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Picture of Gary Knell

Photograph by Mark Thiessen/National Geographic

A message from President and CEO Gary Knell

National Geographic is one of the most trusted brands in the world. Ultimately, this is a result of the personal integrity and highest standard of ethical conduct you demonstrate in everything you do for the National Geographic Society. Maintaining the professional and respectful culture we have established is critically important to our future success.

The fundamental principles we live by at the National Geographic Society are straightforward—always act with honesty, fairness, and transparency. But these principles can sometimes be difficult to apply given the complexities of the world in which we carry out our mission. That’s why I’m pleased to announce our new Code of Ethics. This is a great starting point and resource for helping you put our high standards to good practice.

Importantly, we are not changing any of the principles that have made our organization successful. We are simply putting them together in a way that will hopefully make them easier for you to apply—and get help if you have a question or encounter a challenging situation.

I ask each of you to read and recommit yourself to these principles. And I encourage you to ask questions if you have any concerns about any business practice or conduct you observe at work. There is a wealth of resources available to support you in raising issues, getting answers to any questions, and addressing concerns you may have.

I am grateful for your continuing commitment to upholding the highest standard of ethical conduct in your work for the National Geographic Society.

 

None

Gary E. Knell
President and CEO
National Geographic Society

Introduction

The National Geographic Society’s success depends on each staff member maintaining the highest standard of ethical behavior—by acting with honesty, fairness, and transparency.

Our Code of Ethics establishes these standards as the fundamental requirements for working on behalf of the Society. The Code also serves as a roadmap for putting the Society’s ethical standards into practice. It summarizes some of our key policies for doing business consistent with both our standards and the law. The Code does not describe any policy in full, or the underlying laws each of us must follow—but it does offer links to additional information (including underlying policies) and provide contact information for people who can answer any questions you might have and resolve difficult situations you might face.

Reading the Code of Ethics is not a substitute for reading and familiarizing yourself with the National Geographic Society’s policies. You are responsible for understanding and following all Society policies that apply to your position. If you are unclear about those policies, or how to comply with them, it is your responsibility to find out. There are many resources available to help, including your manager, Human Resources, Audit and Advisory Services (A&AS), Legal and Business Affairs (L&BA), and the Society’s ethics officer. Contact information is available on the last page of the Code.

Importantly, we expect our third party representatives (independent contractors, agents, consultants, suppliers, business partners, and others who support our mission or receive our funds) to act with the same high standards that our Code of Ethics requires of us, and to comply with all policies applicable to the work they do on the National Geographic Society’s behalf.

Maintain the Highest Standards of Ethical Conduct

People’s trust in our brand and our reputation ultimately depend on the personal integrity and highest standard of ethical conduct you demonstrate in everything you do for the National Geographic Society.

You must exercise the highest standard of ethical decision-making and sound professional judgment regardless of where or when you are doing business on behalf of the National Geographic Society. There are two basic principles that must always guide your actions:

1. Conduct every aspect of your business in a fair, lawful, and ethical manner.
2. Encourage and expect everyone you work with to do the same.

We are deeply committed to performing our mission in a manner that earns the respect of everyone we interact with, including charitable donors, business associates, third party representatives, Society members, our staff, explorers, fellows, grantees, and the general public. We believe that the consistent application of our standard of ethical conduct is the best way to do it.

You are responsible for promoting the Society’s mission in a fair, ethical, and professional manner. The professionalism you demonstrate in your work helps us sustain and enhance the Society’s reputation. It’s also what makes the Society a great place to work.

Avoid Conflicts of Interest

A conflict of interest arises when you, a family member, or a close friend has a business, financial, or personal interest in the other side of a transaction or business dealing with the National Geographic Society. You must always act in the best interest of the Society. This includes being sensitive to situations where it might appear that your responsibility to the Society has been compromised.

Here are some ways a conflict of interest might arise:

  • Having a personal, family, or financial interest in any Society transaction
  • Acting as an employee or consultant for, or providing any other assistance to, a competitor

People’s trust in our brand and our reputation ultimately depend on the personal integrity and highest standard of ethical conduct you demonstrate in everything you do for the National Geographic Society.

Most potential conflicts can be resolved in a simple and mutually acceptable way. The key is to disclose the issue promptly—before it becomes an actual conflict that could compromise your responsibility to act exclusively in the National Geographic Society’s best interest.

  • Having a financial interest in a competitor, supplier, contractor, grantee, fellow, consultant, or other business partner

  • Hiring or supervising a family member

  • Accepting gifts, discounts, or services beyond policy limits from anyone doing (or seeking) business with the National Geographic Society

If you have a potential conflict of interest, you must report it to your manager—before you engage in any activity related to the situation. Your manager, in consultation with you, Human Resources, and L&BA, will determine what measures should be taken to resolve it appropriately. Such measures typically include recusing yourself from any decision relating to the matter. If you are unsure but have questions, get help from your manager, Human Resources, A&AS, L&BA, or the Society’s ethics officer.

 

Examples

Here are some examples of conflicts of interest. They are illustrative, not exhaustive, and are intended to enhance your ability to spot potential conflicts and ask the right questions so they may be resolved appropriately:

  • An employee selects a supplier for which the employee’s spouse is an owner, partner, director, or officer, or otherwise has a financial stake in the supplier’s business.

  • An employee negotiates an agreement on behalf of the Society with a business partner who has loaned money to the employee, or the employee has some other financial or personal interest in the business partner’s success.

  • An employee approves a grant application by a family member without disclosing the relationship to a higher-level manager or seeking guidance as required.

  • An employee oversees grant fulfillment activities of a grantee organization for which the employee serves as a board member.

 

Gifts and Gratuities

Staff members may not receive any gift worth more than $100 from any person or organization doing business with the National Geographic Society. Staff members involved in purchasing decisions must take extra care to avoid any gifts that might affect, or appear to affect, their decision-making responsibilities on behalf of the National Geographic Society.

Corruption and Bribery—Strictly Prohibited

Every country we work in has laws against corruption and bribery. We take compliance with these laws seriously. As a U.S.-based organization, the National Geographic Society focuses particular attention on the anti-bribery standards of the U.S. Foreign Corrupt Practices Act.

We may not offer, promise, pay, give, or approve any bribe, kickback, or other inducement in the form of cash or anything else of value (such as gifts, travel, entertainment, or charitable contributions) to any person or organization with the intent to exert improper influence over the recipient, induce the recipient to violate their duty of loyalty, secure an improper advantage for the National Geographic Society, or improperly reward the recipient for past conduct. Nor may we allow any third party representative (such as customs clearance brokers, independent contractors, consultants, business partners, or anyone else) to do so on our behalf.

Our Anti-Corruption policy sets standards that must be followed in our relationships with explorers, fellows, grantees, third party representatives, field workers (“fixers”), exhibitors, and recipients of charitable donations. Additionally, there are special standards that apply to our interactions with government officials (including travel, accommodations, meals, and entertainment). See the Anti-Corruption policy for additional Information.

Demonstrate Business and Financial Integrity

Responsible Use of Assets and Expenditures

The responsible expenditure of financial resources, and use of the National Geographic Society’s assets, is essential to the Society’s sound management, maintenance of our reputation, and the continuing confidence of our donors and partners.

To ensure that our financial statements properly reflect our assets, liabilities, and transactions, the financial records each staff member submits must be complete, accurate, and understandable. This includes the information each of us provides in payroll documents, time cards, travel and expense reports, purchasing, and every other National Geographic Society financial record. The key principles you must follow in your business dealings, expenditures, and record keeping include the following:

  • Act ethically, professionally, and responsibly any time you handle Society resources (funds, trademarks, and other property).National Geographic Society financial record. The key principles you must follow in your business dealings, expenditures, and record keeping include the following:
  • Be conservative when spending the National Geographic Society’s money.

  • Be accurate, thorough, and truthful in your business records.

The Society’s Travel and Business Expenses policy contains requirements that all staff who incur covered expenses must follow to obtain reimbursement. Our Spend policy explains the methods and processes you should use for all business-related purchases. Our Signature Authority policy sets spending limits that our staff must follow.

 

Responsible Business Conduct

All contracts with third parties (such as independent contractors, consultants, vendors, suppliers, business partners) must be approved by L&BA in advance of the National Geographic Society doing business with them, and a contract must be in place before work begins. No contractual agreement will be considered valid and enforceable by the National Geographic Society in the absence of approval. See the Spend policy and Signature Authority policy for additional details.

Respect for intellectual property, including copyrights and trademarks owned by the National Geographic Society and others, is critically important to us. Each of us is responsible for ensuring these rights are upheld. You must contact L&BA to obtain a license, or other appropriate clearance, prior to using any intellectual property in your work on behalf of the Society. See the Intellectual Property policy for additional details.

We comply with all U.S. government trade sanctions. These sanctions may prohibit or restrict travel to certain countries; business activities (such as grants, contracts, collaborations) involving certain countries, nationals, entities, or individuals; and items (such as laptops, smartphones, technical equipment) that may be exported to certain countries. See the Trade Controls policy for more information.

Professional Conduct

We are proud of our professional and congenial work environment, and we are firmly committed to ensuring it remains productive, engaging, and respectful. See the Nondiscrimination and Anti-Harassment policy for additional information.

Use I.T. Systems Reponsibly

Each of us is responsible for protecting the National Geographic Society’s information technology systems (including our computer network, hardware, software, and all related applications). We must do our part to protect these systems from damage, alteration, theft, fraud, misuse, and unauthorized access. See the Information Security policy and Acceptable Use policy for additional information. You must notify the Information Security Team (ext. 4357, 202-807-3000, or helpdesk@ngs.org) immediately in the event of a potential I.T. security issue.

Media Inquiries and Social Media

The Communications Team is exclusively responsible for handling all media inquiries concerning the Society as well as overseeing the creation and use of National Geographic Society–sponsored social media. See the Social Media Guidelines and External Communications policy for additional information.

Lobbying and Political Activities

The National Geographic Society may engage in specific, limited lobbying in the U.S. and internationally in support of our mission. The Society must document its lobbying activities and confine them to acceptable levels to maintain our status as a tax exempt, not-for-profit organization. The Society may not engage in any type of political campaign activity. See our Lobbying policy for additional information.

Addressing Concerns and Reporting Violations

Open Door

We recognize that there are situations in which making the right decision can be challenging. By raising concerns, sooner rather than later, you give the
National Geographic Society the opportunity to resolve issues that might otherwise be damaging to our mission and reputation.

Many of these issues can best be resolved in consultation with your manager, or the next higher level of your management. All managers are responsible for maintaining an “open door” to staff. Alternatively, you may contact Human Resources, A&AS, L&BA, or the Society’s ethics officer. We are here to support your doing the right thing. See the Problem Resolution policy for additional information.

 

Reporting Potential Violations

If you believe that a violation of law, our Code of Ethics, or our policies may have occurred, or is going to occur, you are obligated to report it immediately. While we hope you feel comfortable discussing it with your manager, we recognize there may be times when you prefer to use another avenue for addressing an issue. You should feel comfortable reporting the issue to any one of the following: your next-level manager, Human Resources, A&AS, L&BA, the Society’s ethics officer, the president
and CEO, or any member of the Board of Trustees.

As an additional avenue for reporting actual and potential violations, the National Geographic Society offers an external helpline available to you 24 hours a day, 7 days a week, 365 days a year. The helpline is operated by an independent third party who specializes in these services. You may submit an email, web-based or automated phone report, or speak to a trained customer service representative who will listen to your concern. You may contact the external helpline at (888) 647-0647 (888-NGS-0-NGS), EthicsNGS@getintouch.com, or intouchwebsite.com/NGS.

Reports to the helpline can be made anonymously, but we strongly encourage you to identify yourself. This helps ensure your concern is thoroughly considered and appropriately addressed. You can arrange to receive and respond to follow-up communications through the helpline even if you choose to remain anonymous. We ask that you make these arrangements so we can communicate with you about the issue. Reports are referred to the ethics officer for appropriate handling.

 

Investigation and Resolution

All reported violations of law, our Code of Ethics, or our policies will be investigated promptly, objectively, and thoroughly. The National Geographic Society treats these as confidential internal matters. Information about them is shared only to the extent necessary to investigate and take any corrective action that the Society deems appropriate for resolving the matter consistent with our standards and the law.

Staff members found to have committed violations are subject to disciplinary action up to and including termination of employment and possible legal action depending on the violation. Similarly, third party representatives, and others acting on our behalf, are subject to having their business relationships with the National Geographic Society terminated, and potentially other penalties, for violations.

 

We Do Not Retaliate

Retaliation against any staff member who reports misconduct, or cooperates with an investigation, is strictly prohibited and will not be tolerated. Staff members are expected to seek advice, raise concerns, report potential misconduct in good faith, and cooperate with the investigative process. This is critical because silence hurts us when it comes to ethics and compliance. If you feel you have been retaliated against, be sure to contact one of the resources listed on the last page of the Code.

Additional Expectations for Managers

Managers have a special responsibility to model our Code of Ethics with words backed up by actions that set a strong example for all to follow, including by doing the following:

  • Never ignore illegal behavior, Code of Ethics violations, policy violations, or other conduct that does not meet our high expectations for ethical and lawful conduct.

  • Ensure that the staff and third parties you manage are familiar with our Code of Ethics, and understand the importance of our strong ethical and compliance culture.

  • Create a work environment where staff feels comfortable discussing our Code of Ethics and speaking up when they have concerns.

  • Promptly escalate concerns about a potential violation of law, our Code of Ethics, or our policies to L&BA.

  • Never retaliate against a staff member who reports a concern about suspected or actual misconduct, or tolerate retaliation by anyone else.

Certifications

The National Geographic Society requires staff members and trustees to certify compliance with the Code of Ethics, our policies, and applicable laws annually.

Contact Information

Audit and Advisory Services

Phyllis English, VP 202.807.3121 penglish@ngs.org

 

Human Resources

Yvonne Perry, Executive Director 202.807.3253
yperry@ngs.org

Jenifer White, Human Resources Director 202-807-3152
jwhite@ngs.org

 

Legal and Business Affairs

Angelo Grima, EVP, General Counsel & Corporate Secretary 202.807.3154
agrima@ngs.org

Megan Edwards, SVP, Senior Associate General Counsel 202.807.3117
medwards@ngs.org

Jeanne Fink, VP, Senior Associate General Counsel 202.807.3129
jfink@ngs.org

Agnes Tabah, VP, Senior Associate General Counsel 202.807.3301
atabah@ngs.org

Jeff Williams, VP, Senior Associate General Counsel & Ethics Officer 202.807.3329
jdwilliams@ngs.org

 

Ethics Helpline

U.S. Toll Free: 888.647.0647 | 888.NGS.0.NGS Email: EthicsNGS@getintouch.com
Web: intouchwebsite.com/NGS

 

The National Geographic Society Code of Ethics is a guide to policy and legal requirements that govern how we conduct business. It is a general reference tool for our staff and business partners everywhere. It does not describe all applicable laws or National Geographic Society policies, or give full details on any individual law or policy. It is intended for informational use only. National Geographic Society reserves the right to modify, revise, or alter its Code of Ethics and policies. Nothing in it should be construed as a contract of employment.