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Code of Ethics

1. Purpose

The Atlantic Code of Ethics sets forth standards that we should follow when we engage in Atlantic business or in activities that could reflect on Atlantic.  The Code applies worldwide, complementing local policies specific to our individual offices.  We must respect both the Code and our local policies.

2. Coverage

The Code covers Atlantic directors, trustees, committee members, and staff, regardless of location.

3. Laws and Policies

We will comply with the letter and the spirit of all Atlantic policies and all applicable laws and respect the customs of the countries in which we operate.

4. Professional Behavior

We will act with humility, modesty, and personal and institutional selflessness.  This conviction developed over many years of anonymous giving, and it remains in full force today.  In practice, this means that we will act honestly, ethically, and respectfully toward colleagues, grantees, vendors, and others whom we meet through Atlantic.  We will not seek credit or recognition for supporting our grantees for Atlantic or ourselves. We will focus attention instead on our grantees and try to keep a low profile.  Atlantic will take a more forward role however, when it is clear that public communication or other action will aid our grantees and help us achieve our program goals and mission.

5. Conflicts of Interest

We want to prevent conflicts of interest from creating actual or apparent improprieties that could undermine our effectiveness and reputation.  Accordingly, we have adopted the conflict of interest policy.  The policy applies to everyone covered by the Code.  With Atlantic’s conversion of its investment portfolio to cash equivalents, we believe a separate Personal Investment Policy is no longer needed.  If you have any questions please consult with the General Counsel.

6. Awards and Gifts

We will not accept awards, gifts, or honors from a current or prospective grantee or vendor.  We will not allow anyone to accept these offerings in our stead.  This rule does not apply to (a) awards to Atlantic that entail no personal recognition, if the Board Chair determines that the award will help Atlantic, its grantees, or Giving-while-Living; (b) gifts of nominal value; (c) gifts when their refusal would cause insult under prevailing cultural norms; and (d) meals and entertainment that are modest, take place in appropriate business settings, and are consistent with sound business ethics.

7. Outside Activities

Staff will devote most of their work time to Atlantic.  However, we recognize that outside activities, particularly in the non-profit sector, can contribute to personal and professional development and provide experience that can help Atlantic.  Accordingly, staff may engage in outside activities freely as long as they (a) take little or no time during business hours; (b) yield no compensation; (c) avoid any implication of Atlantic endorsement or support; and (d) violate no other Atlantic policy. Otherwise, the President or the Senior Leadership member to whom the employee reports, and in the case of the President,  the Board Chair, must determine that the activities will not (i) conflict with any staff responsibilities; (ii) violate any Atlantic policy; or (iii) expose Atlantic to any harm.  Staff must obtain a required approval in advance; advise the approver if the circumstances change significantly; and accept that Atlantic may ask them to terminate these activities at any time for any reason permitted by law.

8. Transparency

The financial and other information that we report to our colleagues, grantees, regulators, and others will be accurate, appropriately complete, fair, and clear.  We will follow best practice standards to protect the integrity of this information and to identify and limit risks that can arise from inadequate communication.

9. Confidentiality

9.1      Atlantic Information
We will communicate honestly and openly both inside and outside Atlantic.  At times, however, confidentiality is appropriate, and we will keep information and opinions confidential to the extent that other ethical organizations customarily limit their disclosure.  For example, we will not disclose information or opinions that could (a) compromise sensitive investment or tax positions; (b) violate agreements; (c) invade individual privacy; or (d) breach the anonymity of the few (if any) grants that we need to keep confidential.  Confidentiality concerns, of course, do not justify dishonesty or failure to comply with the law.

9.2      Employee Information
We recognize that Atlantic has an obligation to safeguard the confidentiality of certain information about its employees.  Accordingly, we will limit disclosure of sensitive personal information on a need-to-know basis and as required by law.

10. Diversity

We take pride in Atlantic’s diversity and international character.  Equality of opportunity is an important principle in all our employment, grant, and other decisions. We do not tolerate discrimination against, or sexual or other harassment of, employees, grantees, vendors, or others due to race, color, age, sex, religion, national origin, citizenship, ancestry, marital status, sexual orientation, disability, military or veteran status, political opinion, or any other basis prohibited by law.

11. Property

11.1    Property of Atlantic
We will preserve Atlantic’s property for its mission.  This property includes any proprietary information that we create using Atlantic facilities, equipment, or software.  We will make this information readily available and accessible to appropriate Atlantic colleagues.  We will not appropriate Atlantic information or other property for our personal needs, and we will refrain from any personal use of Atlantic’s facilities that could adversely affect Atlantic’s operations.

11.2    Property of Others
We will respect the property rights of others, for example, their rights to information protected by intellectual property laws.  We will acknowledge the authorship of ideas and views in keeping with customary expectations.

12. Compliance

12.1    Issues and Questions
The Code and our other policy statements provide broad guidance, but they cannot address all situations, and the application of our policies may be uncertain at times.  Consequently, all of us will need to exercise sound judgment to make sure that we avoid any appearance of impropriety.  In the event of any uncertainty, we must err on the side of caution and seek advice before taking action.

12.2    Whistleblowing and Enforcement
1. Reporting. Members of the Board who believe that someone has violated an Atlantic policy should promptly express their concerns to the Chair of our Board.  Staff should promptly report the issue to their manager or to our General Counsel.  If management is unresponsive or has itself violated the policy, staff should report their concerns directly to the Chair of our Board.

2. Investigation. Atlantic will investigate these reports carefully, and all of us must cooperate with its investigation. The need to be thorough means that Atlantic cannot promise complete confidentiality, but it will act as discreetly as reasonably possible.  When Atlantic completes its investigation and concludes that there is a problem, it will promptly take corrective action.

3. Retaliation. As long as you act reasonably and in good faith, Atlantic will not discharge or discriminate against you for your allegations or your participation in any investigation, and it will strongly discipline anyone who threatens or retaliates against you.

4. Compliance Officer. Our General Counsel is our compliance officer and is responsible for policing and enforcing the Code and related Atlantic policies.  If you have any concerns about these policies, you should speak to him, or, in his absence, our Corporate Secretary.

12.3    Discipline
Negligent or intentional violation of Atlantic policies may lead to discipline up to and including termination.  Dismissal following intentional or repeated and reckless violations constitutes termination for cause.

12.4    Acknowledgment
You should sign the attached Acknowledgment and Disclosure Form annually to confirm that you understand and will comply with the Code.

13. Legal Matters

13.1    Changes and Waivers
1. Authority. Atlantic may change the Code and its other policies for any reason and at any time. A waiver or variation in a particular case will not create a general precedent.

2. Publication. Atlantic will give prompt notice of changes in the Code.

13.2    Interpretation
Atlantic will interpret the Code and its other policies in its sole discretion, and its conclusions will be final and binding. Atlantic’s plenary authority to change, waive, and interpret its policies extends to all of its procedures, rules, and benefit and other programs.

13.3    Conflicts with Law
If the Code conflicts with law, the Code will be deemed modified to the minimum extent necessary to resolve the conflict.