifts or compensation as a
result of any transaction involving GHCF
Such disclosure must be made to any member of the Executive Leadership Team and must be made
immediately upon becoming aware of the potential conflict. Until GHCF approves actions to mitigate or
otherwise resolve the conflict, the GHCF Staff member must abstain from participating in any
discussions, deliberations, decisions or voting related to the conflict of interest.
This policy imposes an ongoing obligation on all GHCF Staff to be aware of and consider this Policy at all
times. Complying with the requirements of this Policy should become a habit and the practice of all
GHCF Staff. This Policy establishes only the framework within which GHCF wishes the business to
operate. The purpose of these guidelines is to provide general direction so that GHCF Staff can seek
further clarification on issues related to the subject of acceptable standards of operation. Contact the
General Counsel for more information or questions about the Conflict of Interest Policy.
Disregarding or failing to comply with this Conflict of Interest Policy could lead to disciplinary action, up
to and including termination of employment.
Definition of a relative

Officers, Directors and Advisory Committee/Council Members are bound by the Greg Health Care Foundation (GHCF) Conflict of Interest Policy adopted

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.
Relatives have no immunities and privileges in the organizational policies and so can be employed or
hired like any other employee on merit. At GHCF we consider meritocracy
C. Confidential Information Policy
The protection of confidential business information and trade secrets is vital to the interests and the
success of GHCF. Such confidential business information and trade secrets include, but are not limited
to, the following:
1.Financial information;
2.Donor and client information;
3.Partner information;
4.Operating procedures;
5. GHCF polices and procedures;
6.Contracts and agreements; and
7.Personnel information.
It is the responsibility of the GHCF Staff member to conspicuously mark all confidential documents upon
creation and duplication. GHCF Staff members may only use and disclose confidential business
information and trade secrets to the extent necessary in the ordinary course of performing their job
duties for GHCF and with appropriate protections as advised by the Legal Office. GHCF Staff members
may not remove GHCF’s confidential business information or trade secrets upon leaving employment or
service with GHCF, and may not use GHCF’s confidential business information or trade secrets after
leaving employment or service with GHCF.
All contractors, consultants and partners are required to sign non-disclosure agreements prior to any
disclosure by GHCF Staff members of any confidential information.
Contact the General Counsel for more information or questions about the Confidentiality Policy.
GHCF Staff members who improperly use or disclose confidential business information or trade secrets
will be subject to disciplinary action, up to and including termination of employment, even if they do not
actually benefit from the disclosed information.
D. Intellectual Property Policy

All intellectual property created by GHCF Staff members in the course of employment or using YOFACO
time, equipment, information or materials, is owned by GHCF.
Intellectual Property includes, but is not limited to:
1. all inventions, discoveries, techniques, processes , methods, formulae, ideas, photos, technical data
and specifications, testing methods, research and development activities, computer programs and
designs (including improvements and enhancements and regardless of patentability);
2. trade secrets and know- how, either positive or negative;
3. all copyrightable material that is conceived, developed, or made by the GHCF Staff member alone or
with others;
4. trademarks and service marks; and
5. all other intellectual property.
All GHCF Staff Members must promptly and fully disclose to GHCF any and all Intellectual Property
created and agree to assign, transfer and convey to GHCF the entire right, title and interest in and to all
Intellectual Property and to take sure reasonable steps as are necessary to convey or perfect such rights.
Reasonable steps to convey or perfect such rights include executing an assignment document for
recording in the proper government agency.
In the event of a failure to convey or perfect such rights under the previous paragraph, all GHCF Staff
Members do hereby assign by means of this Agreement all right title and interest in said Intellectual
All GHCF Staff members must ensure that all consulting and other agreements with third parties contain
Intellectual Property provisions as deemed advisable by the General Counsel in order to protect the best
interests of GHCF.
Contact the General Counsel for more information or questions about the Intellectual Property Policy.
Disregarding or failing to comply with this Intellectual Property Policy could lead to disciplinary action,
up to and including termination of employment.