Housing Works’ Duty to Act Policy (9/3/2008)
Introduction:
Organizational values are a very personal thing—but this is because values are a very personal thing; sometimes,
separating a person’s personal values from organizational values are possible, but most often, a person’s individual
values coincide with the values of the organization for which they work. It can be surmised that most people would
not work for organizations that did not support their personal values, but in some cases (such as Housing Works),
values play such an important part in organizational life that any division between a person’s own value system and
that of the organization could result in conflicts which would make work difficult, if not intolerable.
In this sense, organizational values can also be very complicated. As a subsystem of culture and belief systems that
embody the myths and ideologies of an organization, organizational leaders use values as the springboard for
greater ideas and actions, and build upon these concepts to help define an organization’s purpose, policies, and
strategies so that work structures can be better organized.
Housing Works not only maintains a value system that clearly separates it from many organizations in the private
sector, but it also maintains beliefs that separate it from other nonprofit organizations. It is not a typical nonprofit
organization; it is a healing community of people impacted by the twin crisis of homelessness and AIDS. A
community consisting of Board Members, the Executive Team, Managers, staff, trainees, clients, and volunteers
(herein referred to as members). It is one of only a few organizations that make use of direct action as a job
requirement, thereby placing any discussion of values as a topmost driving force behind organizational change.
Some values lead to ideas about how organizations should be managed. Below is a list of values adopted by the
organization:
A healing community.
A full commitment to the highest quality healthcare and services.
Being sophisticated, innovative and aggressive.
A commitment to holding ourselves accountable for what we do, both internally and externally.
Being client-centered and driven.
Being client/staff empowered.
A universal commitment to advocacy and direct action.
Being non-judgmental.
Being drug-user friendly.
Being harm reduction practicing.
Being mentally ill accepting.
Being multicultural.
Being GLBT accepting.
A commitment to finding out and meeting needs of underserved.
Having fun.
Being grassroots.
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Policy:
A Duty to Know, Understand, and Comply
Housing Works, Inc. (Organization) Code of Ethics and Conduct (“Code”) requires directors, officers and employees
to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. As
employees and representatives of the Organization, we must practice honesty and integrity in fulfilling our
responsibilities and comply with all applicable laws and regulations. Failure to comply with the Code could result in
significant risk to Housing Works and its people, and will subject that individual to disciplinary action, up to and
including termination or separation from the Organization.
A Duty to Report
The Ethics and Compliance Policy is designed to educate and foster an atmosphere where open communication of
ethics and compliance inquiries and issues is encouraged, and to provide all personnel with a reasonable
understanding of how to identify and report potential violations. Each of you is responsible for appropriately
addressing — through reporting, consultation, or other means — potentially fraudulent, illegal, or unethical issues
that may come to your attention.
If you observe or become aware of a potential fraudulent, illegal, or unethical act, or other violation of Housing Works
policy, whether committed by a colleague, client, supplier, contractor, alliance, or others associated with or doing
business with Housing Works, Inc. or its subsidiaries, it is your responsibility to report the circumstances through an
appropriate reporting channel, and to cooperate fully with any investigation.
No Retaliation
No director, officer or employee who in good faith reports a violation of the Code shall suffer harassment, retaliation
or adverse employment consequence. 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. This Whistleblower Policy is
intended to encourage and enable employees and others to raise serious concerns within the Organization prior to
seeking resolution outside the Organization.
Reporting Violations
Housing Works has an open door policy and we encourage employees to share their questions, concerns,
suggestions or complaints with someone who can address them properly. In most cases, an employee’s supervisor
is in the best position to address an area of concern. However, if you are not comfortable speaking with your
supervisor or you are not satisfied with your supervisor’s response, you are encouraged to speak with someone in
the Human Resources Department or anyone in management whom you are comfortable in approaching.
Supervisors and managers are required to report suspected violations of the Code of Conduct to the Vice President
of Human Resources or a member of the Executive Team, who have the responsibility to investigate all reported
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violations. For suspected fraud, or when you are not satisfied or uncomfortable with following the Organization’s open
door policy, individuals should contact the Organization’s Compliance Officer directly.
Compliance Officer
The Organization’s Compliance Officer is responsible for investigating and resolving all reported complaints and
allegations concerning violations of the Code and, at his discretion, shall advise the CEO/Executive Team and/or the
audit committee. The Compliance Officer has direct access to the audit committee of the board of directors and is
required to report to the audit committee at least annually on compliance activity. The Organization’s Compliance
Officer is the Vice-Chair of the Board of Directors.
Accounting and Auditing Matters
The audit committee of the board of directors shall address all reported concerns or complaints regarding corporate
accounting practices, internal controls or auditing. The Compliance Officer shall immediately notify the audit
committee of any such complaint and work with the committee until the matter is resolved.
Acting in Good Faith
Anyone filing a complaint concerning a violation or suspected violation of the Code must be acting in good faith and
have reasonable grounds for believing the information disclosed indicates a violation of the Code. Any allegations
that prove not to be substantiated and which prove to have been made maliciously or knowingly to be false will be
viewed as a serious disciplinary offense.
Confidentiality
Violations or suspected violations may be submitted on a confidential basis by the complainant or may be submitted
anonymously. Reports of violations or suspected violations will be kept confidential to the extent possible, consistent
with the need to conduct an adequate investigation.
Handling of Reported Violations
The Vice President of Human Resources, Executive Team member, or Compliance Officer will notify the sender and
acknowledge receipt of the reported violation or suspected violation within five business days. All reports will be
promptly investigated and appropriate corrective action will be taken if warranted by the investigation.
Vice President, Human Resources
Caleb L. Terry
(347) 473-7447
Executive Team
(347) 473-7400
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Compliance Officer
Earl Ward
75 Rockefeller Plaza
New York, NY 10019
(212) 763-5070
The Duty to Act policy stated above applies to all policies relating to:
Confidential and Proprietary Information
Honesty and Trust
Diversity and Inclusion
Respect and Fair Treatment
Conflicts of Interest
Personal Relationships
Health Safety and the Environment
Copyright 2004, National Council of Nonprofit Associations, www.ncna.org.
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I acknowledge that I have read and understand Housing Works’ Duty to Act policy.
Name (PRINT): _________________________ Date: ______________________
SIGNATURE: ___________________________ Department/Location: _________________________
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