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CODE OF ETHICS, DISCIPLINE &

WHISTLEBLOWER PROTECTION POLICY

Adopted and approved by the Board of Directors October 22, 2017

I. Code of Ethics

Students for Sensible Drug Policy Foundation (“SSDP”) requires directors, trustees, officers, employees, student leaders and members to observe the highest standards of business and personal ethics in the conduct of their duties and responsibilities. As employees and representatives of SSDP, we practice honesty and integrity in fulfilling our responsibilities and comply with all applicable laws and regulations.

II. Reporting Responsibility

This Code of Ethics, Discipline and Whistleblower Protection Policy is designed to encourage and enable employees and others to maintain our Code of Ethics and, in the event anyone connected with SSDP believes another has engaged in conduct that conflicts with our Code of Ethics, provides the person with a procedure to raise the concern so that SSDP can address and correct any inappropriate conduct and actions. It is the responsibility of all board members, officers, employees, volunteers, student leaders and members to report and address concerns they become aware of about violations of SSDP’s code of ethics or suspected violations of law or regulations that govern SSDP’s operations, in conformity with this policy.

III. Compliance Officer

The Executive Director shall serve as Compliance Officer unless the Executive Director designates another person to carry out these responsibilities.  The Compliance Officer shall investigate and propose a resolution of all complaints about violations of SSDP’s mission or values, or other allegations of unethical or illegal conduct pursuant to the Conduct Violation Complaint & Restoration Procedure. The Compliance Officer will notify the Board of Directors of all complaints and their resolution and will report at least annually to the Executive Committee on compliance activity relating to accounting or alleged financial improprieties.

The Compliance Officer may be a board member, another staff member, or a third party.

IV. Communications and Complaint Reporting Procedure

SSDP has an open door policy and suggests that employees share their questions, concerns, suggestions or complaints with their supervisor.

If an employee, board member, student, or supporter (i.e. “reporter”) is not comfortable speaking with their supervisor or if the employee, board member, student, or supporter is not satisfied with the  supervisor’s response, the reporter is  encouraged to speak with the Compliance Officer.

Any person in the management of SSDP to whom is provided a whistleblower complaint or information alleging a violation of SSDP’s Code of Ethics shall forward it in writing to SSDP’s Compliance Officer. Reporters may also submit their concerns in writing directly to the Executive Committee of the Board of Directors.

V. Accounting and Auditing Matters

SSDPs Compliance Officer shall immediately notify the Executive Committee of the Board of Directors and Treasurer of any concerns or complaint regarding accounting practices, internal controls or auditing, and work with the committee until the matter is resolved.

VI. Acting in Good Faith

It is presumed that any complaint concerning a suspected violation will be made in good faith and based upon reasonable grounds to believe the information disclosed indicates a violation. Any person who makes allegations maliciously or knowing them to be false will have committed a serious conduct violation.

VII. Confidentiality

Any person in the management of SSDP to whom is provided a complaint, or information as part of an investigation into such a complaint, shall treat as confidential such information, and may only discuss any aspect of this matter with other persons involved in the investigation and for the purpose of investigating and resolving the complaint. A breach of this duty of confidentiality will be viewed as a serious conduct violation offense. Notwithstanding this duty, the Compliance Officer may share any information with another in the furtherance of the investigation into the complaint, and may provide information to the Board of Directors regarding the resolution of the complaint.

VIII. No Retaliation

It is contrary to the values of SSDP for anyone to retaliate against any board member, officer, employee, or volunteer who in good faith reports an ethics violation, or a suspected violation of law. Such violations may include complaints of discrimination, suspected fraud, or suspected violations of any regulation governing the operations of SSDP. An employee who retaliates against someone who has reported a violation in good faith is subject to discipline up to and including termination of employment.

IX. Handling of Reported Violations

SSDP’s Compliance Officer will notify the complainant and shall promptly investigate the complaint according to the Conduct Violation Complaint & Restoration Procedure. If warranted, the Compliance Officer shall report to the Board on the steps necessary to address the substance of the complaint. Any person subject to this policy who believes that a complaint against them was resolved unfairly or falsely may appeal to the Executive Committee of the Board of Directors review their claim, and such committee may make a further inquiry into the complaint and affirm or reject the resolution made by the Compliance Officer. The committee’s determination will be final and there is no right of further internal review.

X. Initial Compliance Officer

Betty Aldworth, Executive Director, SSDP (betty@ssdp.org or 202-393-5280).