USAID ALUMNI ASSOCIATION
ETHICS AND CONFLICT OF INTERESTS POLICY
The USAID Alumni Association (UAA) offers opportunities for USAID alumni to use their experience and expertise for professional counsel and public education in support of U.S. foreign assistance and to promote effective global development. UAA members and other USAID alumni who may participate in activities sponsored or endorsed by UAA are subject to applicable post-employment restrictions for US Government employees and may also be subject to ethical codes of their current employers or professional associations. All USAID alumni are expected to act in accordance with the highest standards of honesty, integrity, impartiality and conduct.
In addition, responsibility for the governance and management of UAA is entrusted to members of the UAA Board of Directors, co-chairs of UAA Committees, and other persons as may be expressly authorized by the Board of Directors. These individuals represent UAA with USAID and other entities and individuals and may take other actions affecting the policies and operations of UAA. This Ethics and Conflict of Interests Policy is intended to assure the highest level of ethical conduct by persons so engaged in the governance and management of UAA and to avoid the misuse, or perception of misuse, of such a person’s position of influence.
UAA Board members, Committee co-chairs, or other person expressly authorized by the Board to act on behalf of UAA (all of whom are hereinafter referred to as “UAA Representatives”) owe a duty of loyalty to UAA. In serving the Association they act, not in their own personal interests, nor in the interests of other entities or individuals, but solely in the interests of UAA. They are obliged not to use their positions or information they obtain about UAA or its policies or operations in any manner that would allow them to secure any material benefit for themselves or for any third party.
A UAA Representative who believes he or she has a conflict of interests or a possible appearance of a conflict of interests shall immediately notify the UAA Co-Chairs in writing. A conflict exists when the interests of the UAA Representative or any individual, group or entity with which the UAA Representative is affiliated may be seen as competing with the interests of UAA or may impair such UAA Representative’s duty of loyalty to UAA.
A conflict of interests or the possible appearance of a conflict may arise from circumstances such as, for example, where the UAA Representative:
– has a business or financial interest in a third party dealing with UAA;
– receives gifts from a third party on the basis of his or her position with UAA;
– makes representations on behalf of UAA to a third party while also having a separate personal, financial or business interest in the subject matter of the representations in question; or
– engages in employment or other affiliation that competes with UAA activities, implies UAA sponsorship or support, or involves representations to third parties inconsistent with policies or positions he or she has a duty to represent on behalf of UAA.
The Board of Directors shall decide on the appropriate disposition of all reported conflicts of interests and the Board’s decision shall be reported in the minutes of the meeting at which the decision was made. The UAA Representative concerned will not participate in the decision.
All UAA Representatives will be asked to sign an acknowledgement of this Policy and the signed acknowledgements will constitute records of UAA.
RELATION TO LAWS AND REGULATIONS
This Policy is intended to provide guidance to UAA Representatives as they perform their fiduciary duties to the Association. It supplements, but is not intended to supersede, duties set out in applicable state or federal laws or regulations. In this regard, questions about laws and regulations concerning USAID may be brought to the attention of USAID’s Office of General Counsel for guidance.
Adopted by the UAA Board of Directors
February 16, 2012