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Ethics Policy

This policy sets out the role of the World Commerce & Contracting (WorldCC) Ethics Committee and the process for handling ethics issues and roles and responsibilities with regard to reporting and resolution.

WorldCC seeks to operate in a clear and transparent manner, fostering a culture of integrity and accountability across its membership. The WorldCC Ethics Committee is responsible for conducting reviews when a breach of the Association's by-laws, policies, and controls occurs or where an allegation of impropriety is raised. It will also oversee and review any disciplinary action taken against any individual, member or organization to ensure equality and fairness prevails.

WorldCC Staff and Representatives

WorldCC requires directors, officers and employees to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. As employees and representatives of the WorldCC, we must all practice honesty and integrity in fulfilling our responsibilities and comply with all applicable laws and regulations.

WorldCC requires staff and representatives to operate in accordance with the ethical standards set out in the Code of Conduct for WorldCC Staff, Contractors, Board of Directors and Representatives dated January 2018. All staff and members of the association are required to operate in accordance with the ethical standards set out in WorldCC published Code of Conduct.

Ethics Committee

The Ethics Committee has been convened and appointed as a “Standing Committee” as set out in Article IV Section 12 of the Bylaws.

The Ethics Committee is responsible for regularly reviewing the guidelines and policies for behavior and conduct across WorldCC and addressing any issues that may arise from conflicts or disclosures between employees, advisors, members, or third parties. In such cases, the Ethics Committee may step in as the arbiter of conflicts and find solutions that can be integrated into WorldCC controls or policies.

Members of the Ethics Committee will be appointed each year at the WorldCC Board and Strategy Meeting, held in January or February following the annual WorldCC Board Elections. A nominated Board Member will hold the position of the Head of the Ethics Committee and the WorldCC HR Director (Compliance Officer) will maintain a permanent place on the Ethics Committee. The Committee will report to the Chair of the Board and the CEO and will formally submit to the WorldCC Board of Directors an independent report and recommendations relating to any issues raised to the Committee.

The Ethics Committee shall meet at least once per annum to review the policy and otherwise as may be required to support any escalations. Formal minutes of the meetings shall be kept and provided to the Chair of the Board and CEO to support good governance and transparency. The outgoing Chair of the Ethics Committee shall provide a formal report to the Board of Directors at the WorldCC Board and Strategy Meeting summarising any activities and outcomes from the previous year.

Reporting Responsibility

This Policy is intended to encourage and enable members and employees to raise serious concerns internally so that WorldCC can address and correct inappropriate conduct and actions. It is the responsibility of all Board Members, Officers, employees, volunteers and members to report concerns about violations of WorldCC's Code of Conduct or suspected violations of law or regulations that govern WorldCC's operations.

No Retaliation or Retribution

It is contrary to the values of WorldCC for anyone to retaliate against any Board Member, Officer, employee, volunteer or member who in good faith reports an ethics violation, or a suspected violation of law, such as a complaint of discrimination, or suspected fraud, or suspected violation of any regulation governing the operations of WorldCC. An WorldCC employee who retaliates against someone who has reported a violation in good faith is subject to discipline up to and including termination of employment.

Reporting Procedure

With regard to employees or other staff/contractors, WorldCC has an open-door policy and encourages individuals to share their questions, concerns, suggestions or complaints with their manager. Should an individual not feel comfortable speaking their respective line manager, or where an individual is not satisfied with their manager’s response, an escalation should be raised with the HR Director or CEO.

Any complaints or concerns about suspected ethical and legal violations should be reported in writing using the dedicated mailbox ethics@worldcc.com which is to be managed by the HR Director who has the responsibility to investigate all reported complaints.

Complaints received directly by any Board member about other WorldCC Board Members, Officers or WorldCC staff must be referred back to the HR Director and the Chair of the Ethics Committee to allow appropriate investigation and confirmation of intended action. Complaints by or about WorldCC Members will in the first instance be referred to the CEO or the HR Director to allow investigation before passing through to the Chair of the Ethics Committee for review and confirmation of intended action.

Compliance Officer

The HR Director will fulfill the role of Compliance Officer and is responsible for ensuring that all complaints about unethical or illegal conduct are investigated and resolved. The Compliance Officer will advise the CEO of all complaints and their resolution and will report at least annually to the Chair of the Ethics Committee on compliance activity including that relating to accounting or alleged financial improprieties. At their discretion, the Compliance Officer may also elect to consult with the Ethics Committee on the handling of any individual complaint by or about an employee of the Association.

Acting in Good Faith

Anyone filing a written complaint concerning a violation or suspected violation must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation. Any allegations that prove not to be substantiated and which proves to have been made maliciously or knowingly to be false will be viewed as a serious disciplinary offense.

Confidentiality

Violations or suspected violations may be submitted on a confidential basis by the complainant. Reports of violations or suspected violations will be kept confidential and anonymized to the extent possible, consistent with the need to conduct an adequate investigation.

Handling of Reported Violations

The Compliance Officer will notify the person who submitted a complaint and acknowledge receipt of the reported violation or suspected violation. All reports will be promptly investigated and appropriate corrective action will be taken if warranted by the investigation.

This policy is owned by the WorldCC Compliance Officer and endorsed by the Chair of the Ethics Committee.

Last reviewed on 12 May 2019.

Policy approved by the Board of Directors on 12 May 2019.