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Code of Ethics
Note – This policy applies to all employees and contingent workers both on-site and remote.
Duty of Confidentiality
It is the duty of Vanguard Charitable employees and contingent workers to keep confidential any non-public information they may obtain while working at Vanguard Charitable. This information includes, but is not limited to:
- Information on current or prospective Vanguard Charitable clients (e.g., their personal information, Investments, or account transactions).
- Information about other employees (e.g., their pay, benefits, position level, and performance ratings).
Employees and contingent workers must not reveal confidential information to any party that does not have a clear and compelling business need to know such information. Employees and contingent workers are required to conduct work, both on-site and remote, in a secure environment so that others cannot overhear conversations or view their screens.
Standards of Conduct
Vanguard Charitable consistently seeks to earn and maintain the trust and loyalty of our clients by adhering to the highest standards of ethical behavior. Accordingly, Vanguard Charitable employees and contingent workers must conduct themselves with the following standards of conduct:
- Vanguard Charitable Clients' interests come first. Employees and contingent workers must always place the interests of Vanguard Charitable clients first.
- Conflicts of interest must be avoided. Employee and contingent worker actions, decisions, and interests should not compete or conflict with Vanguard Charitable’s interests or the interests of Vanguard Charitable clients. See the Conflict-of-Interest policy.
Outside Business Activities
Employees and contingent workers are permitted to engage in outside business activities (permanent, part- time, or one- time assignment) during their personal time. However, those activities should not adversely affect Vanguard Charitable or present a conflict of interest. Employee and contingent worker jobs and assignments at Vanguard Charitable should come first over other business opportunities, nonprofit activities, or a second job. Be mindful of potential conflicts, obtain any necessary approvals, and be aware employees or contingent workers may be required to discontinue an activity if a conflict exists.
Gifts
- Employees and contingent workers may accept the following gifts from a third party. No other gifts may be accepted.
- Perishable items such as food, flowers, and plants. These gifts should be shared with other work colleagues—for example, with the department or business unit.
- Gifts that are promotional in nature, are of nominal value, and bear a company's logo or similar third- party branding (e.g., pens, coffee mugs, and baseball caps).
- Discounts or rebates that are offered to the general public or to all employees and contingent workers.
- Other types of gifts under U.S. $100 or currency equivalent, but only if approved by a Designated Officer.
Note – This policy applies to all employees and contingent workers both on-site and remote.
Duty of Confidentiality
It is the duty of Vanguard Charitable employees and contingent workers to keep confidential any non-public information they may obtain while working at Vanguard Charitable. This information includes, but is not limited to:
- Information on current or prospective Vanguard Charitable clients (e.g., their personal information, Investments, or account transactions).
- Information about other employees (e.g., their pay, benefits, position level, and performance ratings).
Employees and contingent workers must not reveal confidential information to any party that does not have a clear and compelling business need to know such information. Employees and contingent workers are required to conduct work, both on-site and remote, in a secure environment so that others cannot overhear conversations or view their screens.
Standards of Conduct
Vanguard Charitable consistently seeks to earn and maintain the trust and loyalty of our clients by adhering to the highest standards of ethical behavior. Accordingly, Vanguard Charitable employees and contingent workers must conduct themselves with the following standards of conduct:
- Vanguard Charitable Clients' interests come first. Employees and contingent workers must always place the interests of Vanguard Charitable clients first.
- Conflicts of interest must be avoided. Employee and contingent worker actions, decisions, and interests should not compete or conflict with Vanguard Charitable’s interests or the interests of Vanguard Charitable clients. See the Conflict-of-Interest policy.
Outside Business Activities
Employees and contingent workers are permitted to engage in outside business activities (permanent, part- time, or one- time assignment) during their personal time. However, those activities should not adversely affect Vanguard Charitable or present a conflict of interest. Employee and contingent worker jobs and assignments at Vanguard Charitable should come first over other business opportunities, nonprofit activities, or a second job. Be mindful of potential conflicts, obtain any necessary approvals, and be aware employees or contingent workers may be required to discontinue an activity if a conflict exists.
Gifts
- Employees and contingent workers may accept the following gifts from a third party. No other gifts may be accepted.
- Perishable items such as food, flowers, and plants. These gifts should be shared with other work colleagues—for example, with the department or business unit.
- Gifts that are promotional in nature, are of nominal value, and bear a company's logo or similar third- party branding (e.g., pens, coffee mugs, and baseball caps).
- Discounts or rebates that are offered to the general public or to all employees and contingent workers.
- Other types of gifts under U.S. $100 or currency equivalent, but only if approved by a Designated Officer.