SECTION 4: FINANCE CODE OF ETHICS:

 

The UNAA Executive and UNAA Chapter Officers make significant efforts to promote ethical conduct in the financial management of our association and its activities. Our UNAA Executive Officers, Chapter Officers and UNAA members who are involved with the substantive aspects of the preparation of the internal and external books, records and financial statements of UNAA and our UNAA Chapters play an important role in upholding the integrity of our business information.

 

To uphold the integrity of our business information, the UNAA Executive Officers, the Chapter Officers and each UNAA member are expected to:

• Act with honesty and integrity
• Act responsibly, in good faith, with due care, competence and diligence

 

• Ethically handle actual or apparent conflicts of interest between personal and professional relationships; including, in the case of executive officers complying with local laws.

 

• Provide information that is accurate, timely, complete and understandable, no matter the purpose of the information (such as forecasts, budgets, reports, draft or actual financial statements, and public filings or communications)

 

• Accurately represent material facts and not allow their better judgment to be compromised
• Not let financial data be influenced by others or by factors such as operating unit or individual performance or objectives, plans and forecasts, or organizational commitments or political affiliations.

 

• Not conceal any information from our internal auditors or our Executive Board Members.
• Comply with applicable policies and procedures related to internal controls and the preparation of financial statements

 

• Comply with applicable governmental laws, rules and regulations and with those of appropriate private and public regulatory agencies
• Respect the confidentiality of information acquired in the course of UNAA’s work and take appropriate steps to protect against unauthorized disclosure of confidential information

• Not use confidential information acquired in the course of UNAA’s work for personal advantage
• Share knowledge and maintain skills important and relevant to their positions
• Use responsibly and maintain control over assets and resources used by or entrusted to them
• Immediately bring any concerns regarding questionable accounting or auditing matters, unethical behavior or violations of this Code to the attention of the Chairman of the Audit Committee and of the Board of Directors, whose address will be posted on www.UNAA.org.

 

UNAA will investigate any reported violations of the Code as appropriate.  Any person subject to the Code who is found to be in violation of the Code will be subject to disciplinary action, up to and including termination of membership and legal action. Dishonest reporting could lead to civil or criminal liability and UNAA will cooperate appropriately with investigations and prosecutions. 

 

Any request for a waiver of any provision of the Code by a person who is not an executive officer of UNAA shall be made in writing to the UNAA Board.

Any request for a waiver of any provision of the Code by an executive officer of UNAA shall be made in writing to the Audit Committee. We will disclose any waivers of the Code granted to executive officers of UNAA in accordance with applicable by-laws and regulations.

 

SECTION 5: CONFLICTS OF INTEREST

 

• A conflict of interest occurs when your personal interests interfere or conflict in any way (or appear to interfere or conflict) with UNAA’s.  You may not engage in any personal, business or professional activity, which conflicts or appears to conflict with the responsibilities of your UNAA duties, voluntary or otherwise or with UNAA’s interests since business decisions must be made in UNAA’s best interests and not motivated by your personal interest or gain and even the appearance of impropriety can be damaging to UNAA’s reputation.  You are expected to consider the rights, interests and responsibilities of UNAA’s membership, those outside the association and yourself, and to protect you own reputation and UNAA’s reputation against conflicts.

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  Whether a personal affiliation is a conflict of interest will depend on the facts and circumstances in each given situation.  For this reason, you must treat all potential conflicts as if a conflict exists until you have disclosed and resolved the potential conflict. You are required to disclose in writing to the Office of the Audit Committee, all business, commercial or financial interests or activities where such interests or activities are material and might reasonably be regarded as creating an actual or potential conflict with your UNAA duties voluntary or otherwise to UNAA, so the Audit Council can determine whether the situation is a conflict of interest.

• Some guidelines for complying with this policy include:

  • not entering into transactions where you have, or a family member has, a personal affiliation with a client, supplier or competitor;
    
  • not creating an obligation or distraction that would affect your judgment or ability to act solely in our best interests;
    
  • not taking advantage of discounts or other programs offered by a vendor with whom you negotiate or are responsible for the business relationship;
    not acquiring any interest in a venture or opportunity that you believe UNAA might reasonably be interested in pursuing or developing without obtaining clearance from the Audit Committee; and
    
  • not owning or otherwise participating in a competing or complementary business enterprise.
  
  

  UNAA will investigate any reported violations of this policy as appropriate.  Any member who is found to be in violation of this policy will be subject to disciplinary action, up to and including termination of membership and legal action. In addition, if personal financial benefit is improperly gained by you, directly or indirectly, or through a spouse or child or a relative sharing your residence, as a result of your position and activities with UNAA or by the use or misuse of UNAA’s property or of information that is confidential to UNAA’s business and membership, then you must account to UNAA for any benefit received.

 

SECTION 6: ACCEPTANCE OR SOLICITATION OF GIFTS

 

You may not directly or indirectly offer, solicit, or accept any gratuitous payments, services, gifts, entertainment or other personal benefit, other than as noted below, to or from a past, present or prospective association member, business and interest partner, customer or supplier. All gifts or offers of gifts that are not “nominal” should be reported to the Office of the Audit Committee as soon as practicable.

We recognize certain circumstances when it is lawful and permissible for you to accept a gift or personal benefit or furnish modest gifts, favors or entertainment to persons other than public officials.

SECTION 6: ACCEPTANCE OR SOLICITATION OF GIFTS (cont'd)

The following are guidelines for acceptable gifts:
· The gift has a nominal value, does not violate any laws; and if the gift were disclosed to the public, it would not embarrass the recipient or UNAA and its membership and activities.

· The gift is not in cash, bonds or other negotiable securities;
· The gift is a customary type of gift-such as for a holiday;
· Meals and/or entertainment of a reasonable value, which is generally a value that would be approved by UNAA for reimbursement as an expense on duty; 

· The gift is advertising or promotional materials (such as pens and calendars);
· The gift is an award or honorarium by charitable, educational, civic or other organizations in recognition of meritorious service or accomplishment.
You must immediately notify the Audit Committee or a member of the board when:
· You are offered a cash gift (other than a typical gratuity for those associates who normally receive tips);
· You think the gift may reasonably be thought to influence or corrupt you or you are unsure about the intent of an offer of a gift or the presentation of a gift; or
· The acceptance of a gift may involve or create the appearance of a violation of this policy.
In some situations, the refusal or return of a gift may cause offense that may damage an interest relationship.  You must notify UNAA of such situations.  The UNAA Audit Committee will consult with the UNAA board before determining how to respond to the gift or offer of gift.
No gifts shall be paid for with UNAA funds without the prior written authorization from the UNAA President and UNAA Treasurer or a Chapter head approving the specific disbursement. You must also have the approval of the UNAA President and UNAA Treasurer or a Chapter head and act in compliance with all applicable laws and our policies before conveying anything of value to a public official, including treating the official to a meal.
 UNAA will investigate any reported violations of this policy as appropriate.  Any associate member who is found to be in violation of this policy will be subject to disciplinary action, up to and including termination of membership and legal action.

 

SECTION 7: FOREIGN CORRUPT PRACTICES ACT

 

Introduction and Policy Statement.

The Foreign Corrupt Practices Act (“FCPA”) is a U.S. law intended to prevent the bribery of foreign officials by U. S. persons and domestic concerns doing business overseas.  The following discussion sets forth our policies with respect to the FCPA and explains the basic elements of the law and the penalties for violating it. Since UNAA’s activities cross national borders it is important for all UNAA officials and members to comply with all US laws and the FCPA in particular when acting on UNAA’s behalf voluntarily or otherwise.

• Any UNAA Member who works with government officials while pursuing UNAA activities should be aware of the FCPA and should adhere to UNAA policies requiring compliance with it.  UNAA’s FCPA compliance policies require:
  · Consultation with the Office of the UNAA Audit Committee and UNAA Board before offering or giving anything of value, even minimal value, such as a free lunch or tickets to a sporting event, hotel room to a foreign official or to someone who is in a position to influence a foreign official;
  · Enforcing compliance with our documentation and accounting procedures, especially those regarding the submission and monitoring of UNAA’s and its Chapter’s expenses, and member expenses who may interact with foreign officials.
  UNAA will investigate any reported violations of this policy as appropriate.  Any member who is found to be in violation of this policy will be subject to disciplinary action, up to and including termination of membership and legal action.