CODE OF CONDUCT, ETHICS ​& CONFLICT OF INTEREST POLICY

"There's Room for Everyone in SWIC"

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SouthWest Improvement Council
SouthWest Neighborhood Housing
Rio de Esperanza LLLP; RDE Corporación

CODE OF CONDUCT
The People of SouthWest Denver, our clients, and our supporters expect you personally and SWIC corporately to act for the benefit of the people we serve, and not to favor a few individuals or yourself.

As a general rule, you should avoid situations where your private interests—financial, or non-financial—may affect or appear to affect your objectivity, independence or honesty in performing your duties, whether voluntary or paid. You are personally accountable for your behavior in the course of your activities with and for SWIC.  
All employees, volunteers and Board Members are expected to conduct their duties with the highest levels of personal integrity. 
Staff members and Board members are not allowed to be clients of SWIC’s programs, including but not limited to housing counseling programs.

1.  SWIC strictly prohibits the solicitation and acceptance of gifts or gratuities for personal benefit by officers, employees, and or/other representatives of SWIC.
   1. Token appreciation and holiday reminders from clients of less than $25 that were not solicited by the recipient are permissible.
   2.  The memo is posted next to the Time Clock
   3. This memo will be reviewed with all new hires within their first two weeks of employment.
   4. Each employee is to retain a copy of this memo in their files.
2. Penalties for violation of our Code of Conduct
   1.  Employees will be subject to disciplinary action by Management, up to and including Termination of Employment. Employees who dispute disciplinary action have access to the Grievance Procedures outlined in the Staff Union Contract. A copy of the Union contract is available in the SWIC offices, or, from your Union Representative.
   2. Volunteers will be subject to disciplinary action by Management. Up to and including Termination of Volunteer Assignment.  Volunteers who dispute disciplinary action have access to the Client and Volunteer Grievance Procedure posted in the Dining Center.  A copy is available for your personal files upon request.

CONFLICTS OF INTEREST
Conflict of interest situations often arise during the course of nonprofit public service
What is a Conflict of Interest?
A conflict of interest occurs when you take “direct, official action” on a matter of SWIC business or service in which you, or your immediate family member, have a “substantial financial, contractual or employment interest”.    Immediate family includes husband, wife, domestic partner, son, daughter, stepchildren, mother, father, grandmother, brother, sister, grandchildren, step-grandchildren, and direct descendants.

HOW DO I KNOW IF I HAVE A CONFLICT OF INTEREST? 
When all three of the following occur:

1.  You take direct official action on a matter of SWIC business; AND
2. The result of this action affects you or your immediate family member’s financial, contractual, or employment interest; AND
3. This interest is substantial

DIRECT OFFICIAL ACTION INCLUDES:        

1. Negotiating, approving, disapproving, administering, enforcing, or recommending for or against a contract, purchase, lease, concession, franchise, grant, contribution, loan,  or other financial instrument to which SWIC entities are a party .
2. Enforcing SWIC entity policies, procedures, or resource distributions.
3. Selecting or recommending vendors or other types of entities to do business with SWIC entities.
4. Appointing or terminating employees, temporary workers, and independent contractors.
5. Representing or scheduling a SWIC officer, employee or volunteer in allocating SWIC time and/or resources.

YOU HAVE A SUBSTANTIAL INTEREST IN A SWIC ENTITY MATTER IF:

1. You or an immediate family member, are a party to the instrument;
2. Your, or your spouse/domestic partner, own 1% or more, or another family member owns 5% or more of another party to the instrument;
3. You, or an immediate family member, are an officer in another party to the instrument;
4. You, or an immediate family member, are directly involved in obtaining a SWIC entity’s business for another party to the instrument;
5. You or an immediate family member are directly involved in negotiating the contract or preparing the bid, proposal, response to requests for qualifications/proposals, or similar document(s) for another party to the instrument; or
6. An immediate family member performs, supervises, or manages more than a nominal portion of the work required by the instrument.

WHAT DO I DO IF I HAVE A CONFLICT OF INTEREST?
If a Conflict of Interest exists, you must announce that you have a Conflict of Interest, and you must not take direct action on behalf of SWIC in the matter.
 
If you are in doubt as to whether or not you have a Conflict of Interest and/or how to proceed, contact the Board President (Board Members),  or; Executive Director (staff, program participants/clients, volunteers).
Jan Marie Belle, Executive Director
SouthWest Improvement Council SWIC and Related Corporate Entities

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