Code of Ethics - IntraHealth International

ForewordDear Colleagues:I am pleased to share with you IntraHealth’s Code of Ethics, a document that delineates our organizationalcommitment to our core values of excellence, openness, partnership, and accountability.Setting forth clear standards that are required of all individuals working for or representingIntraHealth, the Code is intended to raise awareness about ethical issues, offer clear guidance onexpectations of ethical practice, and prevent problems.IntraHealth is dedicated to the highest principles of professional integrity and excellence in all thatwe do. As an organization, we will succeed only through a commitment to our values and thesestandards. Only by behaving ethically can we maintain our reputation as a reliable partner andhighly competent organization.The ten ethical standards outlined in this Code were intentionally selected to ensure the highestlevel of honesty and integrity in our work. These standards will inspire excellent performance byoutlining our expectations of compliance, stewardship, fairness, and respect.Ethical conduct is expected of everyone involved with IntraHealth—our staff, our Board of Directors,and contractors. Each of us has an opportunity—and an obligation—to be aleader in adhering to this Code, and in modeling ethical behavior every day. The Code guidesall decisions and actions, large and small, and applies in all of our offices around the world.Ultimately, our adherence to the Code of Ethics will ensure that IntraHealth accomplishes its mission,delivers outstanding results, and remains a great place to work.Pape A. GayePresident and CEOpage 1

VISIONIntraHealth International believesin a world where all people havethe best possible opportunityfor health and well-being. We aspireto achieve this vision by being aglobal champion for health workers.MISSIONIntraHealth empowers healthworkers to better serve communitiesin need around the world. We fosterlocal solutions to health carechallenges by improving healthworker performance, strengtheninghealth systems, harnessing technology,and leveraging partnerships.

IntroductionIntraHealth International is an independent nonprofit organization that aspires to aworld where all people have the best possible opportunity for health and well-being.IntraHealth seeks to achieve this vision through empowering health workers to better servecommunities in need around the world.IntraHealth has a set of core values that guides our organizational culture, how we dobusiness, and how we engage with our clients, stakeholders, partners, and donors.These core values are gpage 3

CORE VALUESExcellenceWe are committed to deliveringoutstanding performance anddemonstrating results achieved.page 4

CORE VALUESOpennessWe seek and actively engagenew and diverse voices, perspectives,and ways of working.page 7

CORE VALUESPartnershipWe work transparently and respectfully witha wide range of stakeholders, donors, andpartners to achieve shared goals.page 8

CORE VALUESAccountabilityWe adhere to high standards ofintegrity, honesty, transparency, andstewardship in all that we do.page 11

IntraHealth employees and members ofthe Board of Directors are committedto these values and to the highestprinciples of professional excellenceand integrity in achieving our mission.IntraHealth expects its leaders to modelethical behavior and foster an ethicalworkplace culture.The IntraHealth Code of Ethics articulatesthe ethical framework that guides alldecision-making and action across theorganization in alignment with our corevalues, vision, and mission. The Codeis intended to raise awareness aboutethical issues, offer clear guidance onexpectations of ethical practice, andprevent problems. It sets forth standardsthat are required of all individuals workingfor or representing IntraHealth.All IntraHealth employees and membersof the Board of Directors are required toacknowledge and adhere to the standardsoutlined in the Code of Ethics. We alsoencourage our partners, suppliers,and other individuals who represent us(interns, volunteers, and seconded staffmembers) to uphold the spirit of this Codeas they work with us. To that end, theCode of Ethics is posted on IntraHealth’swebsite.The Code of Ethics is likewise availableon the IntraHealth Portal Policy Site.IntraHealth maintains comprehensiveand practical organizational policies andprocedures that offer further guidance onmany of the standards included inthis Code.page 12

Standards

Standard 1Compliance with all applicable laws,policies, and regulationsIntraHealth operates in countries aroundthe world and with diverse government,corporate, and individual funding sources.IntraHealth expects its employees tocomply with all applicable local, state,and federal laws, rules, and regulations inthe US and the countries where we work.IntraHealth employees and members ofthe Board of Directors are expected tocomply with the rules and requirementsof all of our donors and funding sourcesas well as IntraHealth policies andprocedures. When there is an apparentconflict among different laws, rules, orregulations, and employees are uncertainof the course of action, employees shouldseek advice from their supervisors.We maintain updated, comprehensive,and clear policies and guidelines (tailoredto a given country as required) andconsistently monitor our activities forcompliance with policy.page 15

Standard 2Stewardship of financial resourcesIntraHealth upholds the highest standardsof stewardship of the financial resourcesentrusted to the organization, followsethical business practices, and adheresto the accounting principles as set forthin the Generally Accepted AccountingPrinciples. IntraHealth’s books, records,and accounts are complete andaccurately reflect the true nature of thetransactions they record, and IntraHealthemployees and members of the Board ofDirectors honestly and accurately reportall business transactions.All funds that IntraHealth accepts areused only for their intended purpose, andfinancial and other reporting (such astimekeeping) is accurate and complete.IntraHealth undertakes an annual externalaudit of financial statements reviewed andaccepted by the Boardof Directors.IntraHealth actively seeks to preventand uncover fraud by establishing andmonitoring robust systems of financialcontrols, conducting fraud preventionFRAUD IS DELIBERATELY COMMITTEDDECEPTION TO SECURE SOMETHINGOF VALUE. DECEPTION INCLUDESLYING, ASSERTING AS FACTSOMETHING THAT IS NOT KNOWN TOBE TRUE, OR CONCEALING FACTS.EXAMPLES OF FRAUD INCLUDEFALSE CLAIMS ON EXPENSE REPORTS,STEALING, AND ACCEPTING ORGIVING KICKBACKS OR BRIBES.training programs, and maintaining awhistleblower mechanism. Employeeswho observe or see evidence of fraud areexpected to report it.Associated Policies 1 : WhistleblowerPolicy; Fraud Reporting Policy; thecollection of accounting policies found onthe policy site1All associated policies referred to in this Code of Ethics areincorporated in and made a part of this Code, and compliancewith such policies, as applicable, is required as part of compliancewith this Code.page 16

Standard 3Fairness and impartiality inconducting businessAs a good steward of its resources,IntraHealth applies fair, open, andimpartial competitive processes anddecision-making in its procurement,proposal development, purchasing, andhiring. Employees and members of theBoard of Directors do not abuse theirposition with IntraHealth, organizationalproperty, or information for improperpersonal gain.All employees, members of the Board ofDirectors, and other representatives ofthe organization are expected to avoidactivities that could give rise to potentialconflicts of interest. Examples of potentialconflicts of interest include engagingin paid activities outside of work, holdingpublic office, and volunteering withorganizations that could compete withIntraHealth for business. IntraHealthemployees should avoid conflicts ofA CONFLICT OF INTEREST OCCURSWHEN AN INDIVIDUAL BENEFITS FROMORGANIZATIONAL OPPORTUNITIES,FINANCIAL OR OTHERWISE, AS ARESULT OF HER/HIS POSITION, ORIS IN A POSITION TO BENEFIT IN AMANNER THAT MAY INAPPROPRIATELYINFLUENCE JUDGMENT, COMPROMISETHE INDIVIDUAL’S ABILITY TO CARRYOUT HER/HIS RESPONSIBILITIES, ORCOULD BE A DETRIMENT TO THEORGANIZATION’S INTEGRITY.interest that occur when their personalinterests may interfere in any way withthe best interests of the organizationor the performance of their duties andresponsibilities honestly, objectively,and effectively.page 18

IntraHealth employees are expected toguard against situations where someone(e.g., a friend, spouse, family member,professional contact, co-worker, orsupervisor) overtly or subtly attemptsto unduly influence a decision thatinvolves a contract or vendor award.In addition, IntraHealth does not placeor maintain an employee in a positionthat has a reporting relationship with aclose relative; nor does the organizationallow employees to hire or contract closerelatives for service to be performed onbehalf of the organization.IntraHealth employees do not offeror accept inducements as a gestureto influence a decision. Inducementsmay include cash, gratuities, hospitality,entertainment, travel and transportation,favors, contracts, or employment.IntraHealth employees are expected toEMPLOYEES MAY GIVE OR RECEIVEOCCASIONAL GIFTS OF LOWMONETARY VALUE AT A RATE OF NOMORE THAN US$25 PER GIFT-GIVER PERYEAR. EXAMPLES OF THESE GIFTS MAYINCLUDE LOCAL SOUVENIRS, BOOKS,FOOD, FLOWERS, OR AN INEXPENSIVEMEAL.pay particular attention to situationsinvolving government officials, thecorporate sector, or nongovernmentalorganization representatives.Associated Policy: Conflict of Interestand Disclosure Policypage 19

Standard 4Respect for diversityIntraHealth is a multicultural organizationthat appreciates and benefits fromthe diversity of its workforce. IntraHealthemployees treat others with respectregardless of gender, race, age,color, religion, language, disability,national origin, or sexual orientation.IntraHealth promotes gender equality,nondiscrimination, and human rightsin our organizational culture, behavior,and public image as well as in ourprogramming approaches, products,and results. IntraHealth is committedto hiring a diverse workforce andhonoring principles of equal opportunityemployment. We commit to translate allorganizational policies and importantcommunications into French and Spanish,and encourage staff in our country officesto translate these into appropriate locallanguages.Associated Policies: Gender Policy;Harassment and Discrimination Policy;Human Resources policies and Handbookpage 20

Standard 5Commitment to health and safetyThe health and safety of employees inthe workplace is of utmost importanceto IntraHealth. The organization iscommitted to educating, training, andmotivating its employees to maintain asafe and healthy work environment forits employees, partner organizations,and others who visit our workplaces.IntraHealth is committed to developingand maintaining country-level securityplans and procedures that reflect thesecurity environment for each location.IntraHealth expects employees to abideby corporate safety plans and to activelycontribute to a safe work environment freefrom violence, threats of violence, physicalor verbal abuse, bullying, intimidation,or other disruptive behavior. IntraHealthis committed to promoting a healthywork-life balance for its employees, andmaintains drug and smoke-free workenvironments.Associated Policies: Safety and SecurityPolicy; country safety and securityplans; field operations manuals; DisasterPreparedness, Business Continuityand Recovery Plan; Human ResourcesHandbookpage 21

Standard 6Protection of confidential and othersensitive informationIntraHealth values, respects, and protectsthe privacy of our employees, Board ofDirectors, clients, stakeholders, partners,and donors. Employees and membersof the Board of Directors frequentlyhave access to information that isconfidential and proprietary to individuals(e.g., compensation and performance,contribution levels, and health status) andIntraHealth or other organizations (e.g.,internal business decisions, competitivestrategy, proposals and data that belongto partners, donors, and governments).As such, they are expected to safeguardand hold in confidence any sensitive and/or proprietary information, only disclosingsuch information to those who have aclear, professional need to know.We also require consultants and partnersto sign nondisclosure and confidentialityagreements in order to work withIntraHealth. IntraHealth maintains robustdata storage and back-up systems andpolicies that define how employees cansafely and securely access, use, and storeinformation.Associated Policies: Privacy Policy;IT Computer Network Policypage 23

Standard 7Respect for and protection ofintellectual assetsIntraHealth recognizes and respectsintellectual property rights and iscommitted to fulfilling IntraHealth’sethical and legal obligations with respectto the fair use of copyrighted materials.Employees are expected to protectIntraHealth’s intellectual assets and maynot infringe on the intellectual propertyrights of others (e.g., individuals, academicinstitutions, partners, donors, andcorporations).IntraHealth encourages widedissemination, use, and modification ofour technical products and materialsfor noncommercial purposes and withproper attribution to IntraHealth. At thesame time, IntraHealth is committed toprotecting those assets that are associatedmost closely with our corporate brand(e.g., our corporate materials, trademark,and logo).EXAMPLES OF INTELLECTUAL ASSETSINCLUDE DATA, SOFTWARE,INFORMATION, PROPOSALS, REPORTS,PROGRAMS, CONCEPTS, INVENTIONS,DESIGNS, METHODOLOGIES,PROCESSES, TOOLS, AND PRODUCTS.All technical materials and products,including authored pieces, written orprepared on IntraHealth time and underan IntraHealth title, are considered theorganization’s intellectual property.Associated Policies: Copyright Policy;Authorship Guidelinespage 24

Standard 8Integrity in conducting global healthresearch and programmingIntraHealth and its employees shallprotect the welfare and rights of humansubjects in research and other assessmentactivities, and of clients and participantsimpacted by our program activities.For research, we do this throughapplication of comprehensive humansubjects’ protection procedures thatinvolve use of an institutional reviewboard for human subjects’ protection,meaningful assessment of risks/benefitsfor human subjects, and informed consentprocedures. IntraHealth adheres to thehuman subjects’ protection requirementsaccording to US federal regulations, andas outlined by ourown policy, donors, and regulationsin the countries where we areconducting research.IntraHealth safeguards the confidentialityand privacy of health workers, clients, andcommunity members in the context of ourroutine monitoring, program assessments,training, and service delivery programs.IntraHealth also maintains formal informedA HUMAN SUBJECT IS AN INDIVIDUALABOUT WHOM AN INVESTIGATOROBTAINS DATA THROUGHINTERVENTION OR INTERACTION, ORIDENTIFIABLE PRIVATE INFORMATIONTHROUGH EXISTING DATA SOURCES.consent procedures for specific healthprograms (e.g., informed choice for familyplanning counselingand services).Further, IntraHealth has no tolerance forabuse or sexual exploitation of projectparticipants and clients committed by ouremployees and partners, and will respondseriously and appropriately to anysuch reports.Associated Policy: Human SubjectsProtection Guidelinespage 25

Standard 9Accuracy, fairness, and honesty incommunicating about our workIntraHealth and its employees strive toshare complete and accurate informationwith donors, the professional globalhealth community, the media, and thegeneral public about our work, ouraccomplishments, and the results towhich we contribute. IntraHealth is mindfulof the breadth of effort it takes to achievesignificant global health impact, doesnot overstate its own contribution, andacknowledges the contribution of others.IntraHealth collects material from programstakeholders and beneficiaries for use incommunicating about our work. Whengathering and using such material,IntraHealth strives to inform the individualsof the possible uses of the material and toseek advance permission (either writtenor verbal) prior to use. When necessary,IntraHealth uses pseudonyms to protect asource’s identity, privacy, and safety.Associated Policy: Photography forPublications Guidelinespage 26

Standard 10Stewardship of natural resourcesand the environmentIntraHealth is committed to reducingthe impact of its operations on theenvironment and being environmentallyfriendly. IntraHealth strives todemonstrate its long-term commitmentto environmental sustainability by creatinga work environment that minimizes wasteby mitigating IntraHealth’s impact on theenvironment. Examples of environmentallysensitive practices include carefulweighing of environmental costs againstprogrammatic benefits of travel; recycling;reducing consumption of energy, water,and paper products; proper disposal ofmedical waste, computers, and otherinformation technology tools; andintegrating environmental factors into theprocurement process.Associated Policy: Green Policypage 27

Supporting Ethical PracticeThe ethics liaison officer, or Compliance Officer, for purposes of the Code isIntraHealth’s Vice President for Human Resources. The Compliance Officer has theresponsibility to develop, lead, and monitor a robust organizational ethics program.This program includes, at a minimum, the following:• Employee orientation and ongoing training and support on the Code and itsrelated policies (this may include engaging employees across the organization asethics point persons).• Providing guidance when an employee is not clear what is expected in a specific situation.• Systematic collection of information related to implementation of the Code (to includesuch items as employee perceptions and reporting on ethical concerns and how theirconcerns are addressed).• Serving as the first line of response in investigating possible ethics violations.• Liaison and ongoing reporting to the Executive Team and the Board of Directors.Every employee and member of the Board of Directors has the responsibility to askquestions, seek guidance, report suspected violations, and express concerns regardingethical practice. In situations where an employee is not certain about the ethical course ofaction or believes s/he has witnessed an unethical action, s/he should bring the situation toher/his supervisor’s attention. Supervisors are expected to promptly report any complaintsreceived or observations of ethics violations to the Compliance Officer. If the ethical courseis not clear after reporting to a supervisor, or if the employee is not comfortable speakingwith a supervisor, the employee should seek guidance from the ethics liaison officer.If these initial actions are inappropriate or unsatisfactory, employees may contactthe member of the Board of Directors who has been designated as the IntraHealthWhistleblower Contact. The Whistleblower Contact maintains an email where employeescan report suspicions of misconduct confidentially without retaliation and have theirreports addressed in a timely manner (intrahealth_whistle_blower@yahoo.com). Anyonefiling a complaint must be acting in good faith and have reasonable grounds for believingthe information disclosed is an ethics violation.For additional information, see our Whistleblower Policy, which is posted on theIntraHealth Portal Policy Site.page 29

Ethics ViolationsIntraHealth is committed to ethical practice across the organization and takes swift,fair, and appropriate action in response to violations of the Code. The consequencewhen an employee or Board Member violates the Code will be commensurate withthe seriousness of the situation, and will involve the most senior individuals within theorganization relevant to the given infraction. Violation of any of our standards andpolicies may result in disciplinary action that can include dismissal and/or legal action.Amending and Updating the CodeIntraHealth reserves the right to amend or alter this Code as it deems appropriate. Themost current version of this Code can be found on the IntraHealth Portal Policy Site.This document is not an employment contract between IntraHealth and any of itsemployees or members of the Board of Directors.page 30

ConclusionIntraHealth’s core values of excellence, openness, partnership, and accountabilityserve as the foundation of ethical practice within the organization. The Code of Ethics isdesigned as a guide for ethical decision-making for the organization and not necessarilyas exhaustive guidance for all the ethical issues that may arise.IntraHealth’s reputation and ultimate success as an organization is derived from theday-to-day conduct of the individuals who work for and in other ways representthe organization. IntraHealth seeks to attract and retain individuals with high ethicalstandards. Employees and members of the Board of Directors are expected to act withgood personal judgment and integrity to uphold these standards and serve asstewards of our good reputation and the core values we espouse.page 32

Standard 1Compliance with all applicable laws,policies, and regulationsStandard 2Stewardship of financial resourcesStandard 3Fairness and impartiality inconducting businessStandard 4Respect for diversityStandard 5Commitment to health and safetyStandard 6Protection of confidential and othersensitive informationStandard 7Respect for and protection ofintellectual assetsStandard 8Integrity in conducting global healthresearch and programmingStandard 9Accuracy, fairness, and honesty incommunicating about our workStandard 10Stewardship of natural resourcesand the environment

www.intrahealth.orgIntraHealth International, Inc.6340 Quadrangle Drive, Suite 200Chapel Hill, NC 27517Tel: +1.919.313.9100Washington, DC office1776 I St. NW, Suite 650Washington, DC 20006Tel: +1.202.407.9432E-mail: intrahealth@intrahealth.org