Report A Concern

Report a concern by either of the following methods:

Completing the communications form on the site:

Calling a special toll-free telephone line designated for NCBA CLUSA

(Posters, reference cards, and training are provided)

Or contact: This email address is being protected from spambots. You need JavaScript enabled to view it.

Conflict of Interest Disclosure Form

Section 4.0310-00 Conflict of Interest Disclosure Form

View, download or print the full PDF:

4.0310-00 Conflict of Interest
Disclosure Form

Code Violations/Reporting

Section 4.0308-00 Code Violations/Reporting

The Human Resources Department is responsible for administering and updating this Code of Business Ethics. Depending on the nature of an alleged violation, the Chief Human Resources Officer or his/her designee would be responsible for conducting an investigation and would be responsible, together with appropriate management officials, for determining appropriate disciplinary action and reporting to the Board of Directors. NCBA CLUSA attempts to impose discipline for each Code of Conduct violation in a consistent manner appropriate to the nature of the violation, including termination of employment if circumstances warrant. NCBA CLUSA reserves the right, however, to determine, in its discretion, the appropriate level of discipline for any violation of the Code of Business Ethics.

All NCBA CLUSA employees are responsible for promptly reporting any issue or concern they believe in good faith may constitute a violation of this Code of Business Ethics or any other NCBA CLUSA policy. If you believe a violation of this code, or any other NCBA CLUSA policy, has occurred, please contact NCBA CLUSA’s Human Resources Department.

Any such complaints may be submitted in person, in writing or on an anonymous basis to a Human Resources representative.


As a participant in highly regulated activities utilizing government grants, NCBA may at times be subject to inquiries and investigations by government agencies. NCBA is committed to cooperating with any such inquiry or investigation. All such interactions must be coordinated with the President/CEO to secure appropriate legal assistance to ensure that NCBA’s legal interests are protected.

Subsection 4.0308-01 Whistleblower Policy

Reporting Responsibility

It is the responsibility of all Board members, Officers, employees, and volunteers to report concerns about violations of NCBA CLUSA’s Code of Business Ethics or suspected violations of law or regulations that govern NCBA CLUSA’s operations.

Compliance Hotline for Financial Integrity

NCBA CLUSA has retained the services of Signius Communications to manage a hotline program to enable employees from any office site to report anonymously any incidents of theft, financial misconduct, or any wrongdoing. Signius Communications is an independent third party that is responsible for ensuring an unbiased communication of any reported information to NCBA CLUSA Board of Directors and management for evaluation and action.

Employees may report a concern by either of the following methods:

Protection for Whistleblowers and Witnesses Policy

It is the responsibility of all employees to comply with NCBA CLUSA’s policies, and to report violations or suspected violations in accordance with this Code of Business Ethics. An employee should be free to initiate good faith contact with any NCBA CLUSA personnel, or provide information in the context of an official investigation or other inquiry, without reprisal.

No employee shall be subject to reprisal as a result of having provided information in good faith regarding a suspected incident of fraud or corruption. A reprisal for the purposes of this policy is an act of retaliation on the part of a staff member’s colleagues, supervisors, or any NCBA CLUSA’s Senior Leadership carried out to punish a staff member for having provided such information. Reprisals are adverse actions on the part of co-workers or supervisors in response to the employee’s acting as whistleblower which could include harassment, discriminatory treatment, assignment of work outside of the corresponding position description, inappropriate evaluations of performance, inappropriate awards of merit pay, or the withholding of any other entitlement. For the purposes of this policy, a reprisal also includes the threat of reprisal.

No Senior Leader/Officer may use his or her position to influence an employee or prevent an employee from exercising their rights as provided in this policy. Any officer who is found to have engaged in such behavior shall be subject to disciplinary action.

The protection affirmed in this policy applies only to an employee acting in good faith and providing information which they reasonably believes is true. Providing information for motives of personal gain or with malicious intent, or information that is known to be false, is not protected by this Policy and may be subject to disciplinary action against the individual making the malicious allegation.

An employee who believes that they have been the subject of reprisal as described in this policy, should report their concerns to the Chief Human Resources Officer or to the Chair of NCBA CLUSA Board’s Audit Committee.

No Retaliation

It is contrary to the values of NCBA CLUSA 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 as a complaint of discrimination, or suspected fraud, or suspected violation of any law or regulation governing the operations of NCBA CLUSA. An employee who retaliates against another employee who has reported a violation in good faith is subject to discipline up to and including termination of employment.

An employee who believes that he or she has been the subject of reprisal as described in this policy should report their concerns to the Chief Human Resources Officer or to the Chair of the Board’s Audit Committee.

Reporting Procedure

The 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. It is the responsibility of all Directors, Officers, and Employees to comply with the Code of Business Ethics and to report violations or suspected violations in accordance with this Whistleblower Policy. Employees should share their questions, concerns, suggestions, or complaints with an immediate supervisor. If an employee believes an immediate supervisor would stymie, prevent or inhibit remedial action, the employee should contact the Chief Human Resources Officer or contact the Whistleblower Hotline directly to ensure protection of anonymity.

The Whistleblower Hotline reports are not managed within NCBA CLUSA and are directly provided to Chairman of the Board of Directors, Vice Chairman of the Board of Directors, and the Chair of the Audit Committee.

Acting in Good Faith

Anyone filing a complaint concerning a violation or suspected violation must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation. 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.


Violations or suspected violations may be submitted on a confidential basis by the complainant. 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 NCBA CLUSA’s representative designated by the Board of Director’s will notify the person who submitted a complaint and acknowledge receipt of the reported violation or suspected violation. All reports will be promptly investigated and appropriate corrective action will be taken if warranted by the investigation.

It is NCBA CLUSA’s policy to promote and implement prompt and consistent enforcement of this code, fair treatment for persons reporting unethical behavior, objective and clear standards for compliance and a fair process by which to determine violations of this code and other NCBA CLUSA policies. It is against NCBA CLUSA policy to retaliate against any employee for good faith reporting of violations of this code or any other NCBA CLUSA policy. Any employee who retaliates against someone who has reported a violation in good faith is subject to discipline up to an including termination of employment. The Whistleblower Policy is intended to encourage and enable employees and others to raise serious concerns within the organization prior to seeking resolution outside of the organization.

Code of Business Ethics and Conduct Acknowledgement Form

Section 4.0309-00 Code of Business Ethics and Conduct Acknowledgement Form

Overview of Conduct

Section 4.0307-00 Overview of Conduct

NCBA CLUSA is committed providing a work environment that will attract and retain a highly talented workforce. As a global community, we value and celebrate each of our unique cultures and qualities.

Every employee is responsible for creating a climate of trust and respect, and for promoting a productive work environment that is free from discrimination, harassment, exploitation, and retaliation.

Subsection 4.0307-01 Sexual Exploitation and Abuse of Clients (SEA) Policy

NCBA CLUSA recognizes the unequal power dynamic that may exist between its staff and clients (participants or stakeholders) and the resulting potential for exploitation inherent in its work. NCBA CLUSA further recognizes that exploitation undermines the credibility of its work and severely damages victims of these exploitive acts and their families and communities. As a condition of their employment, NCBA CLUSA employees, consultants and volunteers must acknowledge and agree to the following core principles:

  • Sexual exploitation and abuse by NCBA CLUSA staff is strictly prohibited;
  • Sexual activity with children (defined according to the Convention on the Rights of the Child, as all persons under the age of 18) is prohibited, regardless of the local age of majority or age of consent. Mistaken belief in the age of a child is not a defense;
  • Exchange of money, employment, goods, or services for sex, including sexual favors or other forms of humiliating, degrading or exploitative behavior is prohibited. This prohibition includes exchange of assistance that is due to clients;
  • Sexual relationships between NCBA CLUSA staff and clients are forbidden since they are based on inherently unequal power dynamics. Such relationships undermine the credibility and integrity of humanitarian aid work;
  • Whenever a NCBA CLUSA staff member has concerns or suspicions regarding sexual abuse or exploitation by a fellow worker, they must be reported to their supervisor or to the Human Resources Department;
  • As humanitarian workers, we are obliged to create and maintain an environment which prevents sexual exploitation and abuse, while promoting the implementation of the required code of conduct. Managers at all levels have particular responsibilities to support and develop systems that maintain this environment.

If NCBA CLUSA discovers that any of its staff has violated this policy, NCBA CLUSA will take all necessary action, including immediately terminating that staff member’s employment, reporting all unlawful conduct to the local authorities, and cooperating in any subsequent investigation by said local authorities. NCBA CLUSA will not tolerate any violation of this policy. If you have any questions about the SEA policy, please contact Human Resources.

Additionally, to the extent applicable NCBA will comply with Federal anti-trafficking laws that are contained in any of its government contracts.

Subsection 4.0307-02 Equal Employment Opportunity Policy

NCBA CLUSA is an equal opportunity employer and considers all employees and applicants for employment without regard to race, color, religion, sex, national origin, sexual orientation, gender identity, gender expression, age, disability, genetic information, military or veteran status, marital status, personal appearance, familial status, family responsibilities, matriculation, political affiliation, childbirth or related medical conditions or any other characteristic protected by applicable federal, state or local law. NCBA CLUSA also provides reasonable accommodation to qualified individuals with a disability in accordance with applicable laws.

This policy extends to every phase of the employment process including recruiting, hiring, training, transfer, promotion, compensation, benefits, performance evaluation, discipline, termination, layoffs and all other terms and conditions of employment. All employment decisions are made on the basis of job related criteria, recognizing the principle of equal employment opportunity.

If you have a question or concern, please do not hesitate to contact Human Resources. Employees, who believe they have been discriminated against or otherwise treated unfairly in violation of this policy, should promptly utilize NCBA CLUSA’s complaint procedure. No employee will be subject to retaliation by NCBA CLUSA for reporting what they believe, in good faith, to be an incident of discrimination or harassment.

Appropriate disciplinary action, up to and including termination, may be taken against any employee willfully violating this policy.

NCBA CLUSA is committed to a work environment free from unlawful discrimination and harassment. Each individual has the right to work in a professional atmosphere that promotes equal employment opportunities and prohibits discriminatory practices, including unlawful harassment. Therefore, NCBA CLUSA expects that all relationships among persons in the workplace will be business-like and free of such bias, prejudice and harassment.

Subsection 4.0307-03 Communications with the Media

NCBA CLUSA wishes to provide open, accurate, and consistent communication to the public. To maintain the consistency and accuracy of this information, only designated spokespersons may respond to all inquiries. Only these spokespersons are authorized to release information to the public at the appropriate time. Unless you have been designated as a spokesperson, you should not respond to inquiries from the press. All inquiries from the media should be forwarded immediately to the Director of Communications or the CEO.


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