Statement of Our Core Values
As an LOA employee, we are responsible for adding value to the organization and contribute to the ethical success of LOA. Advocating for the agency by engaging in activities that enhance its credibility and value. Among those values include:
(a) Employees should act to expand choice and opportunity for older persons.
(b) Employees should promote conditions that encourage respect for older persons and advocate for programs and institutions that demonstrate and promote policies that safeguard the rights of and confirm equity for all older persons.
(c) Employees should act to prevent and eliminate exploitation, discrimination or abuse of any person 60 years or older.
Build Trust and Credibility
The success of our business is dependent on the trust and confidence we earn from our employees clients and community. We gain credibility by adhering to our commitments, displaying honesty and integrity and reaching Agency goals solely through honorable conduct. It is easy to say what we must do, but the proof is in our actions. Ultimately, we will be judged on what we do.
When considering any action, it is wise to ask: will this build trust and credibility for The Local Office on Aging, Inc.? Will it help create a working environment in which The Local Office on Aging, Inc. can succeed over the long term? Is the commitment I am making one I can follow through with? The only way we will maximize trust and credibility is by answering, “yes” to those questions and by working every day to build our trust and credibility.
Respect for the Individual
We all deserve to work in an environment where we are treated with dignity and respect. The Local Office on Aging, Inc. is committed to creating such an environment because it brings out the full potential in each of us, which, in turn, contributes directly to our business success. We cannot afford to let anyone’s talents go to waste.
The Local Office on Aging, Inc. is an equal employment/affirmative action employer and is committed to providing a workplace that is free of discrimination of all types from abusive, offensive or harassing behavior. Any employee who feels harassed or discriminated against should report the incident to his or her manager or to human resources.
Create a Culture of Open and Honest Communication
At The Local Office on Aging, Inc. everyone should feel comfortable to speak his or her mind, particularly with respect to ethics concerns. Managers have a responsibility to create an open and supportive environment where employees feel comfortable raising such questions. We all benefit tremendously when employees exercise their power to prevent mistakes or wrongdoing by asking the right questions at the right times.
The Local Office on Aging, Inc. will investigate all reported instances of questionable or unethical behavior. In every instance where improper behavior is found to have occurred, the Agency will take appropriate action. We will not tolerate retaliation against employees who raise genuine ethics concerns in good faith.
For your information The Local Office on Aging, Inc.’s whistleblower policy is as follows:
The Sarbanes-Oxley Act provides protections for whistle blower and criminal penalties for actions taken in retaliation against whistle blowers. The Act protects employees who risk their careers by reporting suspected illegal activities in the organization. Illegal activities may include corporate fraud, unethical business conduct, a violation of State or Federal law, or substantial and specific danger to an employee’s health and safety. It is illegal for a corporate entity to punish the whistle blower in any manner. No employee will be penalized, formally or informally, for voicing a complaint in a reasonable business like manner, or for filing a complaint. If a situation occurs wherein employees believe that a condition of employment or a decision affecting them is unjust or inequitable, they are encouraged to report the condition to their immediate supervisor, if the report involves their immediate supervisor, the report may be taken up the chain of command to the Program Manager, Human Resource Director or Executive Director. In the event the report involves the Executive Director, it can be taken up with the Board of Directors.
Employees are encouraged, in the first instance, to address such issues with their managers or the HR Director, as most problems can be resolved swiftly. If for any reason that is not possible or if an employee is not comfortable raising the issue with his or her manager or HR, The Local Office on Aging, Inc. The Executive Director does operate with an open-door policy.
Set Tone at the Top
Management has the added responsibility for demonstrating, through their actions, the importance of this Code. In any business, ethical behavior does not simply happen; it is the product of clear and direct communication of behavioral expectations, modeled from the top and demonstrated by example. Again, ultimately, our actions are what matters.
To make our Code work, managers must be responsible for promptly addressing ethical questions or concerns raised by employees and for taking the appropriate steps to deal with such issues. Managers should not consider employees’ ethics concerns as threats or challenges to their authority, but rather as another encouraged form of business communication. At The Local Office on Aging, Inc., we want the ethics dialogue to become a natural part of daily work.
Uphold the Law
The Local Office on Aging, Inc.’s commitment to integrity begins with complying with laws, rules and regulations where we do business. Further, each of us must have an understanding of the Agency policies, laws, rules and regulations that apply to our specific roles. If we are unsure of whether a contemplated action is permitted by law or The Local Office on Aging, Inc. policy, we should seek the advice from the resource expert. We are responsible for preventing violations of law and for speaking up if we see possible violations. Because of the nature of our business, some legal requirements warrant specific mention here.
It is important that we respect the property rights of others. We will not acquire or seek to acquire improper means of a competitor’s trade secrets or other proprietary or confidential information. We will not engage in unauthorized use, copying, distribution or alteration of software or other intellectual property.
We will not selectively disclose (whether in one-on-one or small discussions, meetings, presentations, proposals or otherwise) any material nonpublic information with respect to The Local Office on Aging, Inc., its securities, business operations, plans, financial condition, results of operations or any development plan. We should be particularly vigilant when making presentations or proposals to the general public to ensure that our presentations do not contain material with nonpublic information.
Health and Safety
The Local Office on Aging, Inc. is dedicated to maintaining a healthy environment. A safety manual has been designed to educate you on safety in the workplace. If you do not have a copy of this manual, please see your HR department.
Avoid Conflicts of Interest
Conflicts of Interest
We must avoid any relationship or activity that might impair, or even appear to impair, our ability to make objective and fair decisions when performing our jobs. At times, we may be faced with situations where the business actions we take on behalf of The Local Office on Aging, Inc. may conflict with our own personal or family interests because of the course of action that is best for us personally may not also be the best course of action for The Local Office on Aging, Inc. We owe a duty to The Local Office on Aging, Inc. to advance its legitimate interests when the opportunity to do so arises. We must never use The Local Office on Aging, Inc. property or information for personal gain or personally take for ourselves any opportunity that is discovered through our position with The Local Office on Aging, Inc.
Here are some other ways in which conflicts of interest could arise:
Determining whether a conflict of interest exists is not always easy to do. Employees with a conflict of interest question should seek advice from management. Before engaging in any activity, transaction or relationship that might give rise to a conflict of interest, employees must seek review from their managers or the HR department.
Gifts, Gratuities and Business Courtesies
The Local Office on Aging, Inc. is committed to competing solely on a merit of our products and services. We should avoid any actions that create a perception that favorable treatment of outside entities by The Local Office on Aging, Inc. was sought, received or given in exchange for personal business courtesies. Business courtesies include gifts, gratuities, meals, refreshments, entertainment or other benefits from persons or companies with whom The Local Office on Aging, Inc. does or may do business. We will neither give nor accept business courtesies that constitute, or could reasonably be perceived as constituting, unfair business inducements that would violate law, regulation or polices of The Local Office on Aging, Inc. or customers, or would cause embarrassment or reflect negatively on The Local Office on Aging, Inc.’s reputation.
Accepting Business Courtesies
Most business courtesies offered to us in the course of our employment are offered because of our positions at The Local Office on Aging, Inc. We should not feel any entitlement to accept and keep a business courtesy. Although we may not use our position at The Local Office on Aging, Inc. to obtain business courtesies, and we must never ask for them, we may accept unsolicited business courtesies that promote successful working relationships and good will with the firms that The Local Office on Aging, Inc. maintains or may establish a business relationship with.
Employees who award contracts or who can influence the allocation of business, who create specifications that result in the placement of business or who participate in negotiation of contracts must be particularly careful to avoid actions that create the appearance of favoritism or that may adversely affect the Agency’s reputation for impartiality and fair dealing. The prudent course is to refuse a courtesy from a supplier when The Local Office on Aging, Inc. is involved in choosing or reconfirming a supplier or under circumstances that would create an impression that offering courtesies is the way to obtain The Local Office on Aging, Inc. business.
Meals, Refreshments and Entertainment
We may accept occasional meals, refreshments, entertainment and similar business courtesies that are shared with the person who has offered to pay for the meal or entertainment, provided that:
Employees may accept unsolicited gifts, other than money, that conform to the reasonable ethical practices of the marketplace, including:
Generally, employees may not accept compensation, honoraria or money of any amount from entities with whom The Local Office on Aging, Inc. does or may do business. Tangible gifts (including tickets to a sporting or entertainment event) that have a market value greater than $25 may not be accepted unless approval is obtained from management.
Employees with questions about accepting business courtesies should talk to their managers or the HR department.
Offering Business Courtesies
Any employee who offers a business courtesy must assure that it cannot reasonably be interpreted as an attempt to gain an unfair business advantage or otherwise reflect negatively upon The Local Office on Aging, Inc. An employee may never use personal funds or resources to do something that cannot be done with The Local Office on Aging, Inc. resources. Accounting for business courtesies must be done in accordance with approved Agency procedures.
Other than to our government customers, for whom special rules apply, we may provide nonmonetary gifts (i.e., Agency logo apparel or similar promotional items) to our customers. Further, management may approve other courtesies, including meals, refreshments or entertainment of reasonable value, provided that:
Set Metrics and Report Results Accurately
Accurate Public Disclosures
We will make certain that all disclosures made in financial reports and public documents are full, fair, accurate, timely and understandable. This obligation applies to all employees, including all financial executives, with any responsibility for the preparation for such reports, including drafting, reviewing and signing or certifying the information contained therein. No business goal of any kind is ever an excuse for misrepresenting facts or falsifying records.
Employees should inform the Executive Director, Program Managers and the HR department if they learn that information in any filing or public communication was untrue or misleading at the time it was made or if subsequent information would affect a similar future filing or public communication.
We create, retain and dispose of our Agency records as part of our normal course of business in compliance with all The Local Office on Aging, Inc. policies and guidelines, as well as all regulatory and legal requirements.
All corporate records must be true, accurate and complete, and Agency data must be promptly and accurately entered in our books in accordance with The Local Office on Aging, Inc.’s and other applicable accounting principles.
We must not improperly influence, manipulate or mislead any unauthorized audit, nor interfere with any auditor engaged to perform an internal independent audit of The Local Office on Aging, Inc. books, records, processes or internal controls.
Promote Substance Over Form
At times, we are all faced with decisions we would rather not have to make and issues we would prefer to avoid. Sometimes, we hope that if we avoid confronting a problem, it will simply go away.
At The Local Office on Aging, Inc., we must have the courage to tackle the tough decisions and make difficult choices, secure in the knowledge that The Local Office on Aging, Inc. is committed to doing the right thing. At times this will mean doing more than simply what the law requires. Merely because we can pursue a course of action does not mean we should do so.
Although The Local Office on Aging, Inc.’s guiding principles can not address every issue or provide answers to every dilemma, they can define the spirit in which we intend to do business and should guide us in our daily conduct.
Each of us is responsible for knowing and adhering to the values and standards set forth in this Code and for raising questions if we are uncertain about Agency policy. If we are concerned whether the standards are being met or are aware of violations of the Code, we must contact the HR department.
The Local Office on Aging, Inc. takes seriously the standards set forth in the Code, and violations are cause for disciplinary action up to and including termination of employment.
Confidential and Proprietary Information
Integral to The Local Office on Aging, Inc.’s business success is our protection of confidential Agency information, as well as nonpublic information entrusted to us by employees, customers and other business partners. Confidential and proprietary information includes such things as pricing and financial data, customer names/addresses or nonpublic information about other companies, including current or potential supplier and vendors. We will not disclose confidential and nonpublic information without a valid business purpose and proper authorization.
Use of Agency Resources
Agency resources, including time, material, equipment and information, are provided for Agency business use. Nonetheless, occasional personal use is permissible as long as it does not affect job performance or cause a disruption to the workplace.
Employees and those who represent The Local Office on Aging, Inc. are trusted to behave responsibly and use good judgment to conserve Agency resources. Managers are responsible for the resources assigned to their departments and are empowered to resolve issues concerning their proper use.
Generally, we will not use Agency equipment such as computers, copiers and fax machines in the conduct of an outside business or in support of any religious, political or other outside daily activity, except for Agency-requested support to nonprofit organizations. We will not solicit contributions nor distribute non-work related materials during work hours.
In order to protect the interests of The Local Office on Aging, Inc. network and our fellow employees, The Local Office on Aging, Inc. reserves the right to monitor or review all data and information contained on an employee’s Agency-issued computer or electronic device, the use of the Internet or The Local Office on Aging, Inc.’s intranet. We will not tolerate the use of Agency resources to create, access, store, print, solicit or send any materials that are harassing, threatening, abusive, sexually explicit or otherwise offensive or inappropriate.
Questions about the proper use of Agency resources should be directed to your manager.
The Local Office on Aging, Inc. is a high-profile Agency in our community, and from time to time, employees may be approached by reporters and other members of the media. In order to ensure that we speak with one voice and provide accurate information about the Agency, we should direct all media inquiries to the Director of Public Relations and/or Executive Director. No one may issue a press release without first consulting with the Director of Public Relations.
Do the Right Thing
Several key questions can help identify situations that may be unethical, inappropriate or illegal. Ask yourself:
In order to safeguard the activities and assets of the Local Office on Aging, Inc., employees of The Local Office on Aging, Inc. should not have interests in outside businesses which conflict or appear to conflict with their ability to act and make independent decisions in the best interest of the Local Office on Aging, Inc.
An employee is considered to have an interest in an outside business if the employee or any member of his/her immediate family holds any ownership in the business or its property; furnishes goods or services to the business; is a creditor, employee, agent, officer, director, or consultant of the business. Outside businesses include any person, firm, corporation, or government agency that sells or provides a service to, purchases from, or competes with the Local Office on Aging, Inc.
At the time of hire, and periodically thereafter as requested, all employees will be required to complete an Agreement concerning ethical standards of conduct & conflict of interest. Periodic checks will be conducted by the Human Resources Department to determine changes that have occurred; however, all employees are expected to exercise good judgment and discretion in evaluating a particular activity so as to avoid any actual, or apparent, conflict of interest. If there is a doubt, the employee should discuss it with his/her supervisor and/or the Director of Human Resources.
Excluded are investments in the securities of a bank, public utilities, and transportation companies subject to regulations by government authority or a mutual fund or investment Agency registered under the Investment Agency Act. Also are securities listed on a national securities exchange or customarily bought and sold at least once a week in the over-the-counter market or in which the employee and/or his or her family have less than $10,000 invested, at cost or market value, or hold less than one percent of such outstanding securities.
The Local Office on Aging, Inc. expects its employees to observe the highest standards of business ethics.
No employee should take any action on behalf of the Agency that they know, or reasonably should know, violates any applicable law or regulation. This obviously includes such activities as bribery, kickbacks, falsehoods, and misrepresentation.
The Local Office on Aging, Inc. prohibits all employees from accepting gifts, gratuities, or entertainment from individuals and firms with whom the Local Office on Aging, Inc. does business. It is also a violation to give gifts to individuals or firms with whom The Local Office on Aging, Inc. does business. Excluded from this prohibition is the exchange of normal business courtesies such as luncheons or dinners, when they are proper and consistent with regular business practice. Also excluded are advertising or promotional materials and holiday or other gifts, which are of nominal value (less than $25.00).
Failure to comply with the aforementioned provisions may result in corrective action, up to and including termination of employment.