HomeMy WebLinkAbout6 Code of Business Conduct Agenda Item #
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TRUCKEE DOININER
Public Utility District
Memorandum
To: Board of Directors
From: Nancy Waters, Human Resources Administrator
Date: November 1, 2006
Subject: Code of Business Conduct
WHY THIS MATTER IF BEFORE THE BOARD:
The District needs to implement a written policy on ethical business conduct. The Board
reviews and adopts all policies.
HISTORY:
The District's auditors, Virchow Krause, recommended that the District adopt a written
policy on standard business conduct. A first draft of a policy was presented in a
workshop at the May 17, 2006 Board meeting. Suggested changes were made and a
second draft was presented at the last Board meeting. The changes suggested at that
meeting have also been made.
NEW INFORMATION:
A third draft of the Code for Business Conduct is attached for the Board's review and
discussion.
RECOMMENDATION:
I recommend that the Board approve and adopt this version of the Code of Business
Conduct policy.
TRUCKEE DONNER PUBLIC UTILITY DISTRICT
CODE OF BUSINESS CONDUCT
Introduction
The Truckee Donner Public Utility District is committed to behaving in a fair,
honest and ethical manner for all activities conducted on behalf of the District. This
Code of Business Conduct is intended to be a constant reminder of that commitment
and a statement of how we will conduct ourselves on a daily basis. As a statement of
our values and the procedures that will be followed to ensure that these values are
upheld, all employees are expected to know and understand the standards and
expectations set forth herein.
The District believes that ethical standards are achieved not just through the
publication and dissemination of thy, document, but through open and ongoing
discussion about ethical issues related t business and activities of this District.
This District operates in an open-door climate vher employees understand that they
can openly raise questions and concerns tith fear of retaliation. Further, this Code
of Business Conduct not'eaustive designed only to provide guidance to
employees in hove try are erected to carry out their duties. When in doubt,
employees are expected%to use tgient and to raise questions.
standards of Conduct
Employees are expected to uphold the values of the District and are required to
report any situation where the individual reasonably suspects any activity that may be in
violation of the law, board policies, the Memorandum of Understanding (MOU), or this
Code. Standards of conduct include:
• Employees are expected to deal honestly and fairly with customers, co-workers,
suppliers and others having dealings with the District.
• Employees are expected to conduct themselves in a professional, business-like
manner while performing their jobs or representing the District in any manner.
• Employees are prohibited from offering or accepting bribes, kickbacks or other
forms of improper payment from anyone. They are prohibited from receiving gifts,
paid trips or favors of more than nominal value from customers or suppliers. If in
doubt, the party is expected to ask if the proposed gift 0favor is of more than
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"nominal value."
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• Employees are expected to limit their reimb tsAble expenses those that are
rudent and business-related ��
necessary, p ��
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• Employees are prohibited from taking unfair � e of customers, suppliers
or other third parties through manipulation, cenalment, abuse of privileged
information, or any other unfair-dealing practice.
Conflicts of Interest
A conflict of interest exists when an employee is called upon to make or is
involved in any decision that creates or appears to create a conflict between their
personal interests and the business interests of the District.
Employees must not seek any personal benefit through any arrangement with
vendors, suppliers 'or other parties that have a business relationship with the
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District.
• In any situation where it may reasonably be perceived that there is a conflict of
interest, the employee is required to report that potential conflict of interest to
their supervisor or the General Manager.
• In addition to these general standards on conflicts of interests, employees shall
abide by the Conflict of Interest policy adopted by the Board of Directors of the
Truckee Donner Public Utility District, District Code Section 2.52.
Confidentiality of Information
Employees are frequently entrusted with confidential information. This may
include technical or financial information, personnel information, medical information,
customer lists, and other information that, if disclosed, might be a violation of personal
privacy, HIPAA laws, or could be potentially harmful to suppliers, customers, Board
members or employees. This information is the property of the District.
Employees shall:
• Not discuss confidential information with or in the presence of unauthorized
persons, including family members and friends.
Use confidential information � � the District's legitimate business purposes
and not for personal gain.
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• Not disclose cof.11.0 third parties unless such disclosure is
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necessary fad business } rposes, t4- result of a court order or is otherwise
required and appropriate, ar, put in place.
Not use District inform a,�„or other property or resources for any personal gain
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or for the gain of anyone elm.
Customer Communications
In communicating with our customers, the District is committed that it shall:
• Provide all information to which customers have a legitimate right.
• Provide information that is accurate and understandable.
Financial Reporting and Recordkeeping
The Truckee Donner PUD shall:
• Follow generally accepted accounting principles and other prescribed rules and
regulations of other applicable regulatory bodies having jurisdiction.
• Maintain a system of internal accounting controls that will provide reasonable
assurances that all transactions are properly recorded and that material
information is available to management when required.,.
• Maintain books and records that accurately and fairly reflect the District's
financial health.
Maintain a records retention sym it enstr the District's records and
documents are preCained and cured.
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• Conduct an annuail find, Ud to provide an independent, objective review o
financial reports, and,.'-",",tidentify any risks associated with the system of internal
controls.
Legal and Regulatory Compliance
The Truckee Donner PUD will comply with all local, state and federal laws, rules
and regulations applicable to the activities of the District. It will maintain a safe and
healthy work environment free from harassment or discrimination per the District's
policy.
Reporting of Violations
Every employee is responsible for ensuring that violations of laws, rules and
regulations, the MOU or this Code are reported and addressed promptly. Reports of
suspected violations may be made in person or in writing, confidentially or
anonymously, to the General Manager or Human Resources Administrator. All such
reports will be promptly investigated and appropriate corrective action will be taken.
Any employee who makes a report in good faith and on reasonable belief may do so
without fear of harassment, retaliation or retribution.
Employee Education
All employees will receive a copy of the Code sness Conduct and will
receive training to ensure familiarity with its contei and r6gUI ents. Every
employee is required to sign a form indicating tha foie/ a.she has receive ' copy of the
Code of Business Conduct, read its contents, underst� s his/her obligons under
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the Code.
Monitoring and Enforcement,
Every employee is responsible for monitoring compliance with the Code by
reporting suspected violations in a timely manner (as discussed above) and cooperating
with investigations of suspected violations. Employees that violate any laws, rules and
regulations, the MOU or the CIode may face, appropriate, case-specific disciplinary
action. Additionally, on a periodic basis., this Code of Business Conduct policy will be
reviewed for effectiveness and appropriate modifications and/or enhancements will be
recommended as deemed necessary.