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Code of Ethics and Professional Conduct

Introduction

Humanics Global Advisors (HGA) is committed to the highest standards of ethics and professional conduct in all its activities. This Code of Ethics and Professional Conduct (“the Code”) outlines the principles and rules that guide the behavior of HGA’s employees, staff, and network consultants worldwide. It reflects HGA’s dedication to integrity, honesty, transparency, and accountability in support of our mission, “Together for a better world.” All HGA personnel are expected to internalize and abide by this Code at all times, ensuring our work is conducted ethically and in compliance with both the letter and spirit of applicable laws and standards. The Code draws inspiration from the ethical frameworks of leading global development institutions (such as the World Bank, United Nations, regional development banks, the European Commission, and IMF) which demand honesty, integrity, and the “highest standard of ethics” in all projects[1][2]. While aligned with these international best practices, this Code is the proprietary standard of HGA and must be adhered to as a condition of working with or for HGA.

Purpose and Scope

Purpose: The purpose of this Code is to set forth clear expectations of ethical behavior and professional conduct for everyone representing HGA. It serves as a guide to help identify ethical issues, make sound decisions, and uphold our core values in daily work. By articulating our commitments in key areas – from anti-corruption to respectful workplace conduct – the Code helps maintain trust with clients, partners, donors, and the communities we serve.

Scope: This Code applies to all individuals who work with or represent HGA, including: – Internal Staff and Employees: Full-time, part-time, and temporary HGA staff, officers, and directors are bound by this Code.
– Independent Consultants and Network Members: All consultants, advisors, subcontractors, and other experts engaged through the Humanics Global Advisors digital platform or otherwise contracted by HGA must equally adhere to this Code when performing work for or on behalf of HGA.
– Global Application: The Code is global in nature. It applies regardless of location and covers conduct in all professional settings, including on-site project work, virtual/online collaborations via HGA’s platform, and interactions with clients or stakeholders at events or meetings. HGA personnel are expected to uphold these standards both during and outside of regular working hours whenever representing HGA.

By accepting an engagement with HGA (whether as an employee or consultant), individuals agree to comply with this Code. Violations of the Code may result in disciplinary action or contract termination as outlined in the Enforcement section. If local laws or regulations impose stricter requirements than this Code, those stricter rules must be followed. In cases of uncertainty about the proper course of action, individuals should seek guidance from a supervisor or HGA’s compliance officer before acting.

HGA Mission and Values

Our Mission: “Together for a better world.” HGA’s mission is to drive positive global development outcomes by harnessing a network of skilled professionals and a collaborative digital platform. We believe that by working together ethically and transparently, we can achieve sustainable solutions for communities worldwide. This Code is a direct extension of our mission – it ensures that our work is not only effective but conducted with unwavering integrity and respect.

Core Values: HGA’s culture is grounded in a set of core values that inform every aspect of our operations. These values are: Integrity, Honesty, Transparency, Accountability, Respect, Professionalism, and Collaboration. We expect all team members and consultants to embody these values in their decisions and behavior. In practice, this means: always doing the right thing (Integrity), being truthful and trustworthy (Honesty), being open and clear in our communications (Transparency), taking responsibility for our actions (Accountability), treating everyone with dignity and fairness (Respect and Professionalism), and working together in good faith (Collaboration). By living these values, we build trust among ourselves and with clients and partners, reinforcing HGA’s reputation as an ethical leader in global development consulting.

The following sections detail the specific principles and policies that flow from our mission and values. Each section provides guidelines to help ensure our daily actions align with HGA’s ethical standards and the expectations of the international development community.

Integrity and Honesty

HGA holds integrity and honesty as fundamental values. All staff and consultants must conduct themselves with uncompromising integrity – doing what is right even when no one is watching – and with honesty in all dealings. We insist on truthfulness, sincerity, and reliability in every aspect of our work. This includes being honest in communications, in representing our capabilities, and in the information we provide to clients, colleagues, and stakeholders.

Key expectations for integrity and honesty include:

  • Truthful Communications: Always be truthful and accurate in statements and documents. Do not misrepresent qualifications, work experience, or any aspect of your professional credentials. All information submitted in CVs, proposals, reports, and correspondence must be factual and verifiable. Any act of dishonesty, such as falsifying credentials or project data, is a serious ethical breach and grounds for removal or termination[3].
  • Doing the Right Thing: Make decisions guided by ethics and fairness, not by personal gain or pressure. If asked to do something inconsistent with this Code or your moral principles, respectfully decline and report the concern. Upholding integrity may mean refusing to participate in improper activities even if they appear beneficial to business.
  • Fair Dealing: Engage in fair and transparent dealings with clients, partners, and colleagues. Do not cheat, defraud, or deceive others. We honor our commitments and contracts, and we do not make promises we cannot keep.
  • Avoiding Conflicts with Values: Never sacrifice ethical standards for the sake of results. Short-term gains that undermine integrity will lead to long-term harm. Each person is expected to act in HGA’s best interests while also honoring the broader principles of honesty and justice.

By maintaining integrity and honesty in everything we do, we foster trust internally and externally. This value is the foundation upon which all other elements of the Code rest. Every HGA member is a steward of our reputation – we must ensure that our personal conduct consistently reinforces the trust that clients and communities place in us.

Transparency and Accountability

Transparency and accountability are critical to HGA’s platform approach and our collaborative culture. We believe in operating openly and taking responsibility for our actions and decisions. All HGA personnel are expected to be transparent in their work and fully accountable for the outcomes.

Guidelines for transparency and accountability include:

  • Open Communication: Communicate in an open, honest, and timely manner. Share appropriate information with team members, clients, and stakeholders to enable informed decision-making. Important communications – such as project progress, challenges, or changes – should be conveyed promptly and truthfully. We do not withhold information that others have a legitimate need to know.
  • Financial and Operational Transparency: Maintain accuracy and candor in financial matters, billing, and record-keeping. All invoices, expense reports, budgets, and financial documents must reflect actual transactions and adhere to client requirements and auditing standards. Misrepresenting financial information or concealing the true nature of a transaction is strictly prohibited.
  • Accountability for Decisions: Take ownership of your work and decisions. If something goes wrong, do not shift blame unduly – instead, acknowledge mistakes and work to correct them. We expect individuals to hold themselves accountable and also to constructively hold each other accountable to our standards. This means welcoming questions or reviews of one’s work and engaging in problem-solving rather than defensiveness when issues arise.
  • Reporting and Metrics: When managing projects or deliverables, be transparent with clients and HGA about status, results, and any setbacks. Provide accurate reports and updates. If targets may not be met, notify relevant parties in advance and take accountability for developing solutions.
  • Responsible Use of HGA Platform: Our digital platform is designed to foster transparency in matching consultants to opportunities and tracking project performance. Users of the platform must provide truthful profile information, respect open communication channels, and accurately report work progress or hours. The platform’s data and analytics should be used to enhance accountability for deliverables and outcomes.

By embracing transparency, we build credibility with donors and partners who expect openness. By embracing accountability, we demonstrate reliability and a solutions-oriented mindset. In combination, transparency and accountability ensure that “sunlight” is shed on our processes and that each person at HGA can be trusted to own their part in achieving our mission.

Legal Compliance

HGA requires full compliance with all applicable laws and regulations in every jurisdiction where we operate. Following the law is not optional or subject to interpretation – it is the baseline of our ethical practice. Each staff member and consultant is personally responsible for understanding and obeying the laws relevant to their work, with guidance from HGA management or legal counsel as needed. We also commit to upholding the professional standards of our industry and the specific compliance rules of our clients and donors.

Key areas of legal compliance include:

  • General Laws and Regulations: Abide by all laws, rules, and regulations applicable to our work – local, national, and international. This includes laws related to contracts, public procurement, labor and employment, immigration, health and safety, environmental protection, intellectual property, and any other relevant area. We also respect international sanctions and trade controls as applicable. If you are unsure about a legal requirement, seek advice before proceeding.
  • Anti-Corruption and Fraud Laws: Comply with anti-corruption statutes such as the U.S. Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act, as well as any local anti-bribery and anti-fraud laws in the countries where we work[4]. HGA strictly prohibits any form of bribery, kickbacks, or fraudulent practice (these are detailed in Section 7, Anti-Corruption). We also adhere to donor-specific anti-fraud and corruption guidelines when engaged in donor-funded projects[1].
  • Employment and Labor Laws: Follow all applicable labor laws, including those governing wages, working hours, workplace safety, non-discrimination, the rights of workers, and the prohibition of child or forced labor. HGA is an equal opportunity organization and complies with laws protecting human rights and fair labor practices everywhere we operate.
  • Tax and Financial Regulations: Ensure that all financial transactions and accounting practices comply with relevant tax laws and financial reporting requirements. Consultants and staff must accurately report income and pay taxes as required. HGA likewise complies with tax obligations and financial regulations in its jurisdictions. No off-the-books funds or unrecorded accounts shall be maintained.
  • Donor and Client Regulations: Many of HGA’s projects are funded by international donors or governments which impose their own compliance rules. When working on such projects, all team members must understand and follow the donor’s regulations (e.g., procurement rules, allowable costs, code of conduct) in addition to HGA’s Code. For example, the World Bank and other major donors require consultants to observe strict ethical standards, and HGA personnel will adhere to those provisions as if they were fully included in this Code[1][5].

Every individual is expected to be proactive about compliance. If you suspect that an action or decision might violate a law or regulation, pause and seek guidance. HGA will support those who raise compliance questions or concerns. Non-compliance not only risks legal penalties but also damages HGA’s reputation and undermines the trust of clients and beneficiaries. Therefore, violating laws or donor rules is a serious offense that will result in disciplinary measures and potentially legal consequences. By committing to legal compliance, we uphold the rule of law and model the behavior expected by the global development community.

Anti-Corruption and Anti-Bribery

HGA maintains a zero tolerance policy towards corruption in any form. Corruption – defined broadly as the misuse of entrusted power for private gain – is antithetical to our mission and the development outcomes we seek. We will not offer, give, solicit, or accept bribes or improper inducements under any circumstances. This applies to dealings with government officials, clients, partners, vendors, and any other entity. Even the appearance of corrupt behavior must be avoided. Our commitment echoes the strict stance taken by leading organizations; for instance, other international NGOs explicitly prescribe “a policy of zero tolerance towards corruption” with the guiding principle of the highest ethical standards and integrity[6].

Prohibited conduct and requirements under this policy include:

  • Bribery and Kickbacks: No employee or consultant shall directly or indirectly offer, give, solicit, or receive any form of bribe or kickback. A bribe means giving or receiving anything of value (cash, gifts, favors, loans, entertainment, or other advantage) as an inducement to influence a business or governmental decision. A kickback is a payment or benefit given to someone as a reward for facilitating a transaction. These practices are strictly forbidden, whether dealing with public officials or private sector parties. Even in countries where such practices might seem common, HGA staff/consultants must refuse and report any attempted bribe.
  • Facilitation Payments: So-called “grease payments” or facilitation fees – small unofficial payments to expedite routine government actions (like permits or customs) – are considered bribes and are prohibited by HGA policy. We do not authorize any facilitation payments, even if they are claimed to be customary. Any request for such a payment must be declined and reported.
  • Fraud, Collusion, and Coercive Practices: HGA personnel must not engage in fraudulent, collusive, or coercive practices. Fraud includes any act of deceit, trickery, or misrepresentation intended to gain an unfair advantage (such as falsifying financial claims or documents). Collusion involves secret agreements between parties to defraud or cheat others (for example, price-fixing or bid-rigging in procurement). Coercive practices involve harming or threatening to harm persons or their property to influence decisions. All such unethical behaviors are categorically banned. We adhere to donor definitions of these terms – for example, the World Bank prohibits “fraudulent, corrupt, collusive, coercive, or obstructive practices” and HGA fully aligns with that standard[7].
  • International Anti-Corruption Laws: As noted in the Legal Compliance section, we abide by laws like the FCPA, UK Bribery Act, and similar legislation which criminalize bribery and corrupt acts. These laws can have extraterritorial reach (e.g., the FCPA applies to U.S. persons and companies overseas), so all HGA personnel must be knowledgeable about and compliant with them. Violations can lead to severe legal penalties for both individuals and the company.
  • Gifts and Hospitality Controls: Sometimes corruption is concealed as gifts or lavish hospitality. Section 9 of this Code provides detailed rules on acceptable gifts and entertainment. In brief, any gift or benefit intended to improperly influence a decision is strictly disallowed. We maintain internal controls (registers, approvals) to monitor gifts, hospitality, travel expenses, and charitable contributions to ensure they are reasonable, transparent, and not used as a subterfuge for bribery[8].

Our Zero Tolerance Commitment: Every HGA employee and consultant has a duty to actively resist corruption. If you are asked to pay a bribe or encounter any corrupt solicitation, you must refuse and immediately report the incident to HGA management. HGA will support personnel who uphold our anti-corruption policy, even if it results in losing business or experiencing delays. We would rather forgo an opportunity than compromise our integrity. Likewise, if you suspect any colleague or partner of engaging in corrupt behavior, you are required to report it (see Reporting section) so that prompt action can be taken. HGA will investigate all allegations of corruption and take appropriate action, including disciplinary measures or referral to legal authorities.

By enforcing zero tolerance for corruption, HGA protects its reputation, complies with donor expectations, and most importantly, ensures that development resources are used for their intended purpose – the public good – rather than diverted for private gain. This unwavering stance helps create a level playing field and fosters trust with the communities and donors we serve.

Conflict of Interest

A conflict of interest arises when an individual’s personal relationships or financial interests could improperly influence (or appear to influence) their judgment, decisions, or actions on behalf of HGA. All HGA staff and consultants have a duty to act in the best interests of HGA and its clients, and to avoid any situation where personal interest conflicts with professional obligations. Even the perception of a conflict of interest can damage HGA’s credibility, so transparency and proactive management of potential conflicts are essential.

Our policy on conflicts of interest is as follows:

  • Avoid and Disclose Conflicts: You must avoid situations where your private interests (financial, familial, or otherwise) conflict with HGA’s interests or your duties to a client. If such a situation cannot be avoided, you are required to promptly disclose the actual or potential conflict to HGA management so that appropriate measures can be taken[9]. Full disclosure in writing is required as soon as you recognize a potential conflict. Examples of conflicts include: having a significant financial stake in a vendor or subcontractor that HGA is considering hiring; doing outside consulting that competes with HGA’s services; or having close family members employed by a client or beneficiary of an HGA project.
  • Gifts and Favors from Interested Parties: Never allow personal gifts, favors, or hospitality to influence your objectivity (see Section 9 on Gifts). Accepting significant gifts or benefits from a current or potential HGA client, contractor, or partner is a conflict of interest and is prohibited. Such gifts can create a sense of obligation or bias that conflicts with your duty to HGA’s and the client’s best interest.
  • Nepotism and Personal Relationships: Avoid any involvement in hiring, supervising, or contracting decisions that involve your family members or close personal relations. For example, if a family member or spouse is applying for a consulting role or bidding on a contract with HGA, you must recuse yourself from all decision-making and disclose the relationship. Concealing close family relationships or personal connections in matters of hiring or procurement is strictly forbidden[10]. HGA will put mitigation measures in place (such as independent review of decisions) to handle such situations transparently.
  • Multiple Roles and Outside Employment: Consultants often work with multiple organizations. This is acceptable as long as those engagements do not conflict with HGA’s interests or compromise your ability to perform your duties for HGA objectively. You must inform HGA if you are working on any project or contract for another entity that may overlap or interfere with an HGA assignment. Similarly, HGA staff should disclose any outside employment or board service that could pose a conflict. Permission may be denied or conditions imposed if the outside role is seen as conflicting.
  • Procurement Integrity: When involved in evaluating bids or selecting vendors/partners, you must do so impartially and based on merit and predefined criteria. If you have any personal interest in or affiliation with a bidder, you must recuse yourself. All procurement activities must follow applicable donor rules and ethical procurement guidelines, which include avoiding conflicts of interest and not allowing personal connections to influence outcomes[9].

HGA takes conflicts of interest very seriously. All disclosures of potential conflicts will be treated with professionalism, and HGA will determine the appropriate steps to manage or eliminate the conflict (such as reassigning responsibilities, obtaining client consent, or divesting the conflicting interest). Failure to disclose a known conflict, or deliberately masking a conflict (for example, via a third party arrangement), is a violation of this Code and may result in disciplinary action. We expect all individuals to exercise good judgment and when in doubt, err on the side of transparency by disclosing. Maintaining integrity in our decision-making processes is crucial to our promise of being trustworthy advisors “together for a better world.”

Gifts and Hospitality

Exchanging gifts, meals, or hospitality can be a normal part of business and cultural courtesy, but in our sector these gestures carry risks of undue influence or appearance of impropriety. HGA’s policy imposes strict limits and transparency on giving or receiving gifts, entertainment, or other hospitality in connection with our work. The guiding principle is that no gift, favor, or benefit should ever be accepted or given if it might influence, or appear to influence, objective business decisions or the performance of official duties. We maintain a zero-tolerance stance against gifts that function as bribes.

Rules for gifts and hospitality:

  • No Improper Gifts or Favors: Never solicit or accept any gift, favor, entertainment, or benefit in exchange for preferential treatment or an official action/inaction. Likewise, do not offer any such benefit to others to influence them. Any item or courtesy that might sway decision-making or impair impartial judgment is considered improper. This includes money, expensive presents, lavish entertainment, promises of employment, or special discounts not available to others. Even the appearance of a quid pro quo is unacceptable. For example, offering a gift to a client during an active tender process is prohibited.
  • Modest and Token Gifts: Gifts of nominal value that are purely tokens of appreciation and are a common business courtesy (such as pens, calendars, or modest promotional items) may be acceptable, but only if they are of low value and given infrequently. HGA generally defines “nominal” as under USD $50 (or local equivalent), unless local custom dictates a lower amount. Anything beyond a token gift is not permitted. Acceptance or offering of any gifts or favors more than a token (e.g., beyond small office souvenirs) is prohibited[11]. If you are offered a gift valued above a nominal amount, politely decline or, if refusal would be awkward in a cultural context, accept it on behalf of HGA and immediately inform management – HGA will decide how to dispose of it (for example, donating it to charity).
  • Hospitality and Events: Modest hospitality (such as a business lunch or an event with light refreshments) can be part of relationship-building, but it must remain reasonable in scope. Lavish or frequent meals, travel invitations, tickets to entertainment/sporting events, or resort outings paid for by a vendor or client are generally not acceptable. As a rule of thumb, hospitality should not exceed what HGA itself would offer in return and should be limited to standard business interactions. Any hospitality that could create a sense of obligation must be avoided. When in doubt, seek approval from HGA management before accepting.
  • Gifts to Public Officials: Special caution is required in dealings with government or donor agency officials. Many countries and organizations have laws or rules that either forbid or strictly limit what their officials can receive. HGA’s policy is to not give any gifts or payments to public officials to avoid any perception of bribery. In rare ceremonial cases where protocol calls for giving a gift to an official (for example, a symbolic token during an official visit), this must be pre-approved by HGA leadership and properly recorded. Under no circumstance will HGA give cash gifts.
  • Disclosure and Record-Keeping: All personnel must promptly report any gift or hospitality given or received that is more than nominal. HGA maintains a Gifts & Hospitality Register for transparency. Employees/consultants should provide details such as the date, description of the gift or event, the involved parties, and estimated value. Managers will review these to ensure compliance. In some cases, you may be asked to return a gift or reimburse the cost of hospitality if it’s deemed inappropriate. Maintaining clear records ensures that our interactions remain above-board and can stand up to scrutiny[8].

Remember that what might be intended as a simple courtesy in one culture can be viewed as a bribe in another context, particularly in the realm of international development. When representing HGA, always err on the side of caution with gifts and hospitality. It is far better to explain our strict policy to a would-be gift giver (or receiver) than to compromise our integrity or violate the law. By keeping our exchanges modest and transparent, we protect both our personal reputations and HGA’s standing as an ethical organization.

Respectful Professional Conduct

HGA is committed to maintaining a work environment characterized by respect, professionalism, and inclusivity. All forms of harassment, discrimination, or exploitation are strictly prohibited. We value diversity and the unique contributions of each team member, and we insist on a culture where everyone – employees, consultants, partners, and beneficiaries – is treated with dignity and fairness. Professional conduct is expected not only within HGA’s internal team, but also in all interactions with clients, vendors, and community stakeholders. There is zero tolerance for behavior that undermines the rights or safety of others.

Key standards of respectful conduct include:

  • Non-Discrimination: HGA does not tolerate discrimination on the basis of race, color, ethnicity, national origin, religion, gender, gender identity, sexual orientation, age, disability, marital status, political affiliation, or any other characteristic protected by law. All employment and engagement decisions (hiring, promotions, assignments, compensation, etc.) are to be based on merit, qualifications, and business needs – never on biased criteria. We strive to provide equal opportunity and to foster an inclusive environment where diverse backgrounds and perspectives are welcomed.
  • Anti-Harassment: No form of harassment is allowed. Harassment is unwelcome behavior (physical, verbal, visual, or sexual) that creates an intimidating, hostile, or offensive work environment. Examples include derogatory slurs or jokes, offensive comments or images, unwelcome touching or sexual advances, stalking, bullying, or any other conduct that a reasonable person would find abusive or unacceptable. As one respected firm states, “BCG does not tolerate harassment in any circumstances,” and such behavior can take many forms including verbal remarks, sexual advances, or bullying[12]. HGA holds the same high standard globally – all forms of harassment are forbidden, whether they come from colleagues, managers, clients, or any other associates. Client pressure or cultural norms do not excuse harassing behavior.
  • Preventing Sexual Exploitation and Abuse: Particularly in field assignments or interactions with vulnerable populations, HGA staff and consultants must never abuse their position for sexual gain or any form of exploitation. Sexual exploitation is taking advantage of someone (often a beneficiary or subordinate) for sexual purposes – this is strictly prohibited. Consensual romantic relationships that present a power imbalance (e.g. between a supervisor and their team member, or a consultant and a beneficiary in a community) are also inappropriate and must be avoided. HGA supports the international standards on Protection from Sexual Exploitation and Abuse (PSEA) and expects our personnel to uphold those principles in all projects.
  • Professionalism and Courtesy: Maintain a professional demeanor at all times. This includes being courteous in communication, constructive in feedback, and composed under pressure. Even during disagreements or high-stress situations (tight deadlines, challenging field conditions, etc.), everyone is expected to behave civilly and refrain from shouting, insults, or demeaning treatment. Professionalism also extends to appropriate attire and respecting local customs when on assignment.
  • Safe and Healthy Workplace: Violence, threats, or any form of physical intimidation have no place in HGA. We strive to provide a safe work environment free from violence or hazards. Weapons are not permitted at any HGA work site or event. Substance abuse is also not tolerated – being under the influence of alcohol or drugs on the job, or misusing substances in a way that affects work, is a violation of our standards. If someone’s behavior is impaired or unsafe, colleagues should report it so that help can be offered and safety ensured.

Reporting and Addressing Issues: Every individual has a responsibility to speak up if they experience or witness harassment, discrimination, or other misconduct. See Section 12 on Reporting Misconduct for guidance on how to report and the protections in place. HGA will take every report seriously and will not tolerate any retaliation against those who raise concerns in good faith. Managers at HGA are expected to lead by example in fostering a respectful workplace and to promptly address any behavior that undermines these standards. We will also provide training or resources as needed to ensure all team members understand their role in creating an inclusive, respectful environment.

By embracing diversity and insisting on respectful conduct, we create a workplace where everyone can perform to their highest potential, and we mirror the equitable principles that underlie our mission for a better world. Treating colleagues and community members with respect is not only morally right – it enhances teamwork, innovation, and the quality of our engagements.

Confidentiality and Data Protection

In the course of our work, HGA staff and consultants are entrusted with sensitive information. This may include confidential business information about HGA or our clients, personal data of individuals, proprietary technical data, project strategies, reports, financial data, or other non-public materials. Protecting confidentiality and privacy is both an ethical obligation and often a legal requirement. All personnel must safeguard confidential information from unauthorized disclosure or misuse, and handle personal data in compliance with applicable data protection laws (such as the EU General Data Protection Regulation “GDPR”).

Our commitments and rules for confidentiality and data protection:

  • Definition of Confidential Information: Confidential Information encompasses any non-public information that you learn or create through your work with HGA. It includes, but is not limited to, internal business records, proposals, client lists, pricing data, trade secrets, technical designs, research data, software code, client or partner provided information, and any work products or deliverables not yet made public. It also includes personal data about individuals (contact details, CVs, identification numbers, health or financial information, etc.). Essentially, if information is not already public and is labeled or generally understood to be sensitive, it must be treated as confidential[13][14].
  • Non-Disclosure Obligation: You must not disclose HGA’s confidential information to anyone outside the company unless properly authorized and protected (for instance, under a non-disclosure agreement). Even within HGA or a project team, share information only on a need-to-know basis. For client information that we handle, comply with any client-specific confidentiality agreements in addition to HGA’s policies[15][16]. This obligation persists even after your employment or consulting engagement with HGA ends – you remain bound to keep the information confidential until it enters the public domain through authorized channels.
  • Use of Information: Confidential information should be used solely for its intended business purpose – to perform your role or deliver the project work for which it was provided. It must never be used for personal gain or outside purposes. For example, insider information about a forthcoming project or procurement should not be used to advise another bidder, and personal data of individuals should not be accessed or used outside the context of project needs.
  • Data Protection and Privacy: HGA complies with global data protection principles, including GDPR, to ensure personal information is handled lawfully and securely[17]. Any personal data collected or processed (whether it’s data about consultants, HGA staff, survey respondents, etc.) must be: obtained with consent or other legal basis, used for legitimate purposes, kept accurate and up-to-date, and retained only as long as necessary. Personal data is considered a special subset of confidential information that we protect with a high standard of care. If you handle personal data, you must implement appropriate measures (password protection, encryption, etc.) to prevent unauthorized access or breaches. Transferring personal data across borders should be done in line with legal requirements – when in doubt, consult HGA’s data protection officer. Both HGA and each individual are responsible for following applicable privacy laws and agreed standards for data handling.
  • Security Measures: Follow HGA’s IT and data security protocols at all times. This includes using strong passwords, securing laptops or devices, not installing unapproved software, and being vigilant against cyber threats (phishing emails, malware). Do not transmit confidential documents over insecure channels or store sensitive data on personal devices without authorization. If working on the HGA digital platform, ensure that any data you upload is properly protected according to platform guidelines.
  • Third-Party and Client Information: Many of our projects involve accessing clients’ sensitive information or data about beneficiaries. Treat this information with the same (if not greater) level of care as HGA’s own information. Comply with any specific data handling instructions provided by the client or donor. If required, sign additional confidentiality agreements for particular projects and honor those commitments fully.
  • Obligation to Return or Destroy: Upon the completion of an assignment or if asked by HGA or a client, you must return or destroy any confidential information in your possession (including hard copies and electronic files), except for information you are legally required to retain. Confirm in writing that you have done so if requested[18][19]. Do not keep confidential documents for personal use.
  • Reporting Breaches: If you suspect or become aware of any loss, theft, or unauthorized disclosure of confidential or personal data (for example, a lost laptop or a hacked account), you must immediately inform HGA management. Prompt reporting allows us to contain the issue, notify affected parties if needed, and comply with any breach notification laws.

Respecting confidentiality and privacy is essential for maintaining trust – trust from our clients who share information with us, trust from consultants who provide their personal data to our platform, and trust from communities that their data will not be misused. By diligently protecting sensitive information, we also comply with laws and avoid potentially severe penalties associated with data breaches or privacy violations. Each individual’s attention to confidentiality safeguards “information integrity,” which is as important to HGA’s reputation as personal integrity.

Reporting Misconduct and Whistleblower Protection

HGA encourages a culture of openness and accountability where individuals feel empowered to raise concerns about any unethical, illegal, or unsafe conduct. If you see something, say something. Reporting misconduct is not only a right, but a responsibility of all staff and consultants under this Code. We cannot address problems or improve our practices unless we are aware of them. Therefore, HGA provides channels for reporting and guarantees that anyone who reports a concern in good faith will be protected from retaliation.

How to report a concern: If you observe a possible violation of this Code, of HGA’s policies, or of any law or donor regulation, or if you are pressured to do something improper, you should promptly report it through one of the following channels: – Supervisor or Manager: If you feel comfortable, you can report issues to your immediate supervisor or project manager. They are expected to listen and escalate the matter appropriately.
– HGA Compliance Officer or Ethics Focal Point: HGA will designate an individual (or team) responsible for compliance and ethics oversight. You can directly contact this person (for example, via a dedicated ethics email hotline or phone number) to report concerns or seek advice.
– Human Resources: For issues involving workplace conduct (harassment, discrimination, etc.), or personnel matters, you may report to an HR representative.
– Anonymous Reporting (if available): HGA is exploring secure, confidential means (such as an online form or third-party hotline) for individuals to report concerns anonymously if they prefer. Where such a system is in place, details will be communicated to all staff and consultants. Even if you choose to remain anonymous, please provide as much detail as possible to enable a proper investigation.

When making a report, provide clear information: who is involved, what occurred, when and where it happened, and any evidence or witnesses. All reports will be handled with discretion and information shared only with those who need to know to investigate and address the issue.

Non-Retaliation Policy: HGA absolutely forbids retaliation against anyone who, in good faith, reports a concern or participates in an investigation. “Good faith” means you have an honest reason to believe a violation may have occurred, even if it turns out no wrongdoing is found. Examples of retaliation include firing, demotion, reducing pay, harassment, or ostracism of someone because they reported an issue. Such retaliation is a serious violation of this Code. As stated in other professional codes, “In no circumstances will anyone be subject to any form of retaliation for raising a concern in good faith or for participating in an investigation.”[20] This principle is fully endorsed by HGA. If you believe you are experiencing retaliation, report it immediately – it will be investigated and, if confirmed, disciplinary action will be taken against the retaliator.

Whistleblower Protections: Individuals who report misconduct are often referred to as whistleblowers, especially if the issue is serious (e.g., fraud or corruption) and if they are reporting on activities of others. HGA will protect whistleblowers by keeping their identity confidential to the extent possible (consistent with a thorough investigation and legal requirements) and by ensuring they do not suffer negative consequences. We recognize the courage it can take to report problems, and we are committed to creating an environment where people can voice concerns without fear. In fact, HGA views raising a concern as a positive act of loyalty to the organization’s values and mission.

Investigation Process: When a report is made, HGA will undertake a fair and timely investigation. This may involve the compliance officer or an appointed investigator gathering facts, interviewing those involved, and reviewing documents. All employees and consultants are expected to cooperate fully with internal investigations. The investigation will be conducted impartially, respecting the rights of all parties. If misconduct is substantiated, appropriate corrective and disciplinary actions will be taken (as outlined in the next section). Where no wrongdoing is found, the matter will be closed with appropriate documentation. HGA will strive to communicate the outcome of the investigation to the reporting individual (unless reported anonymously) and to relevant stakeholders, within the bounds of confidentiality and privacy.

False Reports: While we encourage all good faith reporting, deliberately making a false accusation – knowingly reporting something you know is untrue – is itself a serious offense. Such behavior can unjustly damage reputations. Any intentional abuse of the reporting system or bad faith allegation will result in disciplinary action. This does not apply to instances where a report was made in genuine belief of truth but later not substantiated – in those cases, there is no penalty for an unconfirmed suspicion raised in good faith.

In summary, HGA’s message is clear: if you suspect something is wrong, do not keep it to yourself. We provide avenues for you to speak up safely. By surfacing issues early, we can address them before they escalate, thereby maintaining the integrity of our organization and the trust of those we serve. Every report is a chance to reinforce our ethical culture.

Enforcement and Disciplinary Actions

Adherence to this Code of Ethics and Professional Conduct is a condition of employment or engagement with HGA. Violations of the Code undermine our mission and will not be ignored. HGA is committed to enforcing the Code consistently and fairly across the organization, regardless of a person’s position or tenure. This section outlines the framework for enforcement, including possible consequences for violations and the processes we follow to address them.

Enforcement structure: Overall responsibility for overseeing compliance with the Code lies with HGA’s leadership (executive management and the Board, as applicable) supported by the Compliance Officer or Ethics Committee. These bodies will ensure that: (a) allegations of misconduct are investigated, (b) appropriate action is taken based on findings, and (c) preventive measures (like training or policy improvements) are implemented to reduce future incidents. Disciplinary decisions will involve the relevant supervisory chain and HR, and in the case of consultants, the contract management team. When donor-funded projects are involved, we may also be obliged to report certain violations to the donor and follow any stipulated remedies (including possibly removing a consultant from a project at the donor’s request).

Investigation of Violations: As described in Section 12, when a report or indication of misconduct arises, HGA will promptly initiate an inquiry. Minor issues might be resolved through managerial fact-finding and counseling, whereas serious allegations (fraud, harassment, corruption, etc.) will likely result in a formal investigation. The subject of a complaint will typically be informed of the core allegations and given a chance to respond or explain their perspective, except in cases where doing so would jeopardize evidence. Investigations will be documented and conducted impartially. If needed, HGA may engage external investigators or legal counsel for complex or sensitive cases to ensure objectivity.

Disciplinary Actions: If an investigation confirms that a violation of the Code (or related policies/laws) has occurred, HGA will decide on appropriate disciplinary or corrective actions. These actions will be proportional to the severity and nature of the offense, and may include one or more of the following:

  • Coaching and Training: For minor or first-time violations that stem from misunderstanding or lack of knowledge, the individual may be given guidance, coaching, or required to undergo additional ethics training. This is a corrective measure to prevent future issues.
  • Verbal or Written Warning: A formal warning may be issued, documenting the misconduct and expectations for improvement. Continued or repeated violations after a warning will lead to more severe consequences.
  • Probation or Suspension: An employee might be put on probation (with closer supervision of their activities) or suspended without pay for a period. A consultant might be suspended from further assignments temporarily.
  • Removal from Project or Role: In some cases, it is necessary to immediately remove an individual from their current project or position. For example, if a consultant’s behavior constitutes serious misconduct (such as fraud or harassment), HGA may remove that consultant from the project immediately due to the severity of the breach[3]. Donor or client requirements may also mandate immediate removal in certain scenarios (like if an individual is found to be debarred or poses a security risk)[21].
  • Termination of Employment/Contract: For grave violations or repeated misconduct, HGA will terminate the employment of the staff member or end the contract of the consultant. Examples of conduct likely to result in termination on the first instance include embezzlement, intentional fraud, bribery, violent behavior, severe harassment or discrimination, willful violation of law, or significant breaches of confidentiality. Termination for cause may render the individual ineligible for future work with HGA. In the case of consultants, HGA reserves the right to terminate the Master Agreement or specific Work Orders for cause if the consultant commits a material breach of this Code or contract terms.
  • Legal Action and Reporting: If the behavior in question violates the law (for instance, corruption, theft, assault, data breach, etc.), HGA may report the matter to law enforcement or regulatory authorities for further action. HGA will cooperate with official investigations as required. Additionally, for donor-funded projects, certain violations may need to be reported to the donor, which could result in sanctions such as the individual or HGA being barred from future contracts.
  • Other Remedies: HGA may seek other remedies as appropriate, such as recovering losses caused by the misconduct (through restitution or legal claims), or in procurement-related cases, re-evaluating contract awards if fairness was compromised. HGA might also issue an apology or correction to any parties adversely affected by the violation, as part of remedying the situation.

The enforcement process strives to be fair and give individuals an opportunity to be heard. However, claiming ignorance of the Code’s requirements or alleging that “everyone does it” will not be considered valid excuses for misconduct. Each person is accountable for their own behavior. HGA will document all disciplinary decisions and maintain records, while also ensuring that personal data and reputational interests are protected during the process to the extent possible.

Consistency and Fairness: HGA is committed to applying disciplinary measures consistently. While each case is considered on its own facts, similar violations will yield similar consequences, regardless of who is involved. There are no “exceptions” based on rank or results – e.g., a high-performing consultant who harasses colleagues will face the same repercussions as anyone else. Our leadership will periodically review enforcement decisions to ensure fairness and consistency with our policies.

Opportunity for Improvement: In cases where an individual remains with HGA after a misconduct finding (e.g., after a warning or suspension), they will be expected to correct their behavior immediately. A plan may be put in place to monitor compliance going forward. Failure to demonstrate immediate and sustained improvement will result in escalated discipline, up to termination.

By enforcing this Code rigorously, we not only address individual incidents but also reinforce to all stakeholders (internal and external) that HGA takes its ethical commitments seriously. Disciplinary action isn’t just punitive – it is a necessary part of upholding our values and protecting the integrity and credibility of Humanics Global Advisors. Ultimately, consistent enforcement deters unethical behavior and helps ensure that “doing the right thing” remains the norm across our organization.

Conclusion

The HGA Code of Ethics and Professional Conduct is more than just a document – it is a reflection of who we are and what we stand for as an organization. By adhering to this Code, each of us contributes to a culture of integrity, trust, and excellence that sets HGA apart. Our collective commitment to ethical behavior enables us to “Together for a better world” – delivering high-quality advisory and consulting services that drive positive change while upholding the highest moral standards.

All HGA staff and consultants are expected to certify that they have read, understood, and will abide by this Code. Keep this Code handy as a reference, and remember that ethical decision-making is a daily exercise. When faced with a tough judgment call, consider our core values and the guidelines herein, consult with colleagues or supervisors, and choose the path that aligns with integrity and transparency.

HGA’s leadership fully endorses this Code and pledges to lead by example. We also commit to periodically reviewing and updating the Code to address new challenges and ensure it remains aligned with global best practices and donor expectations. Ethics is a journey, not a destination – we will continuously strive to improve and uphold these principles in everything we do.

Thank you for your dedication to these standards. By upholding this Code, you help maintain an environment where ethical conduct is the foundation of all success. In turn, that enables HGA to effectively partner with clients and communities in achieving sustainable development outcomes. Let us each do our part to honor this Code, hold ourselves and each other accountable, and work together in the spirit of respect, honesty, and responsibility.

Together, through this shared commitment, we truly can build a better world.