1. To promote and support the overall mission of ANSI as well as the purposes and objectives of the voluntary consensus standards system.
2. To maintain a process that is open, honest, and fair to all participants.
3. To promote the development of consensus through the broad participation of a variety of interests and through a full airing and discussion of all points of view.
4. To adhere, both in letter and in spirit, to all duly established rules, regulations, and policies governing the ANSI voluntary consensus standards system.
Statement of Policy
ANSI is committed to responsible business practices and ethical behavior. This Code of Conduct is intended to provide guidance and direction to all employees, contractors and agents of ANSI and Workcred. Our goal is to promote a culture of ethical behavior, integrity, honesty, and respect for others in all aspects of our work. Adherence to this Code is essential to maintaining the trust of employees, members, stakeholders and customers, and ensuring the continued success of our organization.
The principles contained in this policy set minimum standards of conduct. The Code of Conduct is not meant to be exhaustive and cover all situations that may occur, but rather provide a framework and a foundation for expected conduct. ANSI staff must abide by this Code of Conduct, other policies in this Manual which may also address these principles, and any other related policies and procedures, as applicable.
ANSI participants (all persons serving on the Board, Board Committees, Committees of ANSI, Forums, Policy Advisory Groups, and any other ANSI committees, subcommittees, task groups or other related bodies) should refer to ANSI’s external Code of Conduct, approved by the ANSI Board of Directors on December 5, 2018, found here: https://www.ansi.org/resource-center/code-conduct.
Adherence to Ethical Values
You are expected to act with the highest level of integrity, good faith and honesty and comply with all ethical standards and policies prescribed by ANSI, whether you are acting at an ANSI office or at another location on behalf of ANSI.
Compliance with Applicable Laws and Policies
You are expected to strictly observe all applicable laws, regulations and policies governing your work. This includes laws relating to anti-discrimination, anti-harassment, anti-retaliation, anti-bribery, anti-kickback, anti-corruption, antitrust, competition, privacy and security. This expectation also includes compliance with policies developed by ANSI for its own committees, forums and groups as well as those applicable to committees ANSI administers or with which it engages, either nationally or internationally.
When attending meetings of outside organizations (e.g. ISO, IEC, ILAC or IAF), you should be aware that other Codes of Conduct of such organizations may be applicable. You should familiarize yourself with such Codes of Conduct prior to participation in meetings of outside organizations.
ANSI is committed to observing the applicable antitrust or competition laws of all countries in which it conducts business. Antitrust and competition laws prohibit actions that are deemed to unreasonably restrain trade, such as, but not limited to, data related to prices, discounts, licensing terms, timing of pricing changes, profit, costs, market share, or customers lists; ANSI personnel do not engage in discussions or exchange commercially sensitive information with competitors regarding the allocation of territories, customers, distributors or suppliers. The penalties for failing to comply with these laws can be severe and include significant fines and possible jail time for certain infractions.
Avoiding Conflicts of Interest
You must avoid any conflict of interests that may arise from your work or outside activities. This includes conflicts between your own personal interests and the interests of ANSI in dealing with employees, members, stakeholders and customers.
Professional Conduct
You must maintain the highest level of professional conduct, including treating colleagues, partners, and clients with respect and civility. Although it is recognized that legitimate differences of opinion can exist on individual issues, you should act in a dignified and courteous manner, so as to avoid injuring others, their property, reputation, or employment by false, malicious or improper action and to avoid acting in a disrespectful or unprofessional manner towards other parties or ANSI staff.
This extends to meetings at ANSI’s offices or in other offices in which you conduct work. It also extends to the use of electronic communications, social media, and other communication channels.
Protecting Confidentiality, Privacy and Data
You must keep confidential and not divulge or distribute to others confidential and proprietary information and data regarding the business of ANSI or its current or prospective members, clients, affiliates or suppliers.
ANSI respects the privacy of the individuals with whom we work. ANSI collects, uses, shares, transfers or stores the personal information of others only when specifically authorized and as necessary for legitimate business purposes, and only to collect personal information of others with appropriate notices of the purposes for which that personal information will be used. ANSI implements appropriate safeguards to ensure the protection, integrity, and security of personal information in accordance with applicable data privacy laws.
ANSI maintains technology and security controls and risk management processes to identify and mitigate security risks that could negatively impact ANSI information, services or systems.
Safe and Compliant Business Travel
For any business travel, you have a responsibility to follow relevant ANSI policies, procedures, and guidelines and comply with all applicable federal, state, international and/or local laws and customs. Familiarize yourself with the environment in which you will be operating, use common sense and avoid taking unnecessary risks to yourself or other employees of ANSI. You should seek help, as needed.
Diversity and Inclusion ANSI recognizes that small and diverse businesses have a positive impact on the global community. ANSI is committed to including and utilizing diverse businesses in all of our services, and this includes providing, to the maximum extent possible, contracting opportunities to small, minority-owned, women-owned, and service-disabled veteran-owned businesses.
Substance Use and Abuse
You cannot possess, use, consume, sell, transfer, exchange, or distribute any illegal drugs or engage in unauthorized or illegal use of legal or prescription drugs or consume alcoholic beverages while engaged in ANSI business or on ANSI property. Reasonable alcohol use at functions or gatherings sponsored by ANSI, where other ANSI employees are present, or work-related events sponsored by other organizations is permitted but employees should recognize that excessive alcohol use in these situations is inappropriate.
Escalating and Resolving Disputes, Seeking Help and Reporting Behavior that Violates this Code of Conduct
You are required to report any suspected violations of this Code of Conduct. Violations of these codes may not always be clear from observable facts and disputes may arise as to whether a violation has occurred. To ensure effective work relations and to enable ANSI to address potential problems, it is important that such matters be reported and resolved following the steps laid out in ANSI’s HR Manual or other applicable processes, as the situation may warrant. You must seek input, as needed.
Conclusion
This Code of Conduct outlines the standards expected of all individuals associated with ANSI. By complying with this Code of Conduct, we maintain the trust of our employees, members, stakeholders and customers, uphold our legal obligations, and promote a positive work environment. ANSI may take disciplinary action up to and including termination against employees whose conduct violates the Code of Conduct or other ANSI policies and practices.
This section of the Code of Conduct was approved by the ANSI Senior Staff on September 1, 2023.
1. All persons serving on the Board, Board Committees, Committees of ANSI, Forums, Policy Advisory Groups, and any other ANSI committees, subcommittees, task groups or other related bodies (hereafter "Participants") shall act honestly, in good faith, and with the highest professional standards.
2. Although it is recognized that legitimate differences of opinion can exist on individual issues, Participants should act in a dignified and courteous manner, so as to avoid injuring others, their property, reputation, or employment by false, malicious or improper action and to avoid acting in a disrespectful or unprofessional manner towards other Members or ANSI staff.
3. In order that the points of view and information Participants contribute to the ANSI voluntary consensus standards system can be accurately evaluated by others, Participants should always endeavor to make known their business, commercial, organizational, or other affiliations that might affect their interests or points of view, avoiding real or perceived conflicts of interest whenever possible.
4. In all discussion, debate, and deliberation, Participants should confine their comments to the merits of the issues under review. Although Participants may forcefully advocate their views or positions, they should be candid and forthcoming about any weaknesses in their position, and they should refrain from debate and discussion that is disrespectful or unprofessional in tone or that is unduly personalized or damaging to the overall process of achieving consensus.
5. In circumstances where duly established policies and procedures related to the ANSI voluntary consensus standards system permit deliberations to take place in executive session, participants should respect and observe the confidentiality of those executive sessions.
6. No Participant should ever attempt to withhold or prohibit information or points of view from being disseminated, particularly on the grounds that the Participant is in disagreement with the information or points of view. Disagreements should be addressed and resolved through full presentation and discussion of all information and points of view not through withholding information or preventing points of view from being expressed.
7. Participants who have been retained to represent the interests of another with respect to a specific issue or issues that are to be addressed by any ANSI body shall declare those interests.
8. Participants should treat all persons with respect and fairness and should not offer or appear to offer preferential treatment to any person or group.
9. Participants should refrain from disseminating false or misleading information or from withholding information necessary to a full, fair, and complete consideration of the issues duly discussed.
10. Participants should obey all applicable laws and ANSI policies, including policies promulgated by ANSI for the committee, forum or group on which they participate; and
11. Participants should safeguard ANSI’s reputation and integrity by ensuring that any public statements relating to ANSI, which are not official statements of ANSI, are properly portrayed as the opinion of the individual making them.
This Code of Conduct was approved by the ANSI Board of Directors on December 5, 2018.
12. Violations of this Code will result in disciplinary action against Participants, which may include termination of a Participant's continued participation and/or termination of ANSI membership status of the ANSI member on whose behalf the Participant acts.
This Code of Conduct was approved by the ANSI Board of Directors on December 5, 2018.
The Board of Directors of the American National Standards Institute, Inc. (ANSI) has adopted these Procedures for Handling Code of Conduct violations and suspected violations.
13. It is the responsibility of all Participants to report violations of ANSI’s Code of Conduct. Such reports must be made in good faith.
14. Any Participant may lodge a complaint concerning another Participant’s suspected violation of ANSI’s Code of Conduct. A complaint must be in writing and include the name, position, address, telephone number and signature of the author of the complaint and a brief statement of the basis upon which the complainant believes a Participant has violated the Code of Conduct. Complaints must be submitted to ANSI’s General Counsel, who will share it with ANSI's President and the Chair of ANSI's Board of Directors.
15. Upon receipt of a complaint, the ANSI Board Chair, with the assistance of ANSI’s General Counsel and President, will review the complaint and determine whether it is within the scope of this Code of Conduct policy and whether further action is appropriate.
16. The ANSI Board Chair, in consultation with ANSI’s General Counsel and President may, in their discretion, reject the complaint if it: (a) lacks sufficient factual allegations, (b) is frivolous on its face; or (c) was submitted under circumstances that demonstrate it was made in bad faith.
17. Upon reaching a determination on a complaint, the ANSI Board Chair, in consultation with ANSI's General Counsel and President, will send written notification to the complainant and, if appropriate, the subject of the complaint. The notification shall acknowledge receipt of the complaint, enclose a copy of the complaint and ANSI Code of Conduct, and include the Chair’s determination whether further action will be taken.
18. Investigative Inquiry. If the ANSI Board Chair determines that the complaint requires further action, the Chair shall promptly designate an investigative team, which may be comprised of ANSI’s General Counsel, ANSI staff, and/or any disinterested director(s) (collectively “investigators”) to undertake an investigative inquiry, which may at the Chair’s or investigators’ discretion include the following steps:
a. Interviewing the complainant, the subject of the complaint, and/or relevant witnesses identified by either party;
b. Reviewing any documents provided by the complainant, the subject of the complaint and/or other witnesses;
c. Consulting with subject matter experts; and
d. Taking any other steps appropriate to aid in determining whether the complaint should be pursued further.
After considering all information gathered during the investigative inquiry, the investigators will provide a written recommendation to ANSI's General Counsel and Board Chair as to whether the subject should be found in violation of the Code of Conduct policy and/or whether further steps should be taken. The recommendation shall include the rationale for the recommendation and any supporting materials.
The Board Chair will review the written recommendation and other materials submitted and, in consultation with ANSI's General Counsel and President, will make a determination whether the subject violated ANSI’s Code of Conduct.
If the Chair determines that the subject of the complaint violated ANSI’s Code of Conduct, the Chair will determine the appropriate remediation to pursue. If the Chair makes a determination that the subject of the complaint did not violate ANSI’s Code of Conduct, no further action will be taken by ANSI, except to notify the subject and complainant of the determination.
19. Remediation. Corrective measures or discipline should be appropriate to the facts and circumstances of the violation and, subject to the Bylaws and applicable law, may include, but not be limited to: written admonishment or reprimand; a demand that remedial action be taken; removal from ANSI Board or committee assignments; loss of certain membership-related privileges; exclusion from attendance at certain ANSI-related events or conferences or participation in ANSI activities for a specified time; suspension from involvement in ANSI activities for a specified time; and expulsion from ANSI membership. Any recommended remediation will be overseen by the ANSI Board Chair and designated ANSI staff persons.
20. Remediation without Investigative Inquiry. Notwithstanding the provisions of paragraph 18, once the Chair has determined that the complaint will be addressed under the Code of Conduct policy, in consultation with ANSI's General Counsel, the Chair may at any time forego or suspend an investigative inquiry and offer remediation to the subject to resolve the complaint. In the event a remediation offer is accepted by the subject, notice will be provided to the complainant. The matter will otherwise be kept confidential, except to the extent necessary to effect the applicable remediation or for ANSI to comply with its legal obligations.
21. Notification of Determination of Remediation. The Chair will notify the complainant and subject in writing of any remediation determination and, if the determination is pursuant to a recommendation following an investigative inquiry, will simultaneously provide to the complainant and subject copies of the written recommendation and supporting materials.
22. Subject’s Rejection of Recommended Remediation. If the Chair recommends remediation and the subject does not agree, the Chair may, in consultation with the ANSI President and/or General Counsel, offer the subject the opportunity to appeal the remediation determination to the ANSI Appeals Board in accordance with the Appeals Board Operating Procedures.
23. In addition to complying with ANSI's Conflict of Interest Policy, individuals involved in hearing and determining Code of Conduct violations shall act at all times in a manner that promotes confidence in the integrity and impartiality of ANSI’s processes and procedures. No Participant may participate in resolving a complaint if they have a conflict of interest. Conflicts of interest may include, but are not necessarily limited to, a personal, business or financial relationship with the complainant or subject; a personal, business or financial interest in the outcome of the complaint; or personal involvement in or knowledge of the conduct at issue in the complaint. Any Participant who believes he or she has a conflict of interest should promptly recuse him- or herself and disclose the nature of the conflict of interest to ANSI’s General Counsel.
24. Although the results of the remedial determination may be announced to ANSI’s Board or its membership, ANSI endeavors to keep proceedings under its Code of Conduct policy as confidential as is reasonably possible. Participants in any proceeding under the Code of Conduct, including the complainant, subject, witnesses, and Participants involved in resolving the complaint, are expected to adhere to this confidentiality policy. However, Participants may, at their own expense, consult legal counsel and discuss the matter with immediate family members, provided they have first agreed to keep the matter confidential. Violation of this expectation of confidentiality may be considered a violation of the Code of Conduct.
25. The President of ANSI may disclose information regarding the proceedings to ANSI staff, members and third parties as necessary for ANSI’s business purposes, including, but not limited to, facilitating proceedings, implementing remedial action, or satisfying ANSI’s legal obligations. ANSI may also, in its sole discretion, disclose information obtained during the course of any proceeding for safety or security purposes. In addition, ANSI may, at its discretion, make legal counsel available to consult with its staff, investigators and panelists concerning any aspect of any complaint or proceeding under the Code of Conduct.
26. A copy of key records relevant to each proceeding, including the complaint, materials submitted by the parties or collected during the investigative inquiry, written notices and reports, minutes, the record of the hearing, appeals, and decisions will be retained for seven years by ANSI.
27. Once a complaint has been finally resolved, the Chair will notify all participants that they should delete or destroy, without retaining copies of, all documents and information in their possession relating to the proceeding. All participants are expected to comply with this policy and, to the extent they believe they are unable to do so due to competing legal or other obligations, should discuss the matter with ANSI’s General Counsel. Participants should keep in mind that documents and communications sent via (or stored in) personal or institutional e-mail, networks, or cloud services may not be kept confidential, and they should endeavor to exercise good judgment in sending, storing and retaining documents relating to proceedings under this Policy.
28. While Participants are expected to abide by the Code of Conduct in all of their professional activities, the Chair may decline to consider any complaint at his or her sole discretion, including but not limited to complaints that concern conduct or a dispute in which another organization or institution has a more substantial interest, or that is the subject of legal action or a governmental investigation. The Chair may also decide to defer consideration of any such complaint until the other organization or institution has addressed the matter internally, or until any legal action or governmental investigation has concluded.
29. Further, complaints regarding conduct that falls under ANSI’s Conflict of Interest Policy will ordinarily be first addressed under that policy. ANSI may, at its discretion, also treat such a complaint (or a complaint made pursuant to that policy) as a complaint under the Code of Conduct policy.
30. If at any point the Chair or the President or General Counsel of ANSI determines that a complaint raises or may raise a criminal matter, then ANSI may inform the appropriate authorities. In this event, the Chair or President or General Counsel of ANSI may suspend further consideration of the complaint until after the appropriate authorities have completed their investigation or any other actions. After the involvement of the appropriate authorities is complete, whether or not such involvement results in any criminal or civil sanctions, a complainant may request that ANSI continue its consideration of the complaint under this Code of Conduct policy, or ANSI may choose to do so without prompting.
31. It is inconsistent with the Code of Conduct to make threats or engage in acts of retaliation against individuals who in good faith report suspected violations of the Code. A Participant who believes that he or she has been retaliated against for making a good-faith complaint under the Code of Conduct policy may use the above procedures to report the pertinent facts to the Chair, who will consider the report as a complaint made under this Policy.
