Employee Code of Conduct

1. PURPOSE

The Foundation for Educational Exchange between Canada and the United States of America (the “Foundation”) is a binational public foundation established pursuant to a treaty between the Government of Canada and the Government of the United States of America.

The Foundation administers the Fulbright Program in Canada and related activities in accordance with its treaty mandate, its By-laws, and its obligations to both governments.

As a public sector - private sector partnership and internationally accountable organization, the Foundation is entrusted with advancing educational exchange in a manner that reflects the highest standards of integrity, impartiality, transparency, diplomatic sensitivity, and public stewardship.

This Employee Code of Conduct (the “Code”) establishes the ethical and professional standards expected of all Foundation employees.

2. SCOPE

This policy applies to:

• All full-time and part-time employees
• Term employees and interns

Employees must always comply with this Code when acting in the course of their employment or when representing the Foundation, including during official travel, public events, and interactions with government officials, grantees, alumni, donors, and partners.

3. GUIDING PRINCIPLES

In carrying out their duties, employees shall:

1. Uphold the Foundation’s treaty-based mandate.
2. Act in the public interest of both Canada and the United States.
3. Maintain political neutrality.
4. Safeguard the Foundation’s binational integrity.
5. Steward public funds responsibly.
6. Preserve the confidence of both governments and the public.

4. INTEGRITY AND ETHICAL CONDUCT

Employees shall:

• Act honestly, in good faith, and with professionalism.
• Avoid conduct that could bring disrepute to the Foundation, the Governments of Canada or the United States, or the Fulbright Program.
• Exercise sound judgment and discretion in all professional matters.

5. CONFLICT OF INTEREST

5.1 General Principle

Given the Foundation’s public and binational mandate, employees must endeavour to avoid real, potential, or perceived conflicts of interest.

A conflict of interest arises where personal, financial, or other private interests could improperly influence, or appear to influence outcomes, professional judgment, or decision-making.

5.2 Disclosure and Recusal

Employees must:

• Promptly disclose conflicts of interest to the CEO.
• Recuse themselves from decisions where a conflict exists.
• Not participate in grant adjudication involving friends, family members, or close professional associates with whom there exists an authority relationship.
• Decline gifts, benefits, or hospitality that could compromise impartiality.

6. POLITICAL NEUTRALITY

As a public foundation operating under a treaty:

• Employees must maintain strict political impartiality.
• Employees may not engage in partisan political activities while representing the Foundation. Public statements on behalf of the Foundation must not suggest alignment with any political party, candidate, or government policy unless formally authorized.

Employees retain their personal political rights but must ensure they do not conflict with their professional responsibilities.

7. BINATIONAL SENSITIVITY AND DIPLOMATIC CONDUCT

Employees must:

• Recognize the Foundation’s accountability to both governments.
• Exercise diplomatic judgment and cultural sensitivity in communications.
• Avoid commentary or conduct that could adversely affect the bilateral relationship. Refer official government inquiries to authorized representatives.

The Foundation’s treaty-based role requires discretion and professionalism in all cross-border matters.

8. STEWARDSHIP OF PUBLIC FUNDS

The Foundation receives both public funding and private sector funding and is accountable to both governments, partners, and donors.

Employees must:

• Use Foundation resources solely for authorized purposes.
• Comply with Board-approved financial controls and signing authorities.
• Follow procurement and expense reimbursement policies and protocols.
• Maintain appropriate documentation and transparency.

9. CONFIDENTIALITY AND PRIVACY

Employees may have access to confidential information, including:

• Applicant and grantee records, including personal information.
• Government communications.
• Financial and operational data.
• Board deliberations.

Employees must:

• Protect confidential information during and after employment.
• Use such information only for authorized purposes.
• Comply with applicable Canadian and U.S. privacy laws

10. RESPECTFUL WORKPLACE

The Foundation is committed to maintaining a professional workplace free from harassment, discrimination, violence, and retaliation. Employees should treat colleagues, Board members, applicants, alums, and stakeholders with dignity and respect.

11. USE OF FOUNDATION PROPERTY AND INFORMATION TECHNOLOGY

Employees must:

• Use Foundation property, systems, and information responsibly.
• Take appropriate measures to ensure cybersecurity and protect data integrity.
• Not use Foundation systems for unlawful or inappropriate purposes.
• Comply with records retention and information management requirements.

12. FULBRIGHT PROGRAM BRAND INTEGRITY

The Fulbright Program is a globally recognized symbol of academic excellence, mutual understanding, and binational cooperation between Canada and the United States.

The Foundation is entrusted with administering the Fulbright Program in Canada in a manner consistent with its historic mission and international reputation.

12.1 Stewardship of the Fulbright Name

Employees must:

• Use the Fulbright name and visual identity in accordance with Foundation policy and applicable guidance from governmental partners.
• Adhere to the terms and conditions identified in the Fulbright Global Brand Guide. Ensure all communications accurately reflect the Foundation’s mandate.

12.2 Non-Partisanship

The Fulbright brand must never be associated with partisan political positions or advocacy campaigns.

Employees must exercise heightened judgment in public engagements where the Fulbright affiliation is visible.

12.3 Alumni and Public Platforms

Employees must:

• Distinguish clearly between the personal views of scholars or alums and the official positions of the Foundation.
• Ensure Foundation platforms do not compromise neutrality or public credibility.
• Promote and protect the highest standards of academic freedom.

12.4 Digital Conduct

Employees must:

• Avoid presenting personal opinions as those of the Foundation.
• Exercise discretion when identifying themselves as affiliated with the Program.
• Avoid online conduct that could reasonably harm the Program’s reputation.

Given the Foundation’s diplomatic and treaty-based mandate, employees are expected to uphold the high standards associated with the Fulbright name.

13. PUBLIC COMMUNICATIONS

Only authorized representatives may speak on behalf of the Foundation.

Employees must:

• Obtain approval from the CEO before issuing official public statements.
• Ensure accuracy and consistency in communications.
• Avoid unauthorized representations of the Foundation in media or online forums.

14. REPORTING AND WHISTLEBLOWER PROTECTION

Employees have a duty to report:

• Suspected misconduct.
• Financial irregularities.
• Conflicts of interest.
• Breaches of this Code.

Reports may be made to the CEO or, where appropriate, to the Chair of the Board. No employee shall face retaliation for raising concerns in good faith.

15. COMPLIANCE WITH GOVERNING INSTRUMENTS

Employees must comply with:

• The Treaty establishing the Foundation.
• The Foundation’s By-laws.
• Applicable Canadian and United States laws.
• Board-approved policies.

16. ACCOUNTABILITY AND DISCIPLINE

Violations of this Code may result in:

• Corrective action
• Disciplinary measures

17. ACKNOWLEDGMENT

All employees must:

• Review this Code upon hire and periodically thereafter.
• Sign an acknowledgment confirming understanding and agreement to comply.

POLICY REVIEW

This policy shall be reviewed by the Board of Directors at least every three (3) years, or earlier if required due to legislative, treaty, or governance changes.