Code of Ethics

CORE VALUES
Quality, Integrity, Transparency, Teamwork, Inclusiveness, Responsiveness

BELIEFS
The Learning Lamp believes a reputation of integrity is our most valuable asset. We keep our word, speak the truth, and treat all people with dignity. We strive for excellence in all we do. We adhere to high standards and are efficient stewards of the resources entrusted to us. We measure effectiveness and are accountable to our donors, the community, the people we serve, and each other. As stewards of public trust, we operate with transparency so that people can see what we are doing, how we are doing it, and the value of their financial support. We embody the core values of The Learning Lamp in our words and actions and refuse conflict or the appearance of conflict between personal and organizational interests.

GENERAL GUIDELINES FOR DECISION-MAKING
Unethical actions, or the appearance of unethical actions, are unacceptable under any conditions. All people serving The Learning Lamp must apply her/his own sense of personal ethics, which should extend beyond compliance with applicable laws and regulations in business situations. To govern behavior and decision-making where no existing regulation provides a guideline, people should ask themselves the following questions and be able to respond “yes” to each question:

1. Is my action legal?
2. Is my action ethical?
3. Does my action comply with The Learning Lamp’s policy?
4. Am I sure my action does not appear inappropriate?
5. Am I sure that I would not be embarrassed or compromised if my action became known within the organization or publicly?
6. Am I sure that my action meets my personal code of ethics and behavior?
7. Would I feel comfortable defending my actions on the 6 o’clock news?

RULES OF CONDUCT

All Board of Directors, employees, and volunteers should:

• Speak and act in a manner that reflects the core values of The Learning Lamp.
• Serve as a responsible steward of the assets entrusted to The Learning Lamp and ensure they are used to comply with donor intentions.
• Avoid all conflicts of interest and the appearance of conflicts of interest.Not engage in or condone any form of harassment or discrimination.
• Maintain the confidentiality of children and families served by The Learning Lamp and respect the confidentiality of peers.
• Not manipulate, conceal, and/or abuse privileged information, misrepresent facts or information as it relates to The Learning Lamp.
• Strive for excellence and maximize efficiency in the performance of all responsibilities as they relate to The Learning Lamp.

COMPLIANCE TO THE CODE OF ETHICS

All board, staff, and volunteers are required to sign this Code of Ethics Statement at the onset of their involvement with The Learning Lamp. Additionally, all board and staff are required to sign a Conflict of Interest Statement and Confidentiality Statement annually. If anyone suspects misconduct, illegal activities, fraud, misuse of assets, violations of policies, he/she has a duty to report his/her concerns.

RESOLVING CONFLICTS & CONCERNS

The Learning Lamp supports an open door policy, which encourages that all people serving the organization share their questions, concerns, suggestions or complaints related to the Code of Ethics, conflicts of interests, accounting, or auditing practices with someone who can address them properly. If, after speaking with the immediate supervisor, the individual continues to have reasonable grounds to believe the concern is valid and/or that it involves misconduct on the part of an immediate supervisor, and/or cannot be directly addressed for fear of retribution, the concern should be taken to the next individual in the chain of command, the person who manages the supervisor. If the concern is related to a Board member or volunteer, the concern may be brought to the attention of the CEO, the Chairman of the Board, and/or another Board member. However, every effort to honestly and directly address concerns with the immediate supervisor should be made.

When bringing a concern through the appropriate channels does not lead to satisfaction or change the situation, or when a person feels the need to protect his/her identity, the concern may be reported to the Lighthouse anonymous reporting hotline or email service.

WHISTLE BLOWER POLICY

In order to provide a safer, more ethical work environment, The Learning Lamp offers an Anonymous Reporting Hotline. The hotline is run by an independent third party. It allows employees or volunteers to call in any suspected cases of fraud, compliance or ethics concerns or human resource matters. Employees and volunteers are encouraged to work with their immediate supervisor to address issues that are impacting their work experience in a negative manner. However, if an individual is concerned about retribution, the hotline provides a way to report a problem without having concern for retribution. To reach the hotline, call 1-844-990-0002. The anonymous reporting hotline for employees also offers an online option, which is available at lighthouse-services.com/thelearninglamp.

The Learning Lamp prohibits retaliation against any individual who reports suspected fraud or any other suspected crime or who participates in an investigation of such reports. Retaliation against an individual for reporting a suspected criminal incident is a serious violation of Company policy and will be subject to disciplinary action.

HANDLING REPORTED VIOLATIONS

Any reported allegations of harassment, discrimination or retaliation will be investigated promptly, thoroughly and impartially. The investigation may include individual interviews with the parties involved and, where necessary, with individuals who may have observed the alleged conduct or may have other relevant knowledge. Confidentiality will be maintained throughout the investigatory process to the extent consistent with adequate investigation and appropriate corrective action.

ACTING IN GOOD FAITH

Anyone reporting a concern must act in good faith and have reasonable grounds for believing the information disclosed indicates an improper accounting or auditing practice, or a violation of the Code of Ethics. The act of making unsubstantiated allegations which prove to have been made maliciously, recklessly, or with the foreknowledge that the allegations are false, will be viewed as a serious disciplinary offense and may result in discipline, up to and including dismissal from a volunteer position or termination of employment. Such conduct may also give rise to other actions, including civil lawsuits.

CONFIDENTIALITY

Reports of concerns and investigations of concerns shall be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation. Disclosure of reports of concerns to individuals not involved in the investigation will be viewed as a serious disciplinary offense and may result in discipline, up to and including termination of employment. Such conduct may also give rise to other actions, including civil lawsuits.

NO RETALIATION

This Whistleblower Policy is intended to encourage and enable directors, volunteers, and employees to report concerns within the organization for investigation and appropriate action. With this goal in mind, no Board director, employee, or volunteer who, in good faith, reports a concern shall be subject to retaliation or, in the case of an employee, adverse employment consequences, even if the concern is carefully investigated and proven to be unfounded. Moreover, a volunteer or employee who retaliates against someone who has reported a concern in good faith is subject to discipline up to and including dismissal from the volunteer position or termination of employment.

CHANGES TO THE CODE OF ETHICS AND CONFLICT OF INTEREST POLICIES

The Code of Ethics and Conflict of Interest Policies will be reviewed annually by the CEO with recommendation to the Executive Committee for revisions as necessary. The current Code of Ethics and the Conflict of Interest Policies will be approved by the Board of Directors and inserted into the employee and volunteer policy manuals.