Code of Ethics Draft

Preamble

Access100 (the “Corporation”) is committed to the highest standards of ethical conduct in pursuit of its mission to promote government transparency and public access to information. This Code of Ethics establishes the principles and standards of conduct that guide our Directors, officers, employees, and volunteers in fulfilling their responsibilities to the Corporation, its stakeholders, and the public.

I — Commitment to Mission

All individuals associated with Access100 shall:

• Support and advance the Corporation’s mission to promote government transparency, accountability, and public access to information;
• Act in the best interests of the Corporation and the communities we serve;
• Ensure that the Corporation’s resources are used effectively and efficiently to further its mission;
• Avoid any action that could harm the Corporation’s reputation or undermine public trust; and
• Maintain awareness of and comply with all laws and regulations affecting the Corporation’s operations.

II — Integrity and Honesty

All individuals associated with Access100 shall:

• Act with honesty and integrity in all dealings with the Corporation and on its behalf;
• Provide accurate and complete information in all reports, applications, and communications;
• Never knowingly make false or misleading statements;
• Maintain accurate records and accounts;
• Acknowledge and correct mistakes promptly; and
• Uphold the Corporation’s commitment to transparency by being open and forthcoming about its activities and decisions.

III — Conflicts of Interest

All individuals associated with Access100 shall:

• Avoid situations where personal interests conflict, or appear to conflict, with the interests of the Corporation;
• Disclose any actual or potential conflicts of interest promptly and fully;
• Recuse themselves from discussions and decisions where they have a conflict of interest;
• Never use their position for personal gain or to benefit family members or business associates; and
• Comply fully with the Corporation’s Conflict of Interest Policy.

IV — Confidentiality

All individuals associated with Access100 shall:

• Protect confidential information entrusted to them by the Corporation;
• Not disclose confidential information unless authorized or legally required to do so;
• Use confidential information only for legitimate Corporation purposes;
• Maintain the confidentiality of Board deliberations and executive session discussions;
• Protect the privacy of donors, volunteers, and other stakeholders; and
• After leaving the Corporation, continue to protect confidential information.

V — Stewardship of Resources

All individuals associated with Access100 shall:

• Use Corporation resources, including funds, property, and equipment, only for legitimate Corporation purposes;
• Protect Corporation assets from loss, damage, theft, or misuse;
• Not use Corporation resources for personal benefit;
• Exercise prudent judgment in all financial matters;
• Honor donor intent and restrictions on contributions; and
• Report any suspected misuse of Corporation resources promptly.

VI — Fair Dealing

All individuals associated with Access100 shall:

• Treat all individuals with respect, dignity, and fairness;
• Not discriminate on the basis of race, color, religion, sex, national origin, age, disability, sexual orientation, gender identity, or any other protected characteristic;
• Maintain a work environment free from harassment and intimidation;
• Deal fairly and honestly with vendors, contractors, and other business partners;
• Compete fairly and ethically with other organizations; and
• Respect the intellectual property rights of others.

VII — Compliance with Laws and Regulations

All individuals associated with Access100 shall:

• Comply with all applicable federal, state, and local laws and regulations;
• Maintain the Corporation’s tax-exempt status by adhering to IRS requirements;
• Avoid any activity that could jeopardize the Corporation’s legal standing;
• Report any known or suspected violations of law promptly;
• Cooperate fully with any government investigation or audit; and
• Not engage in or tolerate any form of bribery, corruption, or improper payments.

VIII — Transparency and Accountability

Given the Corporation’s mission to promote government transparency, Access100 holds itself to the highest standards of organizational transparency. All individuals associated with Access100 shall:

• Support the Corporation’s commitment to openness about its governance, finances, and activities;
• Ensure that accurate information about the Corporation is available to the public;
• Welcome scrutiny and feedback from stakeholders;
• Hold themselves and colleagues accountable for upholding this Code;
• Lead by example in demonstrating ethical conduct; and
• Practice what we advocate—if we expect transparency from government, we must exemplify it ourselves.

IX — Reporting Violations

All individuals associated with Access100 have a responsibility to report suspected violations of this Code of Ethics. Reports should be made in accordance with the Corporation’s Whistleblower Policy. The Corporation prohibits retaliation against anyone who reports a suspected violation in good faith.

X — Enforcement

A. The Board of Directors is responsible for overseeing compliance with this Code of Ethics.

B. Violations of this Code may result in disciplinary action, up to and including removal from the Board, termination of employment, or termination of volunteer relationship.

C. The Board shall investigate all reported violations promptly and take appropriate corrective action.

XI — Annual Acknowledgment

All Directors, officers, and key employees shall annually sign an acknowledgment affirming that they have read, understand, and agree to comply with this Code of Ethics.

XII — Amendments

This Code of Ethics may be amended by the Board of Directors at any time. All amendments shall be communicated to Directors, officers, employees, and volunteers.