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Integrity Policy

ThinkWell is committed to ensuring that we maintain the highest ethical and legal standards. It is critical that our business interactions and practices with each other as well as our clients, vendors, donors, sub- awardees, and other stakeholders comply with applicable laws and reinforce our reputation for honesty and integrity. Consultants, agents, or representatives retained in relation to the provision of goods or services to the federal government also must agree to comply with all applicable laws, regulations, and ThinkWell policies governing employee conduct.

Anti-Trafficking Policy

As recipients and contractors of US government funding, ThinkWell employees, consultants, sub- recipients, and subcontractors are prohibited from engaging in trafficking in persons while working on a US government-sponsored program or project. This includes the following:

  • Sex trafficking in which a commercial sex act is induced by force, fraud, or coercion, or in which the person induced to perform the act is under 18 years of age; or
  • Recruiting, transporting, or harboring a person for labor or services using force, fraud, or coercion for the purposes of involuntary servitude, peonage, debt bondage, or slavery; or
  • Procuring commercial sex acts during the contract period; or
  • Using forced labor in performing the contract; or
  • Destroying, concealing, confiscating, or otherwise denying access by an employee to the employee’s identity papers or immigration documents, such as passports, identification cards, or drivers’ licenses; or
  • Use of deceptive or unlawful employment strategies, including failing to disclose work location, terms and conditions, wages, benefits, living conditions, and costs to the employee in a format and language that the employee understands; or
  • Use of recruiters who do not comply with local labor laws of the country where the recruiting takes place or who charge recruitment fees.

All ThinkWell personnel, suppliers, and supplier personnel are required to report any suspected trafficking-related activity or violation of this policy to ThinkWell management. Any ThinkWell employee who receives such a report is required to immediately inform the Talent Director. Employees can also report directly to the Global Human Trafficking Hotline at 1-844-888-FREE or help@befree.org.

ThinkWell prohibits retaliation against any ThinkWell employee who reports prohibited trafficking- related activity or other violations

Whistleblower Policy

ThinkWell encourages staff to report good-faith concerns about potential illegal practices or violations of our policies. Appropriate subjects to raise include concerns about financial improprieties, accounting or audit matters, ethical violations, or illegal behavior.

ThinkWell prohibits retaliation against staff for making good faith complaints, reports, or inquiries under this policy or for participating in related reviews or investigations. This protection extends to those whose allegations are made in good faith but prove to be mistaken. ThinkWell reserves the right to discipline persons who make bad-faith, knowingly false, or vexatious complaints, reports, or inquiries or who otherwise abuse this policy.

Whistleblower complaints or reports may be made on a confidential or anonymous basis. They should describe in detail the specific basis for the complaint or report. They should be directed to either The Talent Director or the ThinkWell third-party whistleblower hotline at: www.integritycounts.ca/org/ThinkWell

United States Toll Free Call: 1-866-921-6714 Email: ThinkWell@integritycounts.ca

Mail:

P.O. Box 91880

West Vancouver, British Columbia

V7V 4S4 Canada

ThinkWell will conduct a prompt, discreet, and objective review or investigation. ThinkWell may be unable to fully evaluate a vague or general complaint, report or inquiry that is made anonymously.

Conflicts of Interest

ThinkWell strives to encourage and promote objectivity in business decision-making. Our employees have a duty of loyalty to the company. We expect our staff to make business decisions with ThinkWell’s best interests in mind and to exercise business judgment independent of external influences such as personal financial interests, external business relationships, outside employment, and familial relationships.

All staff should avoid situations that involve a conflict or perceived conflict between their personal interest and the interest of ThinkWell. Conflicts of interest include the following:

  • Owning (either directly or indirectly through a relative) a business that does or seeks to do business with ThinkWell, or is a competitor of ThinkWell.
  • Serving as a director, officer, partner, consultant, or in a managerial or technical capacity with an outside enterprise that does or is seeking to do business with ThinkWell, or is a competitor of ThinkWell.
  • Hiring or managing an employee who is a family member or a close relation.
  • Acting as a broker or otherwise engaging for the benefit of a third party in transactions involving or potentially involving ThinkWell or its interests.
  • Accepting gifts from a potential business partner.
  • Accepting additional employment with another company.
  • Placing business with any company in which one or a relative has a financial interest.
  • Inappropriately communicating with a competitor.
  • Other arrangements or circumstances, including family or other personal relationships, which might dissuade staff from acting in the best interest of the company.