January 2020 - Winrock International
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January 2020
TABLE OF CONTENTS
A Message from Winrock CEO, Employee Posting on Social Media 24
Rodney Ferguson 3 Confidential Information 25
Our Shared Responsibilities 4 Intellectual Property – Ownership and Protection 25
Individual Responsibilities 4 Use and Protection of Winrock Property and Systems 26
Manager Responsibilities 5 Privacy and Personal Data Protection 27
Winrock Code of Conduct Ambassadors 5
Commitment to Beneficiaries 30
Winrock Leadership 5
Combatting Trafficking in Persons and Protection
Ask a Question or Report a Concern 6 from Sexual Exploitation and Abuse (PSEA) 30
How to Spot an Issue 6 Child Safeguarding Policy 33
How to Spot an Ethical Dilemma 7 Other topics also applicable to Beneficiaries:
Your Duty to Speak Up 7 Diversity and Inclusion
Privacy and Personal Data Protection
Channels for Asking Questions or Raising Concerns 8
Confidential Information
Winrock Hotline 8 Gender Equality
Anonymity and Confidentiality 9
Anti-Retaliation Policy 9 Commitment to Donors and Partners 36
Responsiveness and Employee Cooperation 9 Financial Integrity 36
Enforcement 10 Business Records 37
Accounting Practices 37
Exceptions to this Code 10
Anti-Corruption and Bribery 37
Code of Conduct Acknowledgment Form 11 Anti-Money Laundering and Anti-Terrorist Financing 38
Antitrust and Fair Competition 38
Commitment to Colleagues Global Trade 39
and Organization 13 Supplier, Vendor, or Consultant Relations
Diversity and Inclusion 13 and Purchasing 39
Equal Employment Opportunity (EEO) Records Management Policy 39
and Affirmative Action 14
Conflict of Interest Policy 41
Discrimination-Free Workplace 14
Hiring Members of the Same Family or Persons
Harassment-Free Workplace 14 Known to You 44
Combatting Sexual Harassment 15 Political Activities and Participation
in Candidate Elections 44
Accommodation Policy 16
Lobbying 45
Gender Equality 17
Gifts, Gratuities, and Business Courtesies 45
Drug-Free Workplace 19
Workplace Violence Prevention Policy 21 Other topics also applicable to Donors and Partners:
Confidential Information
Global Safety and Security 22
Gender Equality
Communicating on Behalf of Winrock 23
Use of the Winrock Name and Logo 24
Use of Social Media 24
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A MESSAGE FROM OUR CEO
DEAR COLLEAGUES,
Since 1985, Winrock International has been making a difference in the lives of
people around the world. The respect and confidence that they and our funders,
subcontractors and vendors have in our organization is rooted in the hard work and
integrity of our employees. Our continued success depends on each of us maintaining
the highest of standards, where each employee, Board member, volunteer, intern
and fellow, and consultant is committed to ethical behavior, honesty, and integrity.
Our shared mission is to empower the disadvantaged, increase economic opportunity
and sustain natural resources. Our mission is core not only to what we do, but also to how we do
it. For example, we must comply with all the laws wherever we work. We comply with our funders’
requirements. We also have requirements for how we conduct ourselves in the workplace, set forth
in this Code of Conduct.
Our Code of Conduct is a collection of guiding principles that are an extension of our mission. This
Code dictates how we conduct ourselves in performing this important work, and provides resources
to help us make informed decisions and act on those decisions with integrity. These principles are
required by our funders and meeting our obligations to our funders requires us to adhere to these
principles in letter and spirit. We take ethics and integrity very seriously and believe that all of us have
a duty to fully understand this Code. You should use the Code as an everyday guide to help navigate
what’s right in a particular situation and minimize legal and ethical risk.
We each have both the privilege and the responsibility of sustaining and building upon Winrock’s
reputation for excellence. To succeed in this endeavor, we must all work together to continue to get
the right results in the right way.
Knowing when to seek guidance or to speak up is also an important part of personal accountability. I
am committed to maintaining a culture where people are encouraged to seek advice, voice concerns
or report possible misconduct--and are protected from retaliation when they do so. If you have
questions or if something doesn’t seem right to you, please contact our Hotline or any of the channels
available to you under this Code, including me.
This Code needs to work for you, our valuable employees. If you have questions, concerns, or
suggestions for a better Code, please contact me directly or contact our Risk and Compliance Office.
All the best,
Rodney Ferguson
January 2019
WINROCK CODE OF CONDUCT 3OUR SHARED
RESPONSIBILITIES
At Winrock we follow the laws of every country where we work. We also
follow this Code of Conduct. Upholding Winrock’s Code of Conduct is
a responsibility shared by all involved in contributing to project results,
providing solutions, and delivering on Winrock’s mission. The Code is
mandatory and applies to each employee, Board member, volunteer,
intern and fellow, and consultant (also known as our “workforce”).
In addition to the Code, we also have Operational Policies and Pro-
cedures, which are issued by operational groups (such as Finance,
Human Resources, or Operations) that apply to specific activities or
roles. These Operational Policies and Procedures implement busi-
ness practices to achieve consistent results and efficiencies and to
minimize legal risks. Compliance with the Operational Policies and
Procedures also is a mandatory condition of employment.
Our Code and Operational Policies and Procedures are supported
by our Core Values:
• Accountability
• Equity
• Innovation
• Integrity
• Transformation
These Value reflect our shared beliefs and commitments to each
other, our supporters, and those we serve.
As noted by our CEO, Winrock is known as an organization that makes
a difference in the lives of people around the world. Our success is
based on operating with integrity, in every location, on every project.
When you operate ethically you send a message to others that they
can put their trust in us. By doing the right thing, you not only protect
our reputation, but also help Winrock thrive in today’s complex and
competitive environment.
Conduct or actions prohibited by this Code and the Operational
Policies and Procedures is unacceptable in the workplace and in any
work-related setting outside the workplace, such as during business
trips, business meetings, and business-related social events.
INDIVIDUAL RESPONSIBILITIES
You are responsible for becoming familiar with the Code of Conduct,
particularly those policies that apply to your job or your work with
Winrock. You will be doing your part when you:
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• Stay informed by learning the Code of expectations of each person at your location
Conduct, acknowledging expectations, or nearby work sites. It is a position of trust.
and participating in briefings and available You should always:
ethics and compliance training. • Lead by example and be a positive role
• Seek guidance and ask questions or model to others.
consult with others when the right course • Promote awareness of Winrock’s Code of
of action is unclear. Conduct and make sure that new hires and
• Stand firm by resisting pressure to colleagues are equipped with the knowledge
compromise our standards or policies of they need to comply with the Code.
the Code or cut ethical corners to meet an • Train colleagues in compliance and ethics
objective or complete an activity. and deliver briefings.
• Raise concerns if something does not • Be responsive by answering questions or
seem right. escalating an ethics or compliance concern.
MANAGER WINROCK LEADERSHIP
RESPONSIBILITIES Our Winrock Leadership is entrusted with
If you manage or supervise others, you have the strategic, programmatic, financial, and
been placed in a position of trust. To maintain management operations to fulfill our mission
that trust, you should always: and deliver results to empower the disadvan-
• Lead by example and be a positive role mod- taged, increase economic opportunity, and
el to others. Champion a culture of integrity. sustain natural resources in the United States
and around the world. Every Winrock leader
• Promote awareness of Winrock’s Code of
should always:
Conduct and make sure those you supervise
are equipped with the knowledge and re- • Lead by example and be a positive role
sources they need to comply with the Code. model to others.
• Monitor the conduct of those you • Provide a safe and productive workplace.
supervise and take responsibility for • Promote awareness and give voice to
activities that occur under your supervision. all stakeholders to ask questions and raise
• Be responsive to anyone who raises ethical and compliance concerns or issues.
an ethics or compliance concern. Keep • Be responsive to anyone who raises an
an open door for concerns. Escalate to ethics or compliance concern. Keep an
the Chief Risk and Compliance Officer open door for concerns. Escalate when
violations of this Code, make sure that needed, make sure that action is taken,
action is taken, and ensure concerns are and ensure concerns are resolved in a fair
resolved in a fair and appropriate manner. and appropriate manner.
Click here for more guidance. • Achieve Winrock’s commitment to integ-
rity, respect, and impact; and to the high-
WINROCK CODE OF est ethical standards, rules of law, and do-
nor expectations.
CONDUCT AMBASSADORS
As a Winrock Ambassador, you have been
selected to promote the Code of Conduct and
help your colleagues learn and understand
WINROCK CODE OF CONDUCT 5ASK A QUESTION OR
REPORT A
CONCERN
Winrock’s Code of Conduct is not intended to make you an expert on
every issue, but rather to help you spot risks, obtain guidance, and
make good choices. We must constantly be alert to gaps between
policies and practices and work to close them. Making the right
decision is not always easy. There may be times when you will be
under pressure or unsure of what to do. Always remember that when
you have a tough choice to make, you are not alone. The following
policy, also known as a Whistleblower policy, sets forth guidance
and instruction for how to report, and how Winrock commits to
responding to you.
Part of the responsibility to report is management’s responsory to
act on reports made. Our Core Value of Accountability reflects our
commitment to ensure that we take responsibility when staff speak up:
• We are fiscally responsible.
• We hold ourselves and our colleagues responsible for the
outcomes of our choices, behaviors and actions.
• We take responsibility for all outcomes, positive and negative.
The following policy, also known as a Whistleblower policy, sets
forth guidance and instruction for how to report, and how Winrock
commits to responding to you.
HOW TO SPOT AN ISSUE
Before making a decision or pursuing a course of action, consider
the following:
• Ask yourself: Does the decision or action meet the letter and
spirit of Winrock’s Core Values (especially Integrity), Code of
Conduct or Operational Policies and Procedures? Is it legal?
• If you are unsure if the Code or a policy applies, ask your manager,
your Code of Conduct Ambassador, or the Compliance Officer.
• If you suspect the decision or action violates the Code, raise it.
Do not say to yourself, “I don’t know.” You are not responsible
for investigating Code violations; you are responsible for raising
them.
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HOW TO SPOT AN
ETHICAL DILEMMA
In addition to complying with the rules—such
as the law, this Code or Operational Policies
and Procedures—we at Winrock also have a
duty to act ethically and do the “right thing.”
Sometimes that is not a clear path. If you have
a concern that you or another employee may
be acting unethically, or want to discuss an
ethical dilemma, speak up. Reach out to any
of those identified below, including the Risk
and Compliance Officer (whose duties include
ethics). Here are some red flags that may
indicate an ethical issue:
• Does it serve our Core Values of
Accountability, Equity, Innovation, Integrity,
and Transformation?
• You are ever unsure about the proper
• Are you or someone else trying to keep it
course of action and need advice.
a secret?
• Particular actions or decisions make you
• Is it something Winrock would not want
uncomfortable.
publicized in the news or on social media?
• You know or suspect that any of the
• If this decision was made public, would you
following persons have been or are about
feel comfortable explaining it to colleagues
to engage in Code violations or illegal
or even investigators?
or unethical activity in connection with
• Is your judgement impartial, or do you Winrock’s work:
have a personal stake in the outcome that
makes you less objective? • Any one in Winrock’s workforce
• What if everyone at Winrock did it—would • Vendors, suppliers, or other contractors
that be OK? or consultants
• Partners, grantees, or subcontractors
YOUR DUTY TO SPEAK UP • Agents, intermediaries, or others acting
One of the most tragic aspects of wrongdoing on behalf of Winrock
is when people look the other way or fail to
speak up. In addition to knowing the ethical
and legal obligations that apply to your job,
you are required to speak up if:
• You are aware, or suspect, a violation of
the Code of Conduct, the Operational
Policies and Procedures, or the law. Note
that a suspicion is enough – you do not
need to have all the facts or be certain.
WINROCK CODE OF CONDUCT 7CHANNELS FOR ASKING QUESTIONS OR RAISING CONCERNS
Winrock has numerous channels of communication for employees with questions, seeking advice, or
wishing to report concerns. You should choose the channel that feels the most comfortable for you.
Channel for speaking up Description
Your Manager Your direct supervisor or unit supervisor.
Your Winrock Code of
Usually a colleague and likely working in the same location.
Conduct Ambassador
Chief of Party For a project, the senior-most position at your work location or unit director
or Project Director or senior director responsive to questions or reporting a concern.
Senior-most person at work location responsible for HR functions including
HR Lead or
employee relations. Or the position which handles most HR-related
HR Focal Point
transactions locally. Another option is a Regional HR partner or manager.
Other Managers Other trusted managers and leaders at your work location can be helpful
and Leaders with advice, questions, and reporting a concern.
Chief Risk and Charlotte oversees and facilitates the review of all Code of Conduct
Compliance Officer concerns and compliance with all legal/regulatory and donor requirements,
Charlotte Young reporting to the CEO and the Board of Directors.
Our Hotline provides a means to report both by identifying yourself or
Hotline remaining anonymous, if you prefer. You can call using the telephone
(can be anonymous) or can make a report via the website. Ask for your local language if
needed.
WINROCK HOTLINE partners, clients or beneficiaries and contrac-
tors or consultants.
The Hotline is available at any time to ask
questions or raise concerns but is often If you use the telephone option, a trained
used when: specialist from EthicsPoint/Navex will make a
detailed summary of your question or concern.
• You feel uncomfortable using another
The details will be forwarded to Winrock’s Chief
channel of communication.
Risk and Compliance Officer or designated
• Other channels prove ineffective, unable to representative for further response.
respond, or appear unresponsive.
• You wish to report your concern anonymously.
VIA WEB
The Hotline is administered by EthicsPoint/
Winrock.ethicspoint.com
Navex, which is an independent third-party
that does not log or identify telephone num-
bers or computer IP addresses. It is available VIA PHONE
24 hours a day, seven days a week, in multiple Click here for a list of phone numbers
languages. It is available for use by anyone in all the places we work.
involved with Winrock including employees,
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ANONYMITY AND Winrock encourages managers and employees
to self-report violations and, depending on the
CONFIDENTIALITY specific circumstances, may treat self-reporting as
You are encouraged to provide your name when a mitigating factor when assessing any disciplinary
raising a concern. This allows those who respond to measures.
your concern to contact you if additional information
In addition to Winrock’s prohibition on retaliation,
is needed to look into your concern thoroughly.
U.S. federal law prohibits any form of retaliation
Providing your name also helps us ensure that you
against any employee as a reprisal for disclosing
do not experience retaliation for making a good-
information that the employee reasonably believes
faith report. (There may be unique circumstances
is evidence of gross mismanagement of a federal
when disclosing your identity is required by law or
funding; a gross waste of federal funds; an abuse
is necessary to fully investigate and address your
of authority relating to a federal grant, cooperative
concerns.)
agreement, or contract; a substantial and specific
If you choose to identify yourself when making danger to public health or safety; or a violation of
a report, filing online, or accessing the Hotline, law, rule, or regulation related to a federal grant,
Winrock will endeavor to keep your information cooperative agreement, or contract. Retaliation
confidential, sharing it only on a need-to-know basis is prohibited even if undertaken at the request of
among those directly handling or overseeing the an executive branch government official, unless
issues you reported. the request takes the form of a non-discretionary
If you make a report anonymously using the Hotline, directive that is within the authority of the
it is important to provide detailed information. executive branch government official making the
EthicsPoint will assign you with a case number, and request. If an employee believes that he/she has
you should regularly check the site to respond to been retaliated against for a good faith disclosure
information requests from those handling the issue(s) of the type of conduct listed above, he/she may
you reported. Cases that lack enough information submit a complaint to the Inspector General of the
to pursue may be closed. appropriate U.S. federal agency. The employee’s
rights and remedies may be found at 48 CFR 3.900.
Although anonymous reports are allowed,
employees may not raise issues, file online, or
use the Hotline in bad faith (e.g., to file fabricated RESPONSIVENESS AND
complaints for dishonest or hidden reasons). EMPLOYEE COOPERATION
Anonymous reports made in bad faith undermine
Investigations of Code and policy violations will
the integrity of filing online or using the Hotline and
be led by the Chief Risk and Compliance Officer,
are subject to disciplinary action.
working with partners such as HR, Finance, and
Programs, as needed and while respecting the
ANTI-RETALIATION POLICY need for confidentiality. Employees are required to
Winrock will not tolerate retaliation against anyone cooperate with an investigation.
who, in good faith, reports a concern or participates Winrock takes all concerns seriously and will address
in an investigation, even if the allegation ultimately all reports. Out of respect for the privacy of individ-
is not substantiated. Anyone, regardless of position uals who may be affected by your report, Winrock
or tenure, found to have engaged in retaliatory may be unable to provide you with detailed results
conduct against someone who has raised an ethics of our investigation and may not tell you what
or compliance concern will be subject to disciplinary actions were taken in response. Whenever practica-
action, and possibly termination. If you feel you have ble, we will provide you with status updates, so you
been subjected to retaliation, you should access the know that your concern is receiving an appropriate
Code of Conduct Hotline online or by telephone response. Our Chief Risk and Compliance Officer,
for assistance or directly contact the Chief Risk and members of the Executive Team, and the Compli-
Compliance Officer. ance and Audit Committee of Winrock’s Board of
Directors also monitor the resolution of cases.
WINROCK CODE OF CONDUCT 9ENFORCEMENT
Anyone who violates Winrock’s • No action taken/no action
Code of Conduct or the Operational necessary
Policies and Procedures, regardless • Policy/process review
of position or tenure, may be sub-
ject to disciplinary action, including • Training/advice
termination. The following are ex- • Verbal warning
amples of conduct that may result in • Written warning
disciplinary action:
• Termination
• Violating the Code
In addition, violations of laws or
• Directing or encouraging others
regulations can trigger legal action
to violate the Code
against you, your colleagues, Winrock
• Failing to report known or or its partners, or suppliers that could
suspected violations of the Code result in:
• Interfering with an audit or • Fines
investigation
• Suspension
• Being uncooperative or untruthful
• Debarment
during an audit or investigation
• Imprisonment
• Retaliating against others for
raising a concern Employees will be asked to sign
a statement certifying that they
The disciplinary action will vary
understand and will abide by this
depending on the seriousness of the
Code of Conduct. Each person
offense, whether there is a history of
will sign the statement when they
prior conduct, the certainty of the
begin work for Winrock, and every
facts, and other factors. Disciplinary
year after.
action could be any of the following:
EXCEPTIONS TO THIS CODE
Any employee who requests an exception to this Code of Conduct should
obtain the exception, in writing, in advance, from the Chief Risk and
Compliance Officer. No others are authorized to allow an exception.
Nothing in the Code of Conduct or other Winrock Policies and Procedures
is intended to create an express or implied contract of employment. In the
U.S. and other applicable countries, the maintenance of this Code does
not modify the employment-at-will relationship that may exist between
Winrock and its employees. Nothing in this Code creates a contractual
obligation on the part of Winrock, nor does it expand any third party or
employee legal rights or Winrock’s legal obligations.
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ACKNOWLEDGEMENT
FORM
I hereby certify, by my signature, that I have read, understand,
and will comply with Winrock’s Code of Conduct. I understand
that it is my personal responsibility to ensure that my actions
conform with the provisions in our Code of Conduct and
understand that my failure to comply with these provisions may
result in corrective actions, up to and including my dismissal
from Winrock.
Signature of Employee:
Dated:
WINROCK CODE OF CONDUCT 1112
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COMMITMENT TO
COLLEAGUES AND
ORGANIZATION
Winrock is committed to ensuring safe and secure conditions for
its workforce, regardless of position or location, and to providing a
work environment that promotes staff well-being, resilience, health,
and productivity.
Winrock transforms donor contributions and funds into programs and
projects to empower the disadvantaged, increase economic oppor-
tunity, and sustain natural resources. Winrock combines technical
expertise with entrepreneurial innovation to improve lives around the
globe. To do this, Winrock must remain uncompromised, efficient,
and effective in carrying out our work. We must safeguard Winrock’s
assets and put the interests of the organization first.
Winrock is committed to be a responsible global citizen. Our
interactions with governments, regulators, the media, and local
communities must be grounded on honesty, trust, and fairness.
We support the legitimate rule of law and will promote high ethical
standards in the countries and communities where we work.
DIVERSITY AND INCLUSION
One of our Core Values is Equity:
• We treat our Winrock colleagues, our partners and funders, and
all who benefit from our work with fairness and respect.
• We believe that being inclusive and encouraging all voices to be
heard is fundamental to delivering sustainable, effective solutions
and systemic change.
• We promote diversity in our teams and in our decision-making.
Valuing both collective and individual differences—and ensuring
diversity in our workforce—helps foster a culture of inclusion and
allows each person to thrive in a talent-diverse environment. Winrock
strives to achieve an inclusive work environment where individual
differences and perspectives are valued and respected.
Valuing both collective and individual differences—and ensuring
diversity in our workforce—helps foster a culture of inclusion and
allows each person to thrive in a talent-diverse environment. Winrock
strives to achieve an inclusive work environment where individual
differences and perspectives are valued and respected.
WINROCK CODE OF CONDUCT 13Winrock’s diversity and inclusion goals help The policies and principles of EEO also apply
inform our recruitment and hiring practices to the selection and treatment of independent
and apply to all levels of employment. A contractors, personnel working on our premises
brand that is attractive to a broad diversity of who are employed by temporary agencies,
talent is paramount to creating diverse teams and any other persons, firms, or organizations
around the globe. doing business for or with Winrock.
Winrock believes that to engage, develop,
progress, and retain diverse talent, the DISCRIMINATION-FREE
messages delivered to attract candidates and
employees must be integrated with inclusive
WORKPLACE
Winrock is committed to a work environment
talent practices, processes, and systems.
in which all individuals are treated with respect
and dignity. Everyone has the right to work
EQUAL EMPLOYMENT in a professional atmosphere that prohibits
OPPORTUNITY (EEO) AND discriminatory practices. Winrock expects that
AFFIRMATIVE ACTION all relationships among persons in the office
will be professional and free of bias, prejudice
Winrock is committed to equal employment
and harassment.
opportunities without regard to race, color,
religion, sex, national origin, age, disability, Winrock will not condone or permit discrimi-
marital status, veteran status, sexual orien- nation, including actions that create a hostile
tation, gender identity, genetic information work environment, against any employee
or any other protected characteristic under or applicant for employment based on race,
applicable law. color, religion, sex, national origin, age, dis-
ability, marital status, veteran status, sexual
Equal employment opportunity applies to
orientation, gender identity, gender expres-
all phases of employment, including, but
sion, genetic information, or other protected
not limited to, recruiting, employment,
characteristic under applicable law. It is Win-
placement, promotion, transfer, demotion,
rock’s policy to encourage and support work
reduction of workforce and termination,
environments that respect differences and
rates of pay or other forms of compensation,
provide all employees with dignity, fairness,
employee benefits, selection for training, the
and opportunities for professional develop-
use of facilities, and participation in Winrock-
ment in all locations where Winrock works.
sponsored employee activities.
All complaints or information about sexual
Provisions in applicable laws providing
harassment, workplace harassment or discrim-
for bona fide occupational qualifications,
ination will be investigated, led by the Chief
organizational necessity, or age limitations will
Risk and Compliance Officer. Investigations
be adhered to by Winrock where appropriate.
will be conducted in a timely manner and will
Winrock pursues affirmative action as called for be confidential to the extent possible.
by applicable U.S. laws and Executive Orders
to ensure that minority group individuals,
females, disabled veterans, recently separated
HARASSMENT-FREE
veterans, other protected veterans, Armed WORKPLACE
Forces service medal veterans, and qualified (SEE ALSO WINROCK POLICY:
disabled persons are introduced into our COMBATTING SEXUAL HARASSMENT)
U.S.-based workforce and considered for • Harassment is strictly prohibited.
promotional opportunities. Harassment is verbal, written or physical
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conduct that denigrates or shows hostility perceived sex, gender expression, gender
or aversion toward an individual because identity and the status of being transgen-
of race, color, religion, sex, national origin, der. Sexual harassment includes unwelcome
age, disability, marital status, veteran conduct which is either of a sexual nature,
status, sexual orientation, gender identity, or which is directed at an individual because
gender expression, genetic information or of that individual’s sex, sexual orientation,
any other protected characteristic under self-identified or perceived sex, gender
applicable law, and that: Has the purpose expression, gender identity and the status
or effect of creating an intimidating, hostile of being transgender, when:
or offensive work environment • Such conduct has the purpose or effect of
• Has the purpose or effect of unreasonably unreasonably interfering with an individual’s
interfering with an individual’s work work performance or creating an intimidating,
performance, or hostile or offensive work environment, even
• Otherwise adversely affects an individual’s if the reporting individual is not the intended
employment opportunities target of the sexual harassment;
Harassing conduct includes epithets, slurs or • Such conduct is made either explicitly or
negative stereotyping; threatening, intimidating implicitly a term or condition of employment;
or hostile acts; denigrating jokes; and written or
or graphic material that denigrates or shows • Submission to or rejection of such conduct is
hostility or aversion toward an individual or used as the basis for employment decisions
group that is placed on walls or elsewhere on affecting an individual’s employment.
the employer’s premises or circulated in the A sexually harassing hostile work environment
workplace. Harassment can occur in the physical includes, but is not limited to, words, signs,
workplace, while employees are traveling for jokes, pranks, intimidation or physical vio-
business or at employer-sponsored event or lence which are of a sexual nature, or which
parties. Calls, texts, emails, and social media are directed at an individual because of that
usage by employees can constitute harassment, individual’s sex.
even if they occur away from the workplace
premises, on personal devices, or during non- Sexual harassment also consists of sexually
work hours. explicit derogatory statements or sexually
discriminatory remarks that are offensive or
All complaints or information about sexual objectionable to the recipient, which cause
harassment, workplace harassment or the recipient discomfort or humiliation, or that
discrimination will be investigated, led by the interfere with the recipient’s job performance.
Chief Risk and Compliance Officer. Investigations It includes any unwanted verbal or physical
will be conducted in a timely manner and will be advances that are sexual in nature.
confidential to the extent possible.
Sexual harassment also occurs when a
person in authority tries to trade job or other
COMBATTING SEXUAL benefits for sexual favors. This can include
HARASSMENT hiring, promotion, continued employment or
Winrock is committed to maintaining a work- any other terms, conditions or privileges of
place free from sexual harassment. employment, and access to services. This is
called “quid pro quo” harassment.
WHAT IS SEXUAL HARASSMENT? Anyone who feels harassed should report
it so that any violation of this policy can be
Sexual harassment is harassment on the basis
corrected promptly. Any harassing conduct,
of sex, sexual orientation, self-identified or
WINROCK CODE OF CONDUCT 15even a single incident, can be addressed WHO CAN BE A TARGET OF
under this policy. SEXUAL HARASSMENT?
Sexual harassment can occur between any
EXAMPLES OF individuals, regardless of their sex or gender.
SEXUAL HARASSMENT Winrock protects our workforce and
The following describes some of the types of beneficiaries; those employed by our partners,
acts that may be unlawful sexual harassment grantees, contractors and vendors; and those
and that are strictly prohibited: employed by companies contracting to
• Sexually oriented gestures, noises, remarks provide services in the workplace.
or jokes, or comments about a person’s Harassers can be a superior, a subordinate, a
sexuality or sexual experience, which create coworker or anyone in the workplace including
a hostile work environment. an independent contractor, contract worker,
• Sex stereotyping, such as when conduct vendor, client, customer or visitor.
or personality traits are considered
inappropriate simply because they may WHERE CAN SEXUAL
not conform to other people’s ideas or HARASSMENT OCCUR?
perceptions about how individuals of a Prohibited sexual harassment is not limited
particular sex should act or look. to the physical workplace itself. It can occur
• Sexual or discriminatory displays or while employees are traveling for business
publications anywhere in the workplace, such or at employer-sponsored events or parties.
as displaying pictures, posters, calendars, Calls, texts, emails, and social media usage by
graffiti, objects, promotional material, employees can constitute harassment, even if
reading materials or other materials that are they occur away from the workplace premises,
sexually demeaning or pornographic. This on personal devices, or during non-work hours.
includes such sexual displays on workplace
computers or cell phones and sharing such REPORTING SEXUAL HARASSMENT
displays while in the workplace.
Preventing sexual harassment is everyone’s
• Unwanted sexual advances or propositions, responsibility. Winrock cannot prevent or
such as: remedy sexual harassment unless it knows
• Requests for sexual favors accompanied about it.
by implied or overt threats concerning Any employee who has been subjected to
the target’s job performance evaluation, behavior that may constitute sexual harassment
a promotion or other job benefits or det- is encouraged to report such behavior using
riments any of the channels described in this Code:
• Subtle or obvious pressure for unwel- to a manager, Chief of Party, HR Lead or HR
come sexual activities Manager, any member of the Executive Team,
the Chief Risk and Compliance Officer, or via
• Physical acts of a sexual nature, such as:
Winrock’s Hotline, online or by telephone.
• Touching, pinching, patting, kissing, hug-
Anyone who witnesses or becomes aware of
ging, grabbing, brushing against another
potential instances of sexual harassment should
employee’s body or poking another em-
report such behavior to the same channels:
ployee’s body
a manager, Chief of Party, HR Lead or HR
• Rape, sexual battery, molestation or at- Manager, any member of the Executive Team,
tempts to commit these assaults the Chief Risk and Compliance Officer, or via
Winrock’s Hotline, online or by telephone.
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All managers who receive a complaint or When a job candidate with a disability requests
information about suspected sexual harass- an accommodation and can be reasonably
ment, observe what may be sexually harassing accommodated without creating an undue
behavior, or for any reason suspect that sexual hardship or causing a direct threat to work-
harassment is occurring, are required to report place safety, the individual will be given the
such suspected sexual harassment to the Chief same consideration for employment as any
Risk and Compliance Officer. other candidate.
All complaints or information about sexual
harassment will be investigated, led by the Chief Key Definitions
Risk and Compliance Officer. Investigations will Disability: A physical or mental impairment
be conducted in a timely manner and will be that substantially limits one or more major life
confidential to the extent possible. activities of the individual, a record of such an
impairment, or being regarded as having such
ACCOMMODATION POLICY an impairment.
The Americans with Disabilities Act (ADA) and Major life activities: Term includes caring
the ADA Amendments Act (ADAAA) are U.S. for oneself, performing manual tasks, seeing,
federal laws that require employers to not dis- hearing, eating, sleeping, walking, standing,
criminate against candidates and employees lifting, bending, speaking, breathing, learning,
with disabilities and, when needed, to provide reading, concentrating, thinking, communi-
reasonable accommodations to candidates cating, and working.
and employees who are qualified for a job, Substantially limiting: In accordance with
with or without reasonable accommodations, the ADAAA regulations, the determination
so that they may perform the essential job of whether an impairment substantially limits
duties of the position. Winrock follows these a major life activity requires an individual-
laws globally, wherever we work. ized assessment, and an impairment that is
Per the Equal Employment Opportunity Com- episodic or in remission may also meet the
mission and Affirmative Action policy, Winrock definition of disability if it would substantially
complies with all U.S. federal and state laws limit a major life activity when active.
concerning the employment of persons with Direct threat: A significant risk to the health,
disabilities and acts in accordance with reg- safety or well-being of individuals with dis-
ulations and guidance issued by the EEOC. abilities or others when this risk cannot be
Winrock will not discriminate against qualified eliminated by reasonable accommodation.
individuals with disabilities in all phases of
Qualified individual: An individual who, with
employment, including, but not limited to,
or without reasonable accommodation, can per-
recruiting, employment, placement, promo-
form the essential functions of the employment
tion, transfer, demotion, reduction of workforce
position that such individual holds or desires.
and termination, rates of pay, or other forms of
Winrock-sponsored employee activities. Essential functions of the job: Those job
activities that are determined by the employer
Winrock will reasonably accommodate quali-
to be essential or core to performing the job;
fied individuals with a disability so that they
these functions cannot be modified.
can perform the essential functions of a job
unless doing so causes a direct threat to these Reasonable accommodation: Any changes
individuals or others in the workplace and the to the work environment and may include:
threat cannot be eliminated by reasonable making existing facilities readily accessible
accommodation; or if the accommodation to and usable by individuals with disabilities,
creates an undue hardship to Winrock. job restructuring, part-time or modified work
WINROCK CODE OF CONDUCT 17schedules, telecommuting, reassignment to a differently, based on prevailing social norms and
vacant position, acquisition or modification of unequal access to resources and opportunities.
equipment or devices, appropriate adjustment Gender-based constraints limit the freedom of
or modifications of examinations, training individuals of all genders to fully exercise their
materials or policies, the provision of qualified rights and realize their full potential in societies
readers or interpreters where budget allows, and and institutions. Development challenges
other similar accommodations for individuals require solutions that address gender-based
with disabilities. constraints and create an inclusive enabling
Undue hardship: An action requiring environment for all individuals and communities
significant difficulty or expense by the employer. to contribute to and benefit from development.
In determining whether an accommodation Winrock is committed to analyzing gender
would impose an undue hardship on a covered differences in its programs and creating equi-
entity, factors to be considered include: table opportunities for all genders, adults and
• The nature and cost of the accommodation. children, to overcome barriers, contribute to
their communities’ development, and realize
• The overall financial resources of the facility their full rights and potential.
or facilities involved in the provision of the
reasonable accommodation, the number Winrock also is committed to implementing
of persons employed at such facility, the institutional practices that create equal oppor-
effect on expenses and resources, or the tunities for men and women in its work around
impact of such accommodation on the the globe, and to providing staff with the
operation of the facility. awareness, knowledge, and tools necessary
to implement this policy.
• The overall financial resources of the em-
ployer; the size, number, type, and location
of facilities. TO ESTABLISH THIS COMMITMENT,
WINROCK WILL STRIVE TO:
• The type of operations of the company,
• Share a common understanding of gender
including the composition, structure and
concepts and how they relate to our
functions of the workforce; administrative or
organization and our work.
fiscal relationship of the facility involved in
making the accommodation to the employer. • Strive for gender balance in recruiting
and supporting people at all levels of the
GENDER EQUALITY
institution, including field teams, senior
leaders and managers, and the Board of
Winrock has been a recognized leader in Directors.
fostering women’s empowerment and gender
• Compensate all genders with similar levels
equality since 1989, when it launched African
of responsibility equitably, in line with
Women Leaders in Agriculture and Environment
Winrock’s pay practices.
(AWLAETM) program to recognize and promote
women’s role in agriculture. Winrock’s efforts in • Establish policies that are gender-sensitive
gender integration and women’s empowerment and responsive to the needs of all genders
in agriculture and other areas have positioned it to balance work, family, civic life, and
as a leader in the field. Gender equality is also associated responsibilities (e.g., pregnancy,
a critical component of Winrock’s commitment childrearing and family care).
to diversity and equal opportunity as an orga- • To enhance program quality and promote
nization. gender integration as good development
Winrock recognizes that all genders, adults and practice, support project and program
children, experience poverty and development teams to:
18Back Last Viewed Contents Next
• Be aware of and analyze gender differ- than parity in numbers or laws on the books;
ences and incorporate these consider- it means expanded freedoms and improved
ations into the project cycle overall quality of life for all people.
• Recruit and retain all genders into posi- Gender integration: Systematically identifying,
tions where they have been traditional- and then addressing, gender inequalities during
ly underrepresented, and strive for and strategy and project design, implementation,
align policies to ensure equitable com- and monitoring and evaluation.
pensation for all people in similar posi- Gender justice: The protection and promotion
tions of civil, political, economic, and social rights
• Monitor and evaluate the participation on the basis of gender equality.
of, and relative impact on, gender in Gender sensitive: The ability to acknowl-
project activities, including potential un- edge and highlight gender differences, issues,
intended consequences and inequalities to address them in strategies
• Communicate success stories and les- and actions.
sons learned related to gender equality, LGBT: An acronym for lesbian, gay, bisexual,
gender justice, gender empowerment, and transgender. There are many other varia-
and constructive gender engagement to tions on this acronym that are used in different
internal and external audiences contexts, including, for example, LGBTI, which
adds a reference to intersex people; LGBTIQ,
Key Definitions which adds a reference to queer and question-
Gender: The socially constructed roles and ing; and LGBTIQA, which adds a reference to
responsibilities assigned to males, females, asexuals and allies.
or others in a given culture or location. Ideas
about gender are learned and can change DRUG-FREE WORKPLACE
over time, and often intersect with other
In compliance with the U.S. Drug-Free Work-
factors such as race, class, age, and sexual
place Act of 1988, Winrock has a longstanding
orientation.
commitment to provide a safe, quality-oriented
Sex: The biological differences between and productive work environment, wherever we
males, females, and others especially work globally. Alcohol and drug abuse poses
as differentiated based on reproductive a threat to the health and safety of Winrock
functions. Sex is based on biology, not culture. employees and to the security of Winrock’s
Female empowerment is achieved when equipment and facilities. For these reasons,
women and girls acquire the power to act Winrock is committed to the elimination of drug
freely, exercise their rights, and fulfill their and alcohol use and abuse in the workplace.
potential as full and equal members of society. Employees should report to work fit for duty
While empowerment often comes from within, and free of any adverse effects of illegal
and individuals empower themselves, cultures, drugs or alcohol. This policy does not prohibit
societies, and institutions create conditions employees from the lawful use and possession
that facilitate or undermine the possibilities of prescribed medications. Employees must,
for empowerment. however, consult with their doctors about the
Gender equality: The state or condition that medications’ effect on their fitness for duty and
affords all genders equal enjoyment of human ability to work safely, and they must promptly
rights, socially valued goods, opportunities, disclose any work restrictions to their manager.
and resources. Genuine equality means more
WINROCK CODE OF CONDUCT 19Key Work Rules: absence, referred to treatment providers and
otherwise accommodated as required by law.
1. Whenever an employee is present on
Winrock premises or is conducting Winrock- Employees may be required to document
related work offsite, they are prohibited that they are successfully following prescribed
from: treatment and to take and pass follow-up
tests if they hold jobs that are safety-sensitive
• Using, possessing, buying, selling, manu-
or require driving, or if they have violated this
facturing, or dispensing an illegal drug (to
policy previously.
include possession of drug paraphernalia)
• Being under the influence of alcohol or
INSPECTIONS
an illegal drug as defined in this policy
Winrock reserves the right to inspect all
• Consuming alcohol, unless as part of a portions of its premises for drugs, alcohol
Winrock-approved event; any alcohol or other contraband. All employees may be
consumed at such an event must be asked to cooperate in inspections of their
consumed responsibly persons, work areas, and property that might
2. Whenever any employee is operating any conceal a drug, alcohol, or other contraband.
Winrock and/or project vehicle, they are Employees who possess such contraband or
prohibited from: refuse to cooperate in such inspections are
• Using, possessing, buying, selling, subject to appropriate discipline, up to and
manufacturing or dispensing an illegal including discharge.
drug (to include possession of drug
paraphernalia) CRIMES INVOLVING DRUGS
• Being under the influence of alcohol or Winrock prohibits all employees from manu-
an illegal drug as defined in this policy facturing, distributing, dispensing, possessing,
or using an illegal drug in or on Winrock
• Consuming alcohol
premises or while conducting Winrock busi-
3. Winrock will not allow employees to per- ness. Winrock employees are also prohibited
form their duties while taking prescribed from misusing legally prescribed or over-
drugs that are adversely affecting their the-counter (OTC) drugs. Law enforcement
ability to safely and effectively perform personnel may be notified, as appropriate,
their job duties. Employees taking a pre- when criminal activity is suspected.
scribed medication must carry it in a con-
Winrock does not intend to intrude into the
tainer labeled by a licensed pharmacist or
private lives of its employees but recognizes
be prepared to produce the container if
that employees’ off-the-job involvement with
asked.
drugs and alcohol may have an impact on the
4. Any illegal drugs or drug paraphernalia workplace. Therefore, Winrock reserves the
will be turned over to an appropriate law right to take appropriate disciplinary action
enforcement agency and may result in for drug use, sale, or distribution while off
criminal prosecution. Winrock premises.
All employees who are convicted of, plead
EMPLOYEE ASSISTANCE guilty to, or are sentenced for a crime involving
Winrock will assist and support employees who an illegal drug are required to report the
voluntarily seek help for drug or alcohol prob- conviction, plea or sentence to the HR Lead or
lems before becoming subject to discipline HR Manager within five calendar days of the
or termination under this or other Winrock conviction/plea. Failure to report may result in
policies. Such employees will be allowed to automatic discharge.
use accrued paid time off, placed on leaves of
20Back Last Viewed Contents Next
Key Definitions • Threats of violence or acts of aggression,
whether direct, indirect (veiled) or conditional
Winrock premises includes all buildings,
offices, facilities, grounds, parking lots, • Behavior that acts to intimidate or to instill
lockers, places and vehicles owned, leased, or fear in others
managed by Winrock or any site on which the • Menacing gestures
company is conducting business.
• Bringing, or threatening to bring, weapons
Illegal drug means a substance whose use to the workplace
or possession is controlled by U.S. federal
• Stalking
or other law but that is not being used or
possessed under the supervision of a licensed • Hostile, aggressive, injurious and/or de-
health care professional. (U.S. controlled structive actions undertaken for the purpose
substances are listed in Schedules I-V of 21 of domination or intimidation
C.F.R. Part 1308.)
Under the influence of alcohol means PROHIBITED CONDUCT
actions, appearance, speech or bodily odors • All employees, volunteers, beneficiaries,
that reasonably cause a supervisor to conclude partners, vendors, and donors should be
that an employee is impaired because of treated with courtesy and respect at all times.
alcohol use. • Employees are expected to refrain from
Under the influence of drugs means a fighting, “horseplay”, or other conduct that
confirmed positive test result for illegal drug may be dangerous to others. Conduct that
use per this policy. In addition, it means the threatens, intimidates, or coerces another
misuse of legal drugs (prescription and possibly employee, volunteer, beneficiary, partner,
OTC) when there is not a valid prescription vendor, and/or donor will not be tolerated.
from a physician for the lawful use of a drug • Winrock employees may not carry or
during medical treatment (containers must possess weapons or ammunition while
include the patient’s name, the name of the on assignment.
substance, and quantity/amount to be taken).
• Winrock resources may not be used to
threaten, stalk, or harass anyone at or out-
WORKPLACE VIOLENCE side the workplace.
PREVENTION POLICY
Winrock is committed to preventing workplace Take Action:
violence and to maintaining a safe work environ- Indirect or direct threats of violence, incidents
ment. Winrock has adopted the following policy of actual violence, and suspicious individuals
to address intimidation, harassment, or other or activities should be reported as soon
threats of or actual violence that may occur as possible to those channels identified in
onsite or offsite. the Reporting Policy, and/or the Security
For the purpose of this policy, “workplace Focal Point or Global Safety & Security. It is
violence” is defined as including, but not important that Winrock is made aware of any
limited to: potential danger in the workplace as early as
possible to ensure proper measures can be
• Physical violence or acts of aggression implemented to enhance employee safety
toward or by another person and security in the workplace.
• Physical violence or acts of aggression toward When reporting a threat or incident of
Winrock property or personal property on violence, employees should be as specific
Winrock premises
WINROCK CODE OF CONDUCT 21and detailed as possible. Employees should • Providing advice and guidance to mitigate
not place themselves in peril, nor should they developing threats
attempt to intercede during an incident. • Responding to incidents
Employees should promptly inform the HR • Integrating security into the project life cycle,
Lead or HR Manager of any protective or beginning with the design of each proposal
restraining order that they have obtained that
lists the workplace as a protected area. It is critical that each member of Winrock’s
workforce understand and manage the health,
Employees are encouraged to report safety safety, and security risks when working in some
concerns about intimate partner violence. of the least-developed countries, hostile and
Winrock will not retaliate against employees post-conflict situations, and most remote
making good-faith reports. Winrock is commit- areas in the world.
ted to supporting victims of intimate partner
violence by providing referrals to Winrock’s • Every employee and member of Winrock’s
employee assistance program and community workforce has an obligation to learn and
resources and providing time off for reasons understand the context and security issues
related to intimate partner violence. where they are located. Each must adhere to
all pertinent policies and plans concerning
safety and security and will be accountable
GLOBAL SAFETY for their actions.
AND SECURITY • Each employee has the right to withdraw
Prioritizing the safety and security of each from or refuse to take a work assignment
employee and every volunteer, intern, and or travel in an area due to safety and
partner who work on behalf of Winrock is security concerns.
integral to our work culture and environment. • Winrock has the right to suspend activities
Winrock is committed to minimizing safety or withdraw employees from situations that
and security risks and ensuring our workforce it considers to be too dangerous.
is provided the information, support, and
training to reduce their risk exposure while • An employee does not have a right to
maximizing the impact of our work. remain in a location if they have been
instructed to withdraw from it by an
Safety and security are shared responsibilities authorized Winrock representative.
by both the Winrock workforce and the orga-
nization. Winrock operates in every country, Effective safety and security management for
especially higher-threat countries, under two Winrock is a leadership function. Managers at
guiding principles: each tier of the organization are responsible
and accountable for ensuring that safety and
• Our commitment to keep our workforce safe security policies, standards, plans, and pro-
and secure. cedures are well-integrated into the Winrock
• Our commitment to execute projects project life cycle.
effectively to contribute to meaningful Winrock managers have an obligation to
development. ensure that risks to employees are identified
Winrock’s Global Safety and Security (GSS) and managed, and that employees receive the
department proactively addresses the security support, resources, information, and training
needs of our workforce and projects by: they need to reduce any risk exposure. Learn
• Monitoring the global security and safety more about our Safety and Security Policy
environment here.
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