MGIC - Standards of Conduct for MGIC Personnel

Standards of Conduct for MGIC Personnel

Purpose

The purpose of this policy is to establish clear expectations for professional, ethical, and respectful behavior for all employees of Maryland Global Initiatives Corporation (MGIC). These standards support a productive, safe, and compliant workplace, reinforce organizational values, and ensure alignment with the MGIC Policy on Ethics and Conduct.

Background

MGIC personnel are employed through Employer of Record (EOR) service providers in countries outside the United States, on behalf of Requesting Units of the University of Maryland, Baltimore (UMB) and constituent universities that engage MGIC services through an agreement with UMB. (For purposes of MGIC policies only, these constituent universities are referred to as “Affiliate Entities”). Requesting Units directly supervise and manage the MGIC employees assigned to them, following MGIC policies and procedures.

MGIC’s Policy on Ethics and Conduct provides a Code of Ethics and Conduct for Personnel that outlines the fundamental principles governing employee behavior. This Standards of Conduct policy complements the Code by defining expectations for day-to-day conduct of MGIC personnel, addressing behaviors that may expose MGIC to legal, reputational, or operational risk, and establishing a consistent framework for managing violations.

The International Operations (IO) division of UMB’s Administration and Finance department administers the MGIC mechanism and the policies described herein.

Policy Statement

1. MGIC requires that all personnel abide by the Code of Ethics and Conduct for Personnel dictated in the Ethics and Conduct Policy, and by related standards of conduct presented in other MGIC Policies.
2. The MGIC Board of Directors is committed to protecting employee rights and has a zero-tolerance policy for violations of the Code. Anyone found to be engaging in any type of improper, unethical, or illegal behavior, violating the general standards of conduct, retaliating against a whistleblower, or violating MGIC Policies and Procedures shall be subject to disciplinary action, up to and including termination, as appropriate.

Reporting and Whistleblowing

MGIC does not permit retaliation against any person who reports known or suspected unethical behavior, violations of the standards of conduct, discrimination, harassment, or other unlawful behavior. Reports of this nature should be directed through the Ethics Hotline provided by UMB or the Affiliated Entity.  See MGIC Ethics and Conduct Policy.

Conflict of Interest

All personnel are required to avoid conflicts of interest or apparent conflicts of interest between their obligations to MGIC and their personal affairs. All MGIC personnel are required to abide by this policy in all their dealings with sponsors (institutional donors), suppliers, vendors, consultants, and other MGIC and UMB/Affiliate Entity contacts. See MGIC Ethics and Conduct Policy, as well as the MGIC Procurement Policy for additional Conflict of Interest disclosure requirements for competitive procurement activities.

Nepotism

MGIC does not permit the employment of family members in a supervisor-subordinate relationship and prohibits current employees from using their position to benefit a family member through employment or other financial gain. See Conflict of Interest in the MGIC policy on Ethics and Conduct.

Prohibition of Harassment and Discrimination

MGIC prohibits and does not tolerate any type of harassment or discrimination. MGIC does not discriminate on the basis of race, ethnicity, tribe, color, religion, age, ancestry, national origin, sex, gender, gender identity or expression, sexual orientation, pregnancy, physical or mental disability, marital status, status as a veteran, HIV status, or any other legally protected status. Harassment includes sexual misconduct, which MGIC considers a serious offense (gross misconduct), and which includes sexual and gender-based harassment, sexual violence, dating violence, domestic violence, sexual exploitation, and sexual intimidation.

Combatting Trafficking in Persons and Safeguarding Children

MGIC has zero tolerance for trafficking in people, and strictly enforces this Policy to prevent undesirable actions and imposes immediate consequences for violating it. Violation of the Child Safeguarding Policy constitutes an act of gross misconduct and is, therefore, grounds for termination.

Fraternization

Fraternization and romantic relationships among personnel is strongly discouraged, as well as romantic relationships between personnel and clients, vendors, consultants, and contractors. Avoiding fraternization helps personnel to avoid real or perceived Conflict of Interest, which must be disclosed and may be grounds for disciplinary action if personnel are found in violation of the MGIC Code of Conduct. See MGIC policy on Ethics and Conduct.

Confidentiality of sensitive data

Personnel must not publish or otherwise divulge sensitive data in whole or in part, nor authorize others to do so, unless requested by MGIC or by UMB or an Affiliate Entity as part of the person’s normal duties. Personnel must also take reasonable measures to restrict access to such information in their personal possession, including use of equipment locks, password protection, and encryption. Personnel must not use or disclose confidential and proprietary information relating to the activities or business affairs of MGIC, or UMB, or an Affiliate Entity, except as necessary to carry out MGIC duties and collaborate on program implementation and research with partner organizations. See related MGIC policies on Confidentiality and Data Protection, Procurement, and Financial Conduct and Responsibility.

Scope

This policy applies to all MGIC personnel.  Supervisors of MGIC personnel, including those employed directly by UMB or an Affiliate Entity, are required to monitor and take action on their MGIC employees’ compliance or lack thereof with this and other related MGIC policies. The policy applies at all times when personnel are performing work for or representing MGIC, at partner sites, public venues, or during virtual engagements.

Responsibilities 

1. MGIC Employees: Comply fully with all aspects of thisand related referenced policies. 
2. IO International Human Resources (HR) Manager: Obtain and file Conflict of Interest Disclosure Form, Data Confidentiality Agreement Form, and other procedural disclosures in related MGIC policies. Support maintenance of Ethics Hotline and tracking of reports as requested by UMB.
3. Assistant Vice President - IO (in capacity of MGIC VP – Policy & Administration): Oversee MGIC policy administration. 
4. Requesting Units: Comply fully with all aspects of this and related/referenced policies.  

Procedures

See MGIC Standard Operating Procedures

Documentation Requirements

• Conflict of Interest Disclosure Form, Data Confidentiality Agreement Form

References

• Ethics Hotline
• MGIC Global HR Handbook
• MGIC Policy on Ethics and Conduct
• MGIC Policy on Procurement