CODE OF ETHICS AND CONDUCT
NGO Stabilization Support Services
This Code of Ethics and Conduct (below — Code) applies to all members, employees, and contractors of NGO Stabilization Support Services (below — SSS or Organization), including any contractors or consultants who represent SSS or are acting in its name regardless of their position in our organization (below — stakeholders).
This Code reflects the Organization’s orientation on principles of honesty, integrity, social responsibility, and conflict sensitivity. It outlines the main principles and policies that the stakeholders at SSS should comply with.
We demand that the conduct of stakeholders corresponds the highest ethical norms and professional standards. Nobody is allowed to achieve results by breaking laws and rules, without taking into account gender equality and conflict sensitivity policies.
We are aiming for the activities of the Organization and social programs to be sensitive to economic, cultural, and social priorities of the area where they are implemented.
This Code is not a full code of conduct, it only outlines the main principles. It does not replace specific existing policies and procedures, such as gender sensitivity policy or other policies approved by SSS.
By approving this Code, SSS aims to:
- establish respect to SSS, its authority and strategic value among the civil society organizations, state authority bodies, and communities;
- ensure achievement of goals and objectives;
- encourage professional decision-making and responsibility;
- inform about activities fully and faithfully;
- encourage social responsibility.
Responsibility, serving society. SSS aims to ensure self-development and self-service of the society, balance personal and societal interests, focusing on higher, socially necessary goals.
Partner cooperation. SSS works on establishing ethical relationships with other civil society organizations and, if possible, establishes partner relationships for public interest.
Human rights and dignity. SSS does not violate the rights that every person has and acknowledges that all people are born free and equal. The Organization is sensitive and has positive attitude towards moral values, religions, customs, traditions, and cultures of communities which it serves.
Gender sensitive work attitude. When working on all levels, SSS pays attention to gender aspect. We acknowledge the role of women in the process of restoration of peace and their wish to work on settlement of conflicts, so we apply the principle of affirmative action to women.
Religious freedom. SSS respects the freedom of religion.
Transparency and accountability. SSS is transparent in all of its relations with the government, public, donors, partners, beneficiaries, and other persons, while complying with the requirements on protecting information with limited access (personal data, intellectual property objects etc.). The main financial information, management structure, activities, and the list of partners are open and accessible for public control. The Organization is responsible for its actions and decisions, not only to the donors and the government, but also to people whom it provides services, its employees, members, partner organizations, and society in general.
Honesty and legality. SSS aims to be honest in relations with donors, beneficiaries, employees, members, partner organizations, government, and the public, and also respects laws of any jurisdiction where it works.
Equality and non-discrimination. All SSS activities are based on the principles of equal opportunities and non-discrimination on any grounds. Respecting human rights to a decent life, SSS considers every activity as a possibility for all members of the community to receive services. If necessary, SSS applies methods of reasonable adaptation.
Following ethical conduct codes. All employees of the program oblige to follow codes of ethical conduct in their activities. In particular, to not take part in any form of sexual exploitation of either children or adults. To not support and not take part in any form of illegal, exploitative, or violent actions against children or adults, including child labor and human trafficking.
FUNDAMENTAL PRINCIPLES OF ACTIVITY
Non-profitness. The Organization has been established and operates as a non-profit. No part of the obtained resources will be used in the interests of the executives, members, or employees of the organization, nor any other private persons, excluding the cases when the Organization pays for provided services.
Non-governmentness. SSS is not a part and is not controlled by any state authorities, their members, or intergovernmental organizations. The Organization maintains independence, and is not related to any political party, although it may have joint political or legislative goals with them within its declared mission and goals.
Organization. The Organization ensures all necessary documenting of its activities, the work of its executive bodies, regular meetings and events.
Independence and self-governance. The Organization is independent. Its policy, vision, and activities are not defined by any corporation, donor, government, state official, political party, or other organization.
Voluntariness. The Organization is formed through a private initiative and as a result of voluntary actions of people who have common interests, values, and social goals. Ensuring voluntary values and principles remains crucial for its work.
Adhering to laws, rules, and regulations
All stakeholders of the Organization must monitor and observe legislation in all of their activities. SSS will terminate relationship with stakeholders whose activities do not correspond this Code or acting legislation.
Conflict of interest
Conflict of interest arises when personal interests of stakeholders come in conflict, or seem such that they may in any way come in conflict, with interests of SSS. Conflict of interest may arise if:
(а) actions of a person are aimed at his or her direct or indirect benefit, or direct or indirect benefit of the third party, which is different from the interests of SSS; or
(б) a person or a member of his or her family receives undeserved personal benefits as a result of occupying a certain position at SSS.
Actions that may lead to conflict of interest are prohibited in all cases except those that have specifically been preliminary approved by the Board of Directors. According to the acting legislation, if the conflict involves the director (i.e. when the director has personal interest when signing an important contract or carrying out an important operation), director must inform the Board of Directors of his or her interest and abstain from voting at the meeting of the Board where such contract or operation is discussed.
It is not always easy to determine whether conflict of interest exists, so all possible conflicts of interest need to be immediately reported to the member of the Board of Directors, who is independent from the potential conflict and who will evaluate the problem, asking for legal advice from a consultant if necessary. Unresolved potential conflicts involving an employee, an executive, or director must be submitted for the review of the Board of Directors.
In its activities, SSS implements conflict sensitive approaches to organization and coverage of its activities, as well as in all kinds of external communication. One of SSS priorities is maintaining responsible coverage of the conflict and denouncing measures and actions that will contribute to aggravation of conflicts, which aims to decrease the level of proneness to conflict in the Ukrainian society, influence the socio-psychological, political, and other roots of conflict in a way that removes barriers between different social groups, which are a reason or a consequence of conflict.
The obligatory element of SSS activity planning is conflict analysis on micro-level. Planning projects and programs includes elements of evaluating the impact of the program on conflicts in the Ukrainian society and planning measures for conflict prevention.
Conflict sensitive approaches must be used consistently and comprehensively throughout the life cycle of every SSS program — from analysis and design to evaluation. SSS carries out monitoring of impact and unintentional consequences of the program after implementation of each program and uses resulting experience when implementing other programs.
In their activities, SSS representatives take into account that distribution of any aid and implementation of program activities should strengthen peaceful opportunities in conflicting communities.
All aid programs involving transfer of resources in resource-lacking environment must be implemented as transparently as possible using the principles of social justice and Do No Harm principle.
Using aid means or resources for maintaining the conflict is unacceptable. Employees and contractors of SSS may identify the consequences of their decisions in terms of aggravating the conflict and prevent this. Resource transfer and the way in which SSS employees and contractors carry out the programs must enhance local reconciliation potential, decrease the sources of tension.
SSS employees and contractors must abandon the activities that strengthen barriers in the Ukrainian society and deepen reasons and consequences of conflict. SSS representatives must pay special attention when developing action plans and programs to conflict sensitivity of activities with the participation of social groups related to the conflict in the east.
Social groups related to the conflict (below — target groups, or TG) are:
- ATO participants (mobilized and demobilized servicepersons, members of volunteer battalions, wounded military and those who have spent time in captivity, hostages, foreign combatants who are protecting independence, sovereignty, and territorial integrity of Ukraine).
- Internally displaced persons.
- The other side of the conflict (pro-Russian participants of illegal armed groups, terrorist groups, heads of ‘Luhansk People’s Republic’/’Donetsk People’s Republic’/unlawful administration of Crimea, Russian servicepersons who are fighting on the territory of Ukraine, foreign mercenaries who are fighting on the side of ‘Luhansk People’s Republic’/’Donetsk People’s Republic’).
- People who live in the occupied territories.
- Families of combatants.
- Children (any children impacted by the conflict, whether they are children of IDPs, or Russian children, or children of ATO combatants etc.)
When doing coverage for SSS activities or preparing materials with the participation or financial support of SSS, conflict neutral vocabulary must be used, based on the requirements of acting legislation and defined on the national and international level equal statuses of the participants of armed conflict. It is not acceptable to treat certain social groups as a problem in speeches and planning action or programs.
SSS does not support or allow ungrounded drawing attention of a person’s belonging to this or that group, as it encourages the audience to make negative conclusion about a group as a whole and ungrounded generalizations.
SSS condemns treating groups as sources of danger. SSS is against describing a group as such that is opposed to the rest of the society, isolated from it, and does not take part in social life. Any judgement or statement about a group, as well as discussion surrounding its problems without taking into account its diversity is not appropriate. Excuses, justification, calls for violence or discrimination against a group or by a group itself are unacceptable. This statement does not include the cases when groups have officially been acknowledged illegal armed groups, terrorist groups, or similar groups that are infringing independence, sovereignty, and territorial integrity of Ukraine.
Gender Sensitive Approaches
In its work, SSS takes into account specific needs of women and girls, men and boys that exist in peaceful time and appear during conflicts and in post-conflict period as much as possible.
Gender sensitivity means the approach that takes into account those specific social, cultural, economic, and political contexts where men and women live. In all of its activities, SSS applies gender analysis, which aims to decrease gender inequality and discrimination.
SSS as an organization declares equal opportunities and respect to its employees, prospective employees, beneficiaries regardless of their sex and/or gender. Representatives of the organization oblige to abstain from publicly sharing content that has sexist, discriminatory, degrading for a certain community or gender, or objectifying nature.
Stakeholders must maintain and protect confidentiality of information of beneficiaries and SSS entrusted to them or other information obtained when carrying out their duties, except the cases when disclosing this information is allowed or is a legal obligation.
Obligations related to protection of confidential information continue even after the end of relationship with SSS.
Confidential information includes all non-public information obtained within the framework of the relationship with SSS or such information that may harm SSS or its beneficiaries if disclosed. Information that was entrusted by beneficiaries to SSS or its stakeholders must be treated with special care. No information about them may be transmitted without their consent.
Those stakeholders who have access to confidential information are prohibited to share it with anybody but authorized SSS representatives, if this is necessary to ensure statutory activities. Efforts will be made to limit access to confidential information, access will be granted only to persons who need to know this information, and they will be warned that this information must remain confidential.
All third parties who have confidential information related to SSS must be warned that they must not disclose this information expect those cases when it is necessary to ensure statutory activities of SSS.
Protection and proper use of resources
SSS aims to use resources obtained to implement charity programs in the most rational, effective, and public way. SSS uses its resources exclusively to reach socially useful goals.
Honesty and transparency
All SSS procedures and activities must be fully transparent for those whom SSS is helping, for the public, other charity organizations, corresponding state bodies, media, other stakeholders and organizations.
SSS provides full and truthful information through its informational materials and by providing speedy responses to acceptable information requests.
Safety, health, environment, risk, and quality
SSS values safety and health of people as one of the highest goals. All of us are responsible for maintaining safety, by obeying safety rules, sanitary regulations, and decreasing the risks of current and operational activities. SSS aims to ensure the safety of workplaces and avoid risks for stakeholders and receivers of aid. All employees and contractors must avoid behavior or actions that may harm safe and effective labor.
SSS pays special attention to consequences of its activities, their impact on the environment, health, and safety. The actions of contractors must follow ecological regulations and legislation of administrative and territorial units where they carry out their activities. If an employer or a contractor has any doubts on necessity to apply or meaning of a certain regulation on environment or health protection, or safety, he or she must immediately discuss it with the corresponding SSS representative.
Equality of opportunities
SSS ensures equal opportunities for all employees, partners, contractors, grantees and aid receivers, by applying widely publicized and consistent criteria on applying and considering applications, procedures, and rules. Decisions on employment, membership, beginning of cooperation, providing aid or financing must be made exclusively based on the quality of documents, applications and appeals, regardless of national, political, or religious background, sex, way of life, appearance, or social-economic status.
Presents and entertainment
Business gifts and entertainment are usual kind of favors aimed at establishing good relations between business partners. Such favors include food, drinks, tickets to sports and cultural events, discounts for goods unavailable to broad public, transportation, accommodation, and other services. In some cultures, they play an important role in business relations. However, such exchange of favors may cause problems related to ability to make objective and just management decisions.
Giving or receiving any gifts, monetary reward or entertainment that may impact or may be perceived as means of impacting business relations must be avoided.
Cash value of any gift must be minimal, as must be the frequency of giving gifts. Repeating gifts (no matter how small) may be perceived as an attempt to impose a sense of obligation to the person who is giving them, which deems them inappropriate. In addition, all entertainment must be reasonable and aimed exclusively at reaching charity goals or have social orientation.
We demand that stakeholders adhere to anti-corruption policies when giving gifts, entertaining or treating officials. Pay attention that ‘state public official’ is a broad notion. It may include persons who work for or are related to state government bodies or international organizations, including regular employees of state bodes, organizations controlled by the state, or consultants who hold public office.
Anti-corruption laws and rules
Anti-corruption laws and regulations, including Convention on Combating Bribery of Foreign Public Officials (Canada) are applied to all SSS operations. It is expected that the stakeholders will strictly adhere to anti-corruption laws and rules, as well as anti-corruption policies.
Failure to comply with anti-corruption laws and regulations and / or anti-corruption policies will lead to public termination of all relations with SSS.
Notice of any unlawful or unethical behavior
We are very interested in our activities corresponding to legal and ethical norms. Stakeholders are advised to inform about breaking laws, rules, provisions of this Code to SSS management or program managers. No repressive action will be applied in response to such notice. It is unacceptable to submit a deliberately untrue report or slander.
Corrections, changes, and deviations from the Code of Business Conduct and Ethics
The Code may be changed or amended by SSS Board of Directors.
Procedures of checking for compliance
This Code can not and does not aim to describe all situations that may arise. There will be cases when you face circumstances that are not described in any policies or procedures, and you will have to make a decision about your action plan. Under such circumstances, or if you have questions regarding your obligations according to this Code, we recommend you to address SSS management or program managers that you work with.
Stabilization Support Services Program Director