Meridian International Center Partner Code of Conduct – September 2024

Background on Meridian International Center

Founded in 1960, Meridian International Center (Meridian) is a nonprofit, nonpartisan diplomacy center with the vision that greater understanding and collaboration between the United States and the world leads to a more prosperous future for all.  Meridian believes the United States is stronger and the world is secure and more prosperous when leaders collaborate across countries and cultures. Meridian strengthens engagement between the United States and the world to solve shared global challenges through four pillars of work:  global leadership, diplomatic engagement, culture, and corporate diplomacy

Our Work with Partners

Meridian partners with various organizations, including vendors, contractors, subrecipients, and other external entities, to advance our mission of strengthening global engagement. Our partners are integral to the success of our operations, and we rely on their expertise and cooperation to fulfill our objectives. As we collaborate, it is critical that partners align with Meridian’s core values of global community; collaboration; innovation; and equity, diversity, and inclusion.

Purpose of the Partner Code of Conduct

The Meridian Partner Code of Conduct (Code) sets forth the minimum standards we expect from our partners when providing goods and services to Meridian. This Code helps to communicate our principles and outline expectations for compliance with legal obligations, fair dealings, and responsible business operations.

Our Expectations of Meridian Partners

Meridian expects all partners to adhere to the following principles:

1. Anti-Bribery and Anti-Corruption

Upholding a zero-tolerance policy on bribery and corruption is critical to maintaining ethical standards. Partners are expected to comply with anti-corruption laws and avoid improper payments or kickbacks, reporting any suspected incidents of bribery or unethical conduct immediately.

2.Confidentiality and Data Protection

Maintaining the confidentiality of proprietary and sensitive information is critical to protecting Meridian’s operations, reputation, and compliance with legal obligations. Partners are expected to take all necessary measures to safeguard confidential and proprietary information related to Meridian, its employees, clients, and partners. This includes implementing best practice security measures to protect any Meridian data that is shared with, processed by, or stored by the partner.

Partners must comply with all relevant data protection regulations, including maintaining secure storage, access controls, and encryption where applicable. Any breach or unauthorized access to Meridian data must be reported immediately, and steps must be taken to mitigate any risks resulting from such incidents.

3. Conflicts of Interest

Ensuring that business decisions are free from conflicts of interest helps maintain trust, objectivity, and fair competition. Meridian expects partners to identify, disclose, and resolve any personal or financial conflicts of interest that could affect their work with Meridian. Partners are expected to avoid offering gifts or favors that could influence Meridian’s decision-making.

4. Ethical Business Practices

Ethical business practices build trust and support long-term, transparent partnerships. Meridian expects partners to conduct business with integrity, avoiding bribery, corruption, or fraudulent behavior.  Partners are expected to operate transparently and ensure business decisions are made with honesty and fairness.

5. Fiduciary Responsibility and Federal Compliance

Contractors have a fiduciary responsibility to ensure the appropriate use of federal funds received when contracting with Meridian. Partners are expected to exercise due care in managing these funds, ensuring they are used in compliance with all applicable laws and regulations. This responsibility extends to any subcontracts awarded using these funds, where partners must ensure that their subcontractors adhere to the same standards of care and compliance.

Partners must take all necessary steps to be aware of and comply with any federal requirements that flow down to them, including those related to the management and reporting of federal funds. Misuse, mismanagement, or failure to comply with federal regulations governing these funds could result in significant consequences, including termination of the contract and potential legal action.

6. Health and Safety

A safe and healthy work environment promotes productivity and well-being. Partners are expected to provide a safe working environment in compliance with all applicable health and safety laws and regulations, taking proactive steps to minimize workplace risks and prevent accidents.

7. Human Rights and Labor Practices

Protecting human rights and ensuring the dignity of individuals is central to Meridian’s values. Partners are expected to prohibit the use of forced or child labor, while providing fair wages, safe working conditions, and respect for workers' rights, including the right to collective bargaining. Partners must also avoid any practices that would directly support or enable human trafficking. These expectations include:

      • Avoiding engagement in any commercial sex acts induced by force, fraud, or coercion, especially when individuals under 18 are involved.
      • Ensuring that employment offers are free from false or fraudulent representations about terms and conditions.
      • Prohibiting the charging of recruitment fees to employees and avoiding the confiscation of identity documents.
      • Providing legally required return transportation for employees recruited from another country, unless exempt or otherwise agreed upon.
      • Ensuring that any housing or lodging provided to employees complies with applicable host country standards.
8. Legal and Regulatory Compliance

Operating legally and with integrity ensures that all business dealings are conducted in accordance with applicable laws and regulations. Partners are expected to comply with relevant labor, financial practices, and anti-corruption laws while maintaining valid permits, licenses, and certifications to ensure legal operations.

9. Political Activity

Maintaining Meridian’s non-partisan stance and compliance with federal regulations requires that partners keep political activities and lobbying efforts separate from their work with Meridian. Under the Byrd Anti-Lobbying Amendment, partners are expected to ensure that no Meridian funds, resources, or federally derived funds are used for lobbying efforts aimed at influencing government officials or legislation.

Any political contributions or lobbying activities conducted by the partner must be independent and not associated with Meridian’s resources, contracts, or grants. Partners are expected to comply with all applicable federal, state, and local laws related to lobbying and political activities, including submitting any required disclosures or certifications related to lobbying.

10. Procurement Practices

Ensuring fair and transparent procurement practices is essential to maintaining the integrity of how funds provided by Meridian are used. Partners are expected to procure goods and services fairly and transparently, especially when issuing subcontracts using funds provided by Meridian.

11. Whistleblower Protections

Protecting individuals who report unethical or illegal behavior is essential to ensuring accountability and transparency. Partners are expected to implement mechanisms for employees to report unethical or unlawful behavior without fear of retaliation, including concerns related to the mismanagement of federal contracts or grants, gross waste of federal funds, abuse of authority, and dangers to public health or safety.

Partners are expected to inform their employees in writing of their rights and protections as whistleblowers. Employees must be protected from retaliation when reporting concerns internally or to authorized officials, such as members of Congress or inspectors general. Partners are responsible for promptly addressing any whistleblower reports and ensuring whistleblowers are shielded from retaliation for their disclosures.

Compliance with the Code

All partners providing goods or services to Meridian International are expected to comply with this Code and adhere to the highest standards of ethical and legal responsibility. Partners must ensure that their employees and subcontractors understand and follow these guidelines.

By contracting with Meridian International Center, partners agree to take full accountability for their actions and the actions of their subcontractors, ensuring compliance with this Code and all relevant legal requirements. Meridian reserves the right to request documentation, conduct audits, and verify that partners are meeting their obligations under this Code.

Partners are responsible for promptly reporting any breaches of this Code, along with actions taken to address and resolve the issue. Failure to resolve violations or non-compliance may lead to the termination of the business relationship.