BCM Institute Code of Ethics

Intent

To promote lawful and ethical behaviour by all employees, officers and members of the Advisory Council and its subcommittees, and to ensure that the Institute’s business is conducted according to the values of the Institute and all applicable rules, regulations and laws.

Applies to

This policy applies to all employees and officers of the Institute. This policy also applies to Council & Subcommittee members, where applicable.

Guidelines

The Institute is committed to conducting its business ethically and with integrity. The ethical conduct of the Institute depends on the collective conduct of its employees, officers and Council & Subcommittee members. The Institute has established this Ethics Program to coordinate compliance oversight activities organization-wide.

The Ethics Program establishes processes to assist employees, officers and Council members in obtaining guidance and resolving questions regarding ethical and compliance issues. The Institute has adopted principles in the following areas to guide employees, officers, and, where applicable, Council & Subcommittee members, on behaving with respect, honesty and decency towards everyone affected by our business:

    • 1.0 Compliance with laws, regulations, rules and policies
      Each employee and officer is expected to be familiar and comply with all of the policies of the Institute that apply to their employment. In addition, a commitment to ethical conduct requires that employees and officers comply with the spirit of the law as well as the letter of the law.

      It is the duty of each employee and officer to know, understand and comply with any laws, regulations, and rules that apply in his/her job. Violating the law can seriously damage the Institute’s reputation, subject the Institute to liability, and subject the employee or officer to personal liability.

    • 2.0 Appearance of good conduct and avoidance of conflicts of interest
      Each employee, officer and Council member has a responsibility not only to do the right thing but also to avoid behaviour that could be perceived as failing to do the right thing. Employees, officers and Council members should always act in the best interest of the Institute and avoid even the appearance of a conflict of interest. A conflict of interest occurs when an individual’s private interest interferes in any way with the interests of the Institute as a whole. A conflict situation can arise when an employee, officer or Council Member takes actions or has interests that may make it difficult to perform his or her Institute work objectively and effectively. Conflicts of interest also arise when an employee, officer or Council member, or a member of his or her family, receives improper personal benefits as a result of his or her position with the Institute.
    • 3.0 Employee relations
      Each employee and officer should promote diversity, inclusiveness, and understanding in the workplace by valuing the individuality and creativity that every employee brings to the Institute. The Institute is committed to hiring, placing and promoting employees on the basis of ability and merit and evaluating employees on a fair and consistent basis.

      Harassment
      Management firmly believes that harassment of any kind seriously undermines the integrity of the employment relationship and respect for human dignity. The Institute is committed to providing a work environment free from harassment, intimidation, and coercion based on or related to race, gender or religion. Each employee and officer has a responsibility to uphold the Institute’s commitment to provide a workplace free from harassment of any kind.

      Commitment to safety
      Each employee and officer should perform his/her job safely at all times, protecting the public, customers, other employees and themselves from injury. It is each employee’s responsibility to look out for and resolve unsafe situations. An employee should immediately report to management any unsafe situation he/she is unable to resolve.

      Commitment to excellence
      Each employee and officer should:

      • Represent the Institute with dignity and in a respectful manner.
      • Strive for continuous improvement and maximize efficiency in his/her job.
      • Work with others to achieve the common goal of quality service.
    • 4.0 Community relations
      Officers and employees should be responsible citizens of our local, state and national communities. The Institute supports civic projects and community programs that contribute to the improvement of our society and encourages employee participation in these projects and programs.
    • 5.0 Appropriate use of Institute assets
      Each employee, officer and Council member has a responsibility to properly use Institute property, facilities and equipment. This responsibility includes protecting Institute property from loss, theft, abuse and unauthorized use. All Institute assets should be used for legitimate business purposes.
    • 6.0 Corporate Opportunities
      Employees, officers and Council members are prohibited from (a) taking for themselves, personally, opportunities that are discovered through the use of corporate property, information or position; (b) using corporate property, information, or position for personal gain; and (c) competing with the Institute. Employees, officers and Council members owe a duty to the Institute to advance its legitimate interests when the opportunity to do so arises.
    • 7.0 Fair Dealing
      Each employee, officer and Council member should endeavour to deal fairly with the Institute’s customers, suppliers, competitors and employees. None should take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or any other unfair-dealing practice.
    • 8.0 Accurate Institute records
      It is important that the Institute maintain accurate and reliable records that meet applicable legal, financial, regulatory and management requirements. Each employee and officer has a responsibility to ensure all Institute records, such as accounts, reports, bills, invoices, work and timekeeping records, and correspondence are accurate and maintained in accordance with the applicable document and data retention policies of his/her applicable business area.
    • 9.0 Confidential Institute information
      The Institute’s President, Executive Director and Accountant are responsible for ensuring that the Institute’s financial statements, public reports and communications contain disclosure that is full, fair, accurate, timely and understandable. In that regard, these Officers are responsible for establishing and maintaining effective disclosure controls and procedures and internal controls and procedures for financial reporting.
    • 10.0 Reporting violations
      Confidential information is any non-public information that – if disclosed – would be damaging to the best interests of the Institute or might be of use to competitors. Each employee, officer and Council member has a responsibility to hold all confidential information obtained from the Institute or its customers in confidence, except when disclosure is authorized or legally mandated. Confidential information should not be shared with the media, competitors or any other third parties.
    • 11.0 Granting and disclosing waivers
      If an employee or officer knows about or suspects misconduct, illegal activities, fraud, misuse of Institute assets or violations of Institute policies, he/she has a duty to report his/her concerns. Employees are encouraged to report any such concerns to their immediate supervisor. There will be no retribution against any employee making such a report in good faith.
    • 12.0 Administration of Code of Ethics
      Any waiver of the provisions of this Code may be made only by the Advisory Council to which such responsibility has been delegated. Any waiver of the provisions of this Code must be publicly disclosed in a prompt manner.
    • 13.0 Retaliation
      The Institute’s Executive Director is responsible for ensuring that the Institute’s Ethics Program functions effectively within his or her area of responsibility and for ensuring that the Code of Ethics is effectively communicated to employees and implemented on an ongoing basis.
    • 14.0 Confidential Institute information
      It is a violation of this policy for any Institute employee, officer or Council member to retaliate or discriminate, directly or indirectly, or encourage others to do so, against an individual who reports a suspected violation or provides information relevant to an investigation of any conduct which the individual reasonably believes to be a violation of applicable laws, regulations, or Institute policies.
    • 15.0 Violations
      The Institute will investigate any violation or suspected violation of this Code and take appropriate corrective action. Disciplinary action may include termination, referral for criminal prosecution, and/or reimbursement to the Institute for any losses or damages resulting from violations of the Code of Ethics. Examples of violations include:

      • Authorizing or participating in actions which violate applicable laws, regulations, or Institute policies.
      • Failing to report a violation or willfully withholding relevant and material information concerning a violation.
      • Retaliating against individuals who report or assist in investigations of suspected violations of applicable laws, regulations, or Institute policies.
    • 16.0 Privacy Policy
      BCM Institute has a firm commitment to privacy. This privacy policy covers all personal information that we hold.

      Collection of information
      Whenever we collect personal information from you we will do so in a lawful and fair way. We will also advise you how and where to contact us.

      If we collect the information from a third party we will take reasonable steps to advise you of that collection promptly.

      We will tell you why we are collecting the information and the third parties to whom we usually disclose that information.

      If you do not wish to provide the information we request, we will tell you what impact this will have.
      Quality of information
      We will take reasonable steps to ensure that the information that we collect, use and disclose is accurate, complete and up to date.

      Security
      We are committed to protecting your privacy and will take reasonable steps to ensure that the information we collect is
      protected from loss and misuse and from unauthorised access, modification and disclosure.

      Availability of policy
      This policy is available upon request. It will be reviewed from time to time and any amendments will be included in the
      updated policy.