Code of Business Ethics and Conduct

The American Red Cross is a not-for-profit charitable organization dedicated to providing services to those in need. The Red Cross has traditionally demanded and received the highest ethical performance from its employees and volunteers. In an effort to maintain the high standard of conduct expected and deserved by the American public and to enable the organization to continue to offer its services, the American Red Cross operates under the Code of Business Ethics and Conduct outlined below. All employees and volunteers are required to sign the Code of Business Ethics and Conduct form certifying that, in delivering Red Cross services and in all other Red Cross activities, they shall meet the following standards of conduct:

• Compliance Requirements. All employees and volunteers are required to comply with applicable federal, state, and local laws and regulations and with American Red Cross corporate policies and regulations.
  
• Actions Prohibited by the Code of Business Ethics and Conduct. No employee or volunteer shall engage in the following actions:
  a. Personal Use. Authorize the use of or use for the benefit or advantage of any person, the name, emblem, endorsement, services, or property of the American Red Cross, except in conformance with American Red Cross policy.
  b. Financial Advantage. Accept or seek on behalf of or any other person, any financial advantage or gain of other than nominal value offered as a result of the employee’s or volunteer’s affiliation with the American Red Cross.
  c. Red Cross Affiliation. Publicly use any American Red Cross affiliation in connection with the promotion of partisan politics, religious matters, or positions on any issue not in conformity with the official position of the American Red Cross.
  d. Confidentiality. Disclose any confidential American Red Cross information that is available solely as a result of the employee’s or volunteer's affiliation with the American Red Cross to any person not authorized to receive such information, or use to the disadvantage of the American Red Cross any such confidential information, without the express authorization of the American Red Cross.
  e. Improper Influence. Knowingly take any action or make any statement intended to influence the conduct of the American Red Cross in such a way as to confer any financial benefit on any person, corporation, or entity in which the individual has a significant interest or affiliation.
  f. Conflict of Interest. Operate or act in a manner that creates a conflict or appears to create a conflict with the interests of the American Red Cross and any organization in which the individual has a personal, business, or financial interest. In the event there is a conflict, the American Red Cross has a structured conflict of interest process. First, the individual shall disclose such conflict of interest to the chairman of the board or the chief executive officer of the individual’s Red Cross unit or the general counsel of the American Red Cross, as applicable. Next, a decision will be made about the conflict of interest, and, where required, the individual may be required to absent himself or herself during deliberations, decisions, and/or voting in connection with the matter.
  g. Retaliation. Retaliate against any employee or volunteer who seeks advice from, raises a concern with, or makes a complaint to a supervisor or other member of management, the ombudsman, the Concern Connection Line, or any other whistleblower program, about fraud, waste, abuse, policy violations, discrimination, illegal conduct, unethical conduct, unsafe conduct or any other misconduct by the organization, its employees, or volunteers.
  h. Contrary to the Best Interest of the Red Cross. Operate or act in any manner that is contrary to the best interest of the American Red Cross.
  
• Ombudsman Program – Informal Dispute Resolution. The American Red Cross has an organizational ombudsman designated as the neutral or impartial dispute resolution practitioner whose major function is to provide confidential and informal assistance to the many constituents with concerns or complaints about the Red Cross. The constituents who seek the ombudsman’s services are internal stakeholders, such as employees and volunteers, and external stakeholders, such as Red Cross clients, donors, suppliers, vendors, and the public at large. The ombudsman provides a voluntary, confidential, and informal process to facilitate fair and equitable resolutions and explore a range of alternatives or options to resolve the problems. If a formal investigation is what the individual seeks, referrals to the whistleblower hotlines may be appropriate.
  
• Investigations, Compliance, and Ethics – Formal Dispute Resolution. Distinguishing from the actions of the ombudsman, the Office of the General Counsel and the Office of Investigations, Compliance, and Ethics (IC&E) conduct formal investigations into allegations of fraud, waste, abuse, Red Cross policy violations, illegal or unethical conduct, or other improprieties regarding the Red Cross. Usually, the allegations arise from whistleblower complaints of Red Cross employees and volunteers seeking formal review or investigations of their allegations of wrongdoing.
  
• Whistleblower Hotline Programs. The American Red Cross encourages open communication. All employees and volunteers are encouraged to bring any concerns they have regarding the organization or its employees and volunteers to their direct supervisor. If individuals seek an informal and confidential resolution, the ombudsman may be the appropriate choice. If a formal IC&E investigation is sought, the hotlines described below are the appropriate choice.

If an employee or volunteer suspects or knows about misappropriation, fraud, waste, abuse, Red Cross policy violations, illegal or unethical conduct, unsafe conduct, or any other misconduct by the organization or its employees or volunteers, that individual should alert his or her supervisor or other member of local management. In those cases where an employee or volunteer is not comfortable telling his or her supervisor or local management, the employee or volunteer may contact the Concern Connection Line at 1-888-309-9679. For concerns about the collection, manufacturing, processing, distribution, or utilization of blood or blood components (e.g., violations of FDA or OSHA regulations, falsification, quality failures, training, Biomedical Services computer and equipment issues), an employee or volunteer who is not comfortable with contacting his or her supervisor or local management may contact the Biomedical Regulatory Hotline at 1-800-741-4738.

All employees must disclose any actual or potential conflict of interest to their supervisor immediately upon becoming aware of such actual or potential conflict of interest. In particular, any actual or potential conflict of interest between an individual’s obligation to operate in the best interests of the Red Cross and (a) the interest of any organization in which such individual has a financial interest, or with which he or she is affiliated, or (b) such individual’s personal interest, must be reported immediately.

Concern Connection Line
The Concern Connection Line is a worldwide, 24-hour, anonymous, confidential, toll-free number 1-888-309-9679. It provides a mechanism for reporting concerns or questions regarding illegal, unsafe, or unethical conduct that is observed or discovered within the organization.