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Code of Conduct

PURPOSE

COSMOPOLITAN AID FOUNDATION (CAF) needs to uphold a tradition of ethical standards in the provision of its services as well as in the management of its business affairs. The code of conduct supplements the mission, vision, and values of CAF and applies to all who provide services under the auspices of CAF. Our adopted code of conduct provides guidance to all who carry out daily activities within appropriate ethical and legal standards. It establishes standards of conduct to protect and promote integrity and to enhance CAF’s ability to achieve its mission and compliance goals.

Who should read this?

The Code of Conduct must govern the actions of CAF. It is to be read by employees and service providers, who need to become familiar with the job-specific legal requirements and recognise circumstances that may raise issues. They are required to sign the Acknowledgement Form, confirming that they have received and read the Code of Conduct and are prepared to adhere to its terms.

CODE OF CONDUCT
It has seven principles:
1.    Confidentiality
2.    Business Ethics
3.    Legal and Regulatory Compliance
4.    Professional Conduct
5.    Conflicts of Interest
6.    Appropriate use of resources
7.    Responsibility
1. Confidentiality

Employees and those affiliated with COSMOPOLITAN AID FOUNDATION (CAF) are obliged to maintain the confidentiality of the orphans and vulnerable children, the widows and their children, the elderly, the mentally disabled, the physically disabled including the deaf and the blind, students, patients, and the public at large that it is assisting. They must also maintain the confidentiality of personnel and other proprietary information, as well as information related to those who enter into business or professional relationships with CAF. As such, employees are entrusted with a wide spectrum of confidential information, which remains the sole property of CAF. Sharing of confidential information with other employees or individuals outside the organisation is strictly forbidden, unless the person requesting the information has a legitimate reason to know it for CAF business-related purposes.

Media Relations

All requests from reporters or the general public for information should be referred to the Public Relations department.

2. Business Ethics

CAF is committed to the highest standards of business ethics and integrity, and requires honesty when representing CAF. CAF is dedicated to ensuring that its billing and reimbursement practices comply with applicable laws, regulations, guidelines, and policies of the countries in which CAF operates, and that all billing is accurate.

Book & Accounting

CAF payments and other transactions are to be properly authorised by management and are to be accurately and completely recorded in accordance with generally accepted accounting principles and established corporate policies. This serves as the basis for managing the business and is important to meeting obligations to the orphans and vulnerable children, the widows and their children, the elderly, the mentally disabled, the physically disabled including the deaf and the blind, students, patients, the public at large, suppliers, and others. CAF’s high standard of accuracy and documentation is necessary for tax and financial reporting requirements.

The duty to report accurate and truthful information also applies to our internal dealings. All work-time and expenses recorded are to be reported accurately and honestly.

Kick-Backs/Bribes

CAF prohibits its employees and other service providers from offering, paying, asking for, or accepting any money or other benefit—including, but not limited to, patient referrals, purchases, leases, or orders. All contracts and other referral sources are to follow all applicable laws.

Antitrust

CAF engages in activities that are subject to the antitrust laws of the countries in which it operates. Generally, these laws prohibit competitors from entering into agreements to fix prices or to reduce price competition.

CAF employees should not provide information about CAF to business competitors. In addition, employees are to refrain from engaging in unfair practices that might restrict competition.

Billing

Billing is to comply with all applicable laws, rules, and policies. Employees who handle patient charges, claims, and records are to accurately document and report services and supplies. CAF prohibits its employees or agents from knowingly presenting, or causing to be presented, claims for payment or approval that are false, fictitious, or fraudulent.

Fraud and Abuse

CAF policies and the various laws of the countries in which CAF operates prohibit fraudulent claim activities. The laws of the countries in which CAF operates prohibit conduct such as knowingly submitting a false or fraudulent claim, or using or making a false statement to get a false or fraudulent claim paid. Other laws governing NGO integrity also seek to reduce fraud and abuse. CAF and its employees and other service providers can be prosecuted for filing inaccurate claims for reimbursement and can be subject to civil fines, criminal penalties, or both.

CAF expects employees to report known or suspected activity of this type to the Corporate Compliance Office or the Management Committee. Employees who lawfully report false claims or other fraudulent conduct, or who otherwise assist in an investigation, action, or testimony, are protected from retaliation to the fullest extent possible under the laws of the countries in which CAF operates.

Performing routine audits or reviews and monitoring, along with internal controls, helps CAF prevent and detect fraud, waste, and abuse.

Intellectual Property

CAF is committed to adhering to all applicable intellectual property laws. Additionally, CAF will respect the intellectual property and copyright laws regarding books, trade journals, magazines, and other applicable resources. All software used in connection with CAF must be properly licensed and used in accordance with that licence.

Marketing & Adverts

Marketing and advertising activities may be utilised for the following purposes: to educate the public, to provide information to the community, to increase awareness of our services, and to recruit employees. Marketing materials and media announcements are to be presented in a truthful, fully informative, and non-deceptive manner.

Gifts

Employees are prohibited from soliciting tips, personal gratuities, or gifts from patients or vendors.

Research

CAF is committed to the following ethical standards in full compliance with the laws and regulations in any research, investigations, and clinical trials conducted. CAF is committed to integrity in disseminating appropriate, valid scientific results in accordance with applicable regulations and guidelines. It is CAF’s priority to protect the rights of its subjects. As in all financial accounting and record-keeping, CAF’s policy is to submit accurate and complete costs related to research grants.

Travels

Travel and entertainment expenses of an employee must be consistent with their job responsibilities and the needs and resources of CAF. Employees are encouraged to participate in and attend educational workshops, seminars, and training sessions.

3. Legal & Regulatory

All activities by or on behalf of CAF are to comply with all laws and regulations of the countries in which it operates.

Health & Safety

CAF employees and other healthcare providers are expected to comply with laws designed to improve workplace safety, such as properly controlling and monitoring dangerous materials, and maintaining safe equipment.

Environment

Employees are to dispose of all waste and other materials and store all chemicals and substances in accordance with applicable laws and regulations. It is important to file all necessary environmental reports accurately and promptly, and to cooperate fully with all governmental authorities in the event of an environmental incident.

Discrimination

COSMOPOLITAN AID FOUNDATION does not discriminate with regard to race, religion, gender, sexual orientation, pregnancy, marital status, age, nationality, ethnicity, ancestry, disability, or status as a disabled or military veteran. CAF also does not tolerate harassment.

Regulation

Many controlled drugs, controlled substances, and other medical supplies are governed and monitored by specific regulatory organisations and are to be administered by physicians' orders only. Prescription and controlled medications and supplies are to be handled properly and only by authorised individuals to minimise risk to CAF and to patients.

Screening

CAF will not knowingly employ or contract with individuals or entities that have been listed as debarred, excluded, or otherwise ineligible for participation in national healthcare and social work programs. As a condition of employment, employees are required to notify Human Resources immediately if they are currently, or to the best of their knowledge, will be in the future, listed by the Armed Forces of the nation where CAF operates.

Tax Exemption

CAF is a tax-exempt entity because of its charitable mission. CAF provides community benefits that include orphans and vulnerable children, widows and their children, the elderly, the mentally disabled, the physically disabled including the deaf and the blind, healthcare services, medical training, education, research, community outreach activities, and the public at large. CAF must use its resources in a manner that furthers the public good rather than the private or personal interest of any individual or entity.

4. Professional Conduct

CAF also has a code of conduct that addresses specific professional responsibilities to its clients and to each other.

5. Conflicts of Interest

Employees and other service providers owe a duty of complete loyalty to CAF and may not use their position to profit personally at the expense of the organisation, financially or otherwise. Potential conflicts of interest should be directed to the Legal Office for evaluation.

Family and Work

Employment of immediate relatives (including a spouse, parent, stepparent, children, stepchildren, sister, brother, son-in-law, daughter-in-law, sister-in-law, mother-in-law, and father-in-law) is not permitted where an employee has or would have direct or indirect administrative, supervisory, or decision-making authority over the related person.

Insider Trading

No employee of CAF shall use non-public information acquired through employment at CAF to trade in the securities of any company, or to buy or sell any property or assets.

Outside Activities

CAF employees and other service providers who hold positions of trust and stewardship should refrain from directly or indirectly performing duties, incurring obligations, or engaging in business or professional relationships where there would appear to be a conflict of interest. No outside activity may interfere with your job performance.

Political Activity

CAF does not participate in or intervene in any political campaign on behalf of, or in opposition to, any candidate for political office. While CAF supports employee participation in the political process, employees are not permitted to use their position in the organisation to try to influence the personal decisions of others to contribute to, or otherwise support, political parties or candidates, except as lawfully permitted through political action committees. CAF may choose to support specific issues with the approval of the Legal Office.

Proprietary Info.

CAF closely controls the dissemination of proprietary information. Except as specifically authorised by management pursuant to established policy and procedure, an employee should not disclose to any outside party any non-public business, whether financial, personnel, commercial, or technological information, plans, or data acquired during employment at CAF.

6. Use of Resources

Those affiliated with CAF have a duty to preserve and protect the assets of the system and to ensure their efficient use. Theft, carelessness, and waste have a direct impact on the organisation’s success. As a rule, CAF prohibits the personal use of its property. Employees may not use equipment, supplies, materials, or services for non-work-related purposes. Employees have no expectation of personal privacy in connection with personal or work use of CAF’s electronic resources.

7. Responsibility

Violations of the responsibilities outlined in this Code of Conduct and CAF policies and procedures can lead to disciplinary action, up to and including dismissal. Conduct that violates the law also may result in civil and criminal penalties ranging from fines to imprisonment.

Reporting

Employees and those affiliated with CAF have a responsibility to report any suspected or actual violation of the Code of Conduct or other policy irregularities to a supervisor, the Corporate Compliance Office, or the Legal Office. For those who wish to remain anonymous, the report may be submitted through one of the CAF Compliance Reporting Lines. There will be no negative consequences or retaliation for good faith reporting of possible misconduct.