Code of Conduct

A Pledge of Professional Conduct

Constructive creative conflict faces into controversial issues with good faith and constructive disagreement, but push back against convention and the status quo.

The concept means that your first loyalty is to the mission and principles of the organization, not to a single person, idea or constituent.

One voice: Decisions are often made by teams and they often involve compromise. However, once made, assuming principles are not compromised and the authority to make the decision is assured, you own the decision. Support it from that point onward.

As a professional, I acknowledge and agree to honor my ethical obligations to my colleagues, stakeholders, business partners and to the clients. I promise to comply with the D&A’s Code of Conduct, to treat everyone fairly and with dignity. I promise to go beyond the letter of our policies and the law and conform to the spirit and intent as well. I promise to take personal accountability for what I do right and wrong. And I promise not to take credit for the work of others but rather to freely give credit and honor the contributions of others. I also promise to -

• Conduct myself in a manner which reflects great credit on the organization, my colleagues, on the industry and myself.
• Speak the truth with no intent to deceive or mislead by technicalities or omissions.
• Ensure my performance reports are accurate and honest and include progress, problems, and plans.
• Refrain from behavior that harms the public’s perception of the organization.
• Honor all agreements I make with colleagues and stakeholders.
• Ensure that proprietary information of the organization is kept proprietary.
• Avoid actual or perceived conflicts of interest and, if in doubt, to openly disclose and discuss my concerns.
• Take personal accountability for my actions – for success and failure.
• Take personal responsibility for recognizing and reporting breaches of the Code.
• Discharge my responsibilities with dedication to achieving the company’s mission and in line with the company’s principles.
• Serve all constituents of the company’s impartially, and provide no special privilege to an individual constituent or organization.
• Not to accept special personal compensation from an individual constituent beyond the limitations established by principle or policy, which include full disclosure and arm’s length dealings.
• Comply with all levels of governmental regulations and company’s policy concerning lobbying and political activities and using only legal, ethical and moral means when attempting to influence legislation or regulations affecting the company or the convention and visitor industry.
• Disclose information that belongs in the public domain freely and completely but protecting that information which is confidential (generally related to business plans, activities in the marketplace, and personal information relating to character and competence of people within the organization or stakeholders [including sponsors]). Compensation information relating to the Leadership Team is meant to be in the “open book” category.
• Issue no false or deliberately misleading statements or advertisements concerning the company, , or the convention and visitor industry to the media, the public or any other persons, either affiliated with or unrelated to the convention and visitor industry.
• Actively encourage diversity of thought and background through the inclusion of qualified people from diverse backgrounds including ethnic or racial minorities, women, and refuse to engage in and or sanction discrimination on the basis of race, gender, age, religion, national origin, sexual orientation, physical appearance, or disability.
• Refuse to engage in and or sanction activities for personal gain at the expense of the organization.
• Strive to build collaborative relationships with other industry professionals and others for the advancement of the profession of destination management.

The Basic Tenets

Each of us is required to observe the highest standards of honesty and integrity in dealings with each other, others in the business community, and internal and external stakeholders. The principles and policies that follow, and those policies found in the Employee Handbook, define those responsibilities.

A Description of Ethics, Values and Integrity

Ethics: In this context, ethics defines what is right and wrong, good and bad, acceptable and unacceptable. Ethics define our moral obligations to all those with whom we interact, to the company and to all stakeholders. Our ethics and values are the principles of conduct governing us as individuals and as an organization and they conform to accepted proper professional and personal standards of conduct as well as “public policy” using the legal and morale definition of a “reasonable person.”

Values: Values are our belief system. They are what we believe to be fundamentally important to the Company in terms of how we conduct ourselves and the company’s business. They are the personal and professional characteristics that form the bedrock and foundation of our organization.

We Value

Accountability, transparency and integrity and we don’t accept obfuscation, evasiveness, and half-truths meant to mislead or, even worse, to deceive.

Personal responsibility for what happens right and what happens wrong and we don’t accept hiding behind organization or team accountability.

Personal and organizational integrity to be counted on to do what is right because it is right versus finding the self-serving solution.

Creativity and innovation– finding new ways to accomplish the mission rather than reheating what used to work yesterday.

Integrity: Integrity refers to an unwavering adherence to a high standard of personal conduct, beliefs or set of values in all activities and under all circumstances. Integrity precludes resorting to hedging, quibbling, evasive or misleading behavior, or statements.

Areas to Which the Code of Conduct Applies

Public Policy, Compliance and Laws: Employees are expected to obey all, state and local laws in their personal lives and in meeting their responsibilities as members of the staff of the Company. This includes adherence to laws and public policy prohibiting sexual or other forms of harassment or discrimination. More importantly, we are expected to follow the spirit of the law – its principles and intent – even more than the letter of the law.

Principles vs. Policy: Specifically, we are driven by principles and not by the “policies” designed to accomplish them. That is, we acknowledge that we are not a bureaucratic organization subject to rules but rather an organization of thinking people who will take prudent actions to accomplish the mission, while at the same time, stay the course of ethical conduct.

Conflicts of Interest

All decisions, activities and affiliations are to be undertaken in the best interest of the company and the public good without the possibility of creating a hint or the perception of impropriety. In this regard, we are not meant to look after the best interest of any single person, stakeholder, or constituent, but rather the organization’s mission and principles, a concept we call “first loyalty” to the organization’s mission and principles.

Outside employment: Employees may work for themselves or others while a full time employee of the company but this is subject to a number of specific safeguards. The major provisions are:

• Outside employment must be arm’s length, fully disclosed, and approved by the Competent Authority in advance.
• The outside work may not distract from the employee’s primary responsibilities to the Bureau.
• Employees may not use proprietary or confidential information that belongs to the bureau without the written permission of the Competent Authority
• Employees may not work in a field which would be compromising or embarrassing to the Company.
• Employees may not use bureau resources such as pc’s, software, telephones, copiers, or fax equipment without authorization.
• Outside work may not be conducted on bureau property or on company time without written authorization.
• Employees may reveal that they are members of the Company staff, but not in a way that would result in awkwardness or embarrassment for the Company.

If the company determines that an employee’s outside work interferes with his or her performance or ability to meet the job requirements, he or she may be asked to terminate the outside employment or to resign from the Company

Gifts and Special Treatment: Transactions between the Company and outside organization that includes or appear to include an unusual gain, favors, gifts, special price breaks, kickbacks or other individual benefits to employees is not allowed.

Employment of Relatives: This is permitted provided that the relationship is fully disclosed and arm’s length, with no favorable treatment, and subject to the same screening and employment standards of others. In addition, relatives may not work in a direct reporting relationship or deal with the confidential information relating to each other.

Books and Records: Will be maintained in a manner that accurately reflects all company’s financial transactions, performance history and activities. Falsification of Company records regardless of motive is strictly prohibited including personal and organizational accountability for end-results, total transparency from the standpoint of accurately reflecting “what happened”, and integrity in the process in that it fits together and makes sense. Falsification, obfuscation, or intent to deceive or mislead through organization records regardless of motive is unacceptable.

Zero Tolerance: All breaches of ethical conduct will have a measured response based on the nature of the offense, 100% of the time. (This does not mean automatic termination, but it does mean a full investigation, and if found guilty, a punishment equal to the nature of the offensive, including civil or criminal prosecution if warranted.

Personal Behavior: This requires treating each other with respect and dignity; telling the truth, without quibbling or evasive statements; making decisions and taking action using the highest standards of honesty and ethics. It means listening to each other, respecting each other’s ideas and respecting and honoring the diversity of opinions. Personal behavior also includes appropriate actions to maintain a business atmosphere.

Fraud Aspects of the Code of Conduct

D&A’s position on fraud, misappropriation and similar acts is one of zero tolerance. These acts may result in immediate termination or suspension, pending an internal or legal review of the facts. We also believe that we are duty-bound by our obligations to each other and to stakeholders to prosecute illegal acts and to require restitution, in the belief that it is not appropriate to allow the organization to suffer the consequences of acts of malfeasance or misfeasance by members of the organization.

We also believe that we are duty-bound to pro-actively find and report such acts – that this is not a passive injunction, but rather an obligation.

We also believe that these actions are the personal responsibility of each member of the staff, regardless of position. That is, each of us is positively and proactively required to recognize and report fraud and related areas of misbehavior, and that the company is responsible for the investigation and resolution of issues related to suspected fraud, embezzlement, misappropriation and other similar irregularities.

The term “fraud” as used in this policy includes misappropriation and other irregularities including dishonest or fraudulent acts, embezzlement, forgery or alteration of negotiable instruments, misappropriation of company, employee, customer, partner or supplier assets. It also includes conversion to personal use of cash, supplies or any other assets, unauthorized handling or reporting of company transactions and falsification of records or financial reports for personal or other reasons.

Fraud also includes performance reports intended to mislead or deceive, whether or not the fraudulent reports result in payments based on a performance-based compensation plan.

The above list is not inclusive but intended to be representative of situations involving fraud. Fraud may be perpetrated not only by company’s employees, but by agents and other outside parties as well. All such situations require specific action by the Company.

Responsibilities of the Staff, Investigation Procedure, and Disciplinary Measures

All staff members: Every staff member has an ethical obligation to report breaches of this Code of Conduct without a misguided loyalty to any person who abuses the policy. Loyalty to an individual who would put the organization’s reputation in jeopardy and do harm to other employees is a profoundly misguided act. If no action is taken upon reporting a violation, the staff member should make the report to the next level of management.

Retribution: It is a violation of this Code of Conduct and company policy as well as public policy to intimidate or impose any form of retribution on an employee or agent who utilizes reporting procedures in good faith to report suspected violations.

Ethics Committees: There is an Ethics Committee of the company is headed by the Company and an Ethics Committee of the Board, each with explicitly assigned responsibilities and the authority to act on the company’s behalf, subject to an explicit grant of authority by the full board.

Disciplinary Measures: Supervisors, managers, the Leadership Team, the Company and Board, each subject to explicit grants of authority from the full board, will determine whether violations of the Code or the spirit or intent of the Code have occurred. If so, they will determine the appropriate disciplinary measures to be taken. The disciplinary measures may include counseling, oral or written reprimands, warnings, probation or suspension without pay, demotions, reduction in salary, termination of employment, required restitution and the filing of appropriate civil or criminal charges. Restitution will be required in all cases.

People subject to disciplinary measures: The violator, others involved in the wrongdoing such as people who fail to use reasonable care to ensure the violation doesn’t happen in the first place, people who should but fail to detect a violation, people who withhold material information regarding a violation, and supervisors who approve or condone the violations or attempt to retaliate against employees or agents for reporting violations or violators.

Loyalty is critically important to the principles and mission of the company, but not to a single person or member of the board. If no action is taken upon reporting a violation, the staff member is obliged to report the incident to the next level of management.

Investigation of Violations

If the company receives information regarding an alleged violation of this Code (such a sexual harassment, fraud, or similar actions) those persons authorized and appointed by the authority to investigate alleged violations will:

• Evaluate such information as to the credibility and gravity of the allegations,
• Undertake a formal investigation,
• Prepare a report of the investigation results with recommendations as to the disposition of the issue, and
• Disclose results to law enforcement agencies if warranted by the nature of the violation,
• Ensure a complete resolution of the event in a timely manner.

Persons Responsible

The board of directors has an explicit obligation to set the moral tone of the organization. The board usually accomplishes this by assigning explicit responsibilities to the chief executive, who will establish and communicate this Code-of-Conduct and expected standards to a specific member of the staff – generally the chief financial officer or head of Human Resources – as well as to every single person in the organization. Staff members are obliged to report breaches – the assigned Ethics/Compliance Officer is responsible to investigate, resolve and close each incident. Each person on the Leadership Team, the Senior Staff, managers and supervisors, and all others have explicit responsibilities for recognizing, reporting, and otherwise responding to such issues.

Disciplinary Measures are addressed separately.