MGIC - Ethics and Conduct Policy

Ethics and Conduct

Purpose

The purpose of this policy is to ensure that all activities of the Maryland Global Initiatives Corporation (MGIC) are carried out with integrity, transparency, and compliance, by all individuals participating in the activities of MGIC. It also establishes Codes of Conduct for ethical behavior and accountability of MGIC Personnel, Directors and Officers of the MGIC Board of Directors, MGIC Contractors, and MGIC Grantees. It provides guidance for preventing misconduct, promoting responsible decision-making, safeguarding vulnerable populations, and maintaining a safe, equitable, and respectful work environment.

Background

MGIC has developed two distinct codes (presented below) to guide ethical behavior and professional standards of individuals retained by MGIC in different capacities as well as individuals responsible for corporate governance. The Code of Ethics and Conduct for Personnel outlines the expectations for individual conduct of all MGIC employees and Members and Officers of the Board. The Code of Ethics and Professional Conduct for Business Practices establishes standards for ethical business operations and practices by contractors and grant recipients of MGIC. Together, these codes serve as the foundation for maintaining integrity and professionalism throughout all activities associated with MGIC.

The two codes apply to the following individuals:

• MGIC Personnel (employees)
• UMB Personnel serving on the MGIC Board of Directors in the capacity of MGIC Director or MGIC Officer
• Contractors and suppliers (vendors and providers of goods and services to MGIC)
• MGIC Grantees (recipients of Funding Agreements issued by MGIC)

The International Operations (IO) division of UMB’s Administration and Finance department administers the MGIC mechanism and oversees the application of and compliance with this policy.

Policy Statement

General Requirements

1. MGIC Codes of Ethics and Conduct incorporate applicable laws and policies of the jurisdictions in which it operates, and ethical standards and best practices of the University System of Maryland (USM), University of Maryland, Baltimore (UMB), and the MGIC Board of Directors.
2. Upon the hiring or contractual engagement of MGIC personnel or vendors, or the issuance of policy updates, the IO division will provide all relevant individuals with prompt access to the appropriate Code on behalf of MGIC.
3. MGIC Directors, Officers, and IO personnel administering the MGIC mechanism will hold all individuals accountable for adhering to the appropriate codes, as well as adhering to local laws and regulations related to ethics and conduct.
4. MGIC provides various reporting options, including anonymous channels, and maintains a zero-tolerance policy regarding retaliation against those who report suspected wrongdoing.
5. MGIC Directors, Officers, and MGIC personnel will cooperate fully with UMB-authorized investigations, and the IO division will support these investigations as necessary.
6. IO will provide guidance to MGIC personnel, users, and administrators, to ensure all individuals remain proficient in these ethical codes.

Policy Statement: Code of Ethics and Conduct for Personnel

1. In fulfilling the responsibilities of their positions or assignments, all MGIC personnel, and UMB personnel in the capacity of MGIC Board of Directors Member (Director) or Officer, are expected to adhere to and act in accordance with this Code of Ethics and Conduct for Personnel, and with all laws, rules, regulations, policies, and procedures applicable to their MGIC activities. This Code reflects the requirements of laws and policies that relate to ethical conduct, including any MGIC corporate policies that relate to reporting known or reasonably suspected wrongdoing:
   MGIC expects and requires all MGIC Personnel, MGIC Directors, and MGIC Officers, to:
   • Uphold the highest standards of intellectual honesty and integrity in teaching, research, service, and administrative activity, and seek guidance, as needed, concerning the application of ethical standards to their activities.
   • Act as good stewards of the resources entrusted to MGIC’s care and comply with financial requirements and internal controls applicable to funds and property managed or overseen by them.
   • Comply with all laws, rules, regulations, policies, procedures, and professional standards applicable to their employment and their responsibilities and cooperate with training and continuing education initiatives to make them aware of their responsibilities.
   • Comply with their assigned or assumed responsibilities to fulfill MGIC’s obligations under contracts, grants, and other legal agreements.
   • Disclose and avoid improper or unlawful conflicts of interest and conflicts of commitment.
   • Report known or reasonably suspected wrongdoing; refrain from retaliating against those who report known or reasonably suspected wrongdoing; and cooperate fully with authorized investigations of reports of wrongdoing.
2. This Code does not address every situation or ethical dilemma that may be faced by MGIC Directors, Officers, or Personnel in the course of their MGIC employment or role. Each person is expected to exercise good judgement absent specific guidance from this Code or other policies and procedures. Each person is expected to consult their supervisor, the Assistant Vice President of International Operations (in their capacity as MGIC Vice President – Policy & Administration), or other resource if the appropriate course of action is not clear.
3. Violation of this Code may result in disciplinary action, including termination of appointment, employment, or engagements for MGIC officers, Contractors, Grantees, and personnel. Violations that are criminal offenses will be referred for prosecution under applicable law.
4. The MGIC Board of Directors has authorized the IO division to educate MGIC Personnel, Directors and Officers concerning this Code and related policies and laws. MGIC Personnel may be required to participate in periodic training concerning this Code and related policies and laws. Evaluations of MGIC Personnel’s understanding of this Code and related policies and laws may be part of the training program.

Policy Statement: Code of Ethics and Professional Conduct for Ethical Business Practices

1. MGIC Contractors (vendors and suppliers of goods and services), MGIC Grantees, and their employees, agents, and representatives agree to abide by this Code of Ethics and Professional Conduct:
2. No employee, officer, or agent of Contractor/Grantee shall participate in the selection, award, or administration of any contract supported by MGIC funds if a conflict of interest arises. A conflict of interest will be deemed to exist if the Contractor/Grantee or any of its agents, employees, officers, any immediate or extended family members, partners, or an organization which employs or is about to employ any of the parties indicated herein, has a financial or other interest in the firm, individual, or organization selected for an award or contract.
3. The employees, officers, and agents of Contractor/Grantee shall not give, directly or indirectly, any payments to any business partner(s) or members of their immediate families, nor shall any employees, officers or agents of Contractor/Grantee use any part of MGIC Contract/Grant funds for payments to organizations in which Contractor/Grantee, its employees, officer, agents, or member(s) of their respective immediate families, have a financial interest.
4. Contractor shall not accept for Contractor’s/Grantee’s own benefit any commission, discount or similar payment in connection with activities pursuant to MGIC Contract/Grant or the discharge of Contractor’s/Grantee’s duties. Contractor/Grantee shall not engage in any business or professional activities, directly or indirectly, that would conflict with the activities assigned under MGIC Contract/Grant or any expected or anticipated future activities. Contractor/Grantee shall immediately report any potential or suspected violations of this requirement to MGIC.
5. The remuneration of Contractor/Grant hereunder shall constitute the sole remuneration in connection with an MGIC Contract/Grant. The Contractor/Grantee shall ensure that any subcontractors/subgrantees, as well as the personnel and agents of any of them, similarly, shall not receive any such remuneration.

Scope

This policy applies to all MGIC Personnel, MGIC Directors and Officers, Contractors, Grantees, and Requesting Unit personnel who supervise and/or control the activity of these individuals.

Responsibilities

1. MGIC Personnel, Directors, Officers, Contractors, and Grantees: Comply fully with all aspects of this policy and the Codes of Ethics and Conduct applicable to them.
2. International Operations (IO) staff that administer the MGIC mechanism: Develop, implement, and follow appropriate standard operating procedures to promote policy compliance, including MGIC contract terms and conditions, disclosures and acknowledgements by MGIC parties subject to this policy, and coordination with relevant third parties. Support UMB ethics reporting processes and participate in investigations of misconduct as requested by the MGIC Board of Directors. Engage local legal counsel through the MGIC mechanism as required to investigate reported policy violations in foreign jurisdictions, in compliance with applicable labor laws.
3. Assistant Vice President - IO (in their capacity as MGIC VP – Policy & Administration): Oversee IO division compliance with MGIC policies and procedures. Maintain and revise MGIC policies as necessary for business effectiveness and integrity, for MGIC Board of Directors approval.
4. MGIC President: Represent MGIC in negotiation of roles and responsibilities with UMB legal, compliance, and Requesting Unit leadership as required to address reported misconduct of MGIC Personnel, Contractors or Grantees. Participate in legal procedures as required by law.
5. MGIC Board of Directors: Approve policies and revisions to policies. Review and take action on real or potential conflicts of interest disclosed by MGIC Personnel, Directors and Officers.
6. Requesting Units: Supervise MGIC Personnel, Contractors and Grantees engaged on behalf of the Unit to promote policy compliance. Report known or reasonably suspected wrongdoing by those engaged on behalf of the Unit, and participate in investigative, disciplinary, and legal processes as required by the circumstances and/or by applicable policy or law.

Procedures

See MGIC standard operating procedures

Documentation Requirements

• MGIC Conflict of Interest disclosures
• MGIC Human Resources Handbook
• MGIC procurement and grant instruments

References

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