National Geographic Society’s success is built on the foundation of each staff member acting according to the highest standard of ethical behavior, including honesty, fairness and transparency.

Our Code of Ethics establishes this as the fundamental requirement for everything you do on behalf of the Society. The Code also serves as a roadmap to put the Society’s ethical standards into practice. It summarizes some of our key policies for doing business consistent with our standards, and the law. The Code does not describe all policies, or the underlying laws each of us must follow; nor does it give full details on any individual policy or law. It offers links to additional information (including underlying policies) and contacts to help answer any questions you might have, or resolve difficult situations you might face.

Reading the Code of Ethics is not a substitute for reading and familiarizing yourself with National Geographic Society’s policies. You are responsible for understanding and following all Society policies that apply to your position. If you are unclear about those policies, or how to comply with them, it is your responsibility to find out. There are many resources available to help including your manager, Human Resources, Legal and Business Affairs (L&BA) and the Society’s Ethics Officer. Contact information is available on the last page of the Code.

Importantly, we expect our third party representatives (independent contractors, agents, consultants, suppliers, business partners and others who support our mission or receive our funds) to act with the same high standards that our Code of Ethics requires of us, and to comply with all policies applicable to the work they do on National Geographic Society’s behalf.

Our brand trust and reputation is ultimately the result of the personal integrity and highest standards of ethical conduct you demonstrate in everything you do for National Geographic Society.

You must exercise the highest standard of ethical decision making, and sound professional judgment regardless of where or when you are doing business on National Geographic Society’s behalf. There are two basic principles that must guide your actions:

1. Conduct every aspect of your business in a fair, lawful, and ethical manner;
2. Encourage and expect everyone you work with to do the same.

We are deeply committed to performing our mission in a manner that earns the respect of everyone we interact with including: charitable donors, business associates, third party representatives, Society members, our staff, explorers, fellows, grantees and the general public. We believe that the consistent application of our standard of ethical conduct is the best way to do it.

You are responsible for promoting the Society’s mission in a fair, ethical and professional manner. The professionalism you demonstrate in your work helps us sustain and enhance the Society’s reputation. It’s also what makes the Society a great place to work.

The Society is proud of its professional and congenial work environment, and will take necessary steps to ensure that the environment is a productive one that complies with all applicable laws. The Society prohibits discrimination against and harassment of any employee, applicant, contractor, or other third party. All individuals working for or on behalf of the Society must treat each other with respect and avoid discriminatory, offensive, or demeaning behavior.

Discrimination and harassment may subject both the Society and the person responsible to liability. NGS has zero tolerance for policy violations confirmed as a result of an internal investigation, and will take action appropriate under the circumstances to address such violations, up to and including termination of employment or business relationship (for third parties). The zero tolerance policy applies to both illegal harassment and discrimination as well as behavior that, while not illegal, conflicts with a productive, professional work environment.

See the Nondiscrimination and Anti-Harassment policy for additional information.

Most potential conflicts can be resolved in a simple and mutually acceptable way. The key is to disclose it promptly–before it becomes an actual conflict that could compromise your responsibility to act in National Geographic Society’s best interest exclusively.

A conflict of interest arises when you, a family member or close friend have a business, financial or personal interest in the other side of a transaction or business dealings with National Geographic Society. You must always act in the best interest of National Geographic Society. This includes being sensitive to situations where it might appear your responsibility to the Society is compromised.

Here are some ways a conflict of interest might arise:

• A personal, family, or financial interest in any Society transaction;
• Acting as an employee, consultant (or providing any other assistance) to a competitor;
• A financial interest in a competitor, supplier, contractor, grantee or fellow; consultant, or other business partner;
• Hiring or supervising a family member;
• Accepting gifts, discounts, services beyond policy limits from anyone doing (or seeking) business with National Geographic Society.

If you have a potential conflict, you must report it to your manager – before you engage in any activity, related to the situation. Your manager, in consultation with you, Human Resources and L&BA, will determine what measures should be taken to resolve it appropriately. Such measures typically include recusing yourself from any decision relating to the matter. If you are unsure, but have questions, get help from your manager, Human Resources, L&BA, or the Society’s Ethics Officer.

EXAMPLES

Here are some examples of conflicts of interest. They are illustrative, not exhaustive, and are intended to enhance your ability to spot potential conflicts, and ask questions so they may be resolved appropriately:

• An employee selects a supplier where the employee’s spouse is an owner, partner, director or officer of the supplier, or otherwise has a financial stake in the supplier’s business.
• An employee negotiates an agreement on behalf of the Society with a business partner
• An employee approves a grant application by a family member without disclosing the relationship to a higher-level manager and seeking guidance as required.
• An employee oversees grant fulfillment activities of a grantee organization for which the employee serves as a board member.

GIFTS AND GRATUITIES

Staff members may not receive any gift worth more than $100 from any person or organization doing business with National Geographic Society. Staff members involved in purchasing decisions must take extra care to avoid any gifts that might affect, or appear to affect, their decision-making responsibilities on behalf of National Geographic Society.

If you think that an improper payment has been solicited, offered or made, you must report it promptly to the ethics officer or another contact listed on the last page of the code.

Every country we work in has laws against corruption and bribery. We take compliance with these laws seriously. As a U.S.-based organization, National Geographic Society focuses particular attention on the anti-bribery standards of the U.S. Foreign Corrupt Practices Act (the FCPA).

We may not offer, promise, pay, give or approve any bribe, kickback or other inducement in the form of cash or anything else of value (such as gifts, travel, entertainment, charitable contributions) to any person or organization, with the intent to exert improper influence over the recipient, induce the recipient to violate their duty of loyalty, secure an improper advantage for National Geographic Society, or improperly reward the recipient for past conduct. Normally we allow any third-party representative (such as a customs clearance brokers, independent contractors, consultants, business partners, or anyone else) to do so on our behalf.

Our Anti-Corruption policy sets standards that must be followed in our relationships with Explorers, Fellows, Grantees, Third-Party Representatives, Field Workers (“fixers”), Exhibitors and recipients of charitable donations. Additionally, there are special standards that apply to our interactions with government officials (including travel, accommodations, meals and entertainment).

We rely on the generosity of individuals and organizations that support our mission. We take our obligation for responsible business and financial stewardship very seriously.

RESPONSIBLE USE OF ASSETS AND EXPENDITURES

The responsible expenditure of financial resources, and use of National Geographic Society’s assets, is essential to the Society’s sound management, maintenance of our reputation, and the continuing confidence of our donors and partners.

To ensure that our financial statements properly reflect our assets, liabilities and transactions the financial records each staff member submits must be complete, accurate and understandable. This includes the information each of us provides in payroll documents, time cards, travel and expense reports, purchasing, and every other National Geographic Society financial record. The key principles you must follow in your business dealings, expenditures and record keeping include:

• Act ethically, professionally and responsibly at all times handling NGS resources (funds, trademarks and other property).
• Be conservative when spending National Geographic Society’s money.
• Be accurate, thorough and truthful in your business records.

RESPONSIBLE BUSINESS CONDUCT

All contracts with third parties (such as independent contractors, consultants, vendors, suppliers, business partners and others) must be approved by L&BA in advance of National Geographic Society doing business with the third party, and a contract must be in place before work begins. No contractual agreement will be considered valid and enforceable by the National Geographic Society in the absence approval.

Respect for intellectual property, including copyrights and trademarks owned by National Geographic Society and others, is critically important to us. Each of us is responsible for ensuring that these rights are upheld. You must contact L&BA in order to obtain a license, or other appropriate clearance, prior to using any intellectual property in your work on behalf of the Society.

We comply with all U.S. government trade sanctions. These sanctions may prohibit or restrict travel to certain countries, business activities (such as grants, contracts, collaborations) involving certain countries, nationals, entities or individuals and items (such as laptops, smart phones, technical equipment) that may be exported to certain countries.

Each of us is responsible for protecting National Geographic Society’s information technology systems (including our computer network, hardware, software and all related applications). We must do our part to protect these systems from damage, alteration, theft, fraud, misuse and unauthorized access.

The Communications Team is exclusively responsible for handling all media inquiries concerning the Society as well as overseeing the creation and use of National Geographic Society sponsored social media.

National Geographic Society may engage in specific, limited lobbying in the U.S., and internationally, in support of our mission. The Society must document its lobbying activities and confine them to acceptable levels in order to maintain the Society’s status as a tax exempt, not- for-profit organization. The Society may not engage in any type of political campaign activity.

Each of us shares the privilege and responsibility of upholding the Society’s reputation. You do this each time you act ethically and legally.

OPEN DOOR

We recognize that there are situations in which making the right decision can be challenging. By raising concerns, sooner rather than later, you give National Geographic Society the opportunity to resolve issues that might otherwise be damaging to our mission and reputation.

Many of these issues can best be resolved in consultation with your manager, or the next higher level of your management. All managers are responsible for maintaining an “open door” to staff. Alternatively, you may contact Human Resources, L&BA or the Society’s Ethics Officer. We are here to support you doing the right thing.

REPORTING POTENTIAL VIOLATIONS

If you believe that a violation of law, our Code of Ethics or policies may have occurred, or is going to occur, you are affirmatively obligated to report it immediately. While we hope you feel comfortable discussing it with your manager, we recognize that there may be times when you prefer to use another avenue for addressing an issue. You should feel comfortable reporting the issue to any one of the following: your next level manager, Human Resources, L&BA, the Society’s Ethics Officer, the President & COO, the CEO or any member of the Board of Trustees.

As an additional avenue for reporting actual and potential violations, National Geographic Society offers an external Helpline available to you 24 hours a day, 7 days a week, 365 days a year. The Helpline is operated by an independent third party who specializes in these services. You may submit an email, web-based or automated phone report, and you have the option of speaking to a trained customer service representative who will listen to your concern. You may contact the external helpline at (888) 647-0647 (888-NGS-0-NGS), or [email protected], or www.intouchwebsite.com/NGS.

Reports to the helpline can be made anonymously, but we strongly encourage you to identify yourself. This helps ensure your concern is thoroughly considered and appropriately addressed. You can arrange to receive and respond to follow up communications through the helpline even if you choose to be anonymous. We ask that you make these arrangements in order for us to communicate with you about the issue. Reports are referred to the Ethics Officer for appropriate handling.

INVESTIGATION AND RESOLUTION

All reported violations of law, our Code of Ethics or policies will be investigated promptly, objectively and thoroughly. National Geographic Society treats these as confidential internal matters. Information about them is shared only to the extent necessary to investigate and take any corrective action National Geographic Society deems appropriate for resolving the matter consistent with our standards and law.

Staff members found to have committed violations are subject to disciplinary action up to and including termination of employment and possible legal action depending on the violation.

Similarly, third party representatives, and others acting on our behalf, are subject to having their business relationship with National Geographic Society terminated, and potentially other penalties, for violations.

Effective, honest and open communication are indispensable in everything we do for National Geographic Society – including our efforts to support the timely and effective resolution of potential issues.

WE DO NOT RETALIATE

Retaliation against any staff member who reports misconduct is strictly prohibited and will not be tolerated. Staff members are expected to seek advice, raise concerns, report potential misconduct in good faith and cooperate with the investigative process. This is critical because silence hurts us when it comes to ethics and compliance.

If you feel you have been retaliated against for making a good faith report, be sure to contact one of the resources listed on the last page of the Code.

Managers have a special responsibility to model our Code of Ethics with words backed up by actions that set a strong example for all to follow, including:

• Never ignore illegal behavior, Code of Ethics violations, policy violations or other conduct that does not meet our high expectations for ethical and lawful conduct;
• Ensure that the staff and third parties you manage are familiar with our Code of Ethics, and understand the importance of our strong ethical and compliance culture;
• Create a work environment where staff feel comfortable discussing our Code of Ethics, and speaking up when they have concerns;
• Promptly escalate concern about a potential violation of law, our Code of Ethics or policies to L&BA.
• Never retaliate against a staff member who reports a concern about suspected or actual misconduct, or tolerate retaliation by anyone else.

National Geographic Society requires staff members and Trustees to certify compliance with the Code of Ethics, policies and applicable laws annually.

HUMAN RESOURCES

Mara Dell, Chief Human Resources Officer
202-807-3922
[email protected]

Yvonne Perry, Vice President
202-807-3253
[email protected]

LEGAL & BUSINESS AFFAIRS

Sumeet Seam, Chief Legal Officer
202-807-3154
[email protected]

Jeanne Fink, VP, Senior Associate General Counsel
202-807-3129
[email protected]

Agnes Tabah, VP, Senior Associate General Counsel
202-807-3301
[email protected]

ETHICS HELPLINE

(888) 647-0647 (NGS-0-NGS)
[email protected]
www.intouchwebsite.com/NGS