Policies

CODE OF CONDUCT

The Foundation expects its staff and directors to conduct themselves consistent with the highest ethical standards. The Foundation's policies set forth the expected standards and the procedures to be followed to comply with the policy.  The Foundation's Code of Conduct, which emphasizes a number of different policies, is set forth below.  No policy can address every conceivable ethical situation.  Ultimately, therefore, the Foundation relies on the good judgment, integrity, and honesty of its staff and directors to ensure it addresses all situations in an ethical and legal fashion and in compliance with the applicable policy.

Conflicts of Interest
Work Standards
Confidentiality
Participation in Campaigns and Other Political Activity
Volunteer Activities
Sexual and Other Unlawful Harassment
Paid Work Outside the Foundation
Reporting Illegal or Unethical Conduct
Policy for Ethical Conduct by Members of the Investment Department
Policy on Information Sharing

FOUNDATION'S RELATIONSHIP WITH ITS GRANTEES

There is no more important relationship for a foundation than its relationship with its grantees, yet this relationship is often misunderstood.  At MacArthur, we have attempted to articulate principles addressing the relationship between the Foundation and its grantees to provide a clear understanding to our staff, grantees, and the public of our views on this relationship.  These principles find expression in the following polices or procedures adopted by the Foundation: 

Procedures for Foundation's Response to Allegations of Grantee Misconduct
Grantees at Risk
Freedom of Expression

While each policy addresses a somewhat different set of issues, there are common principles or themes linking them together. These can be summarized as follows:

• The Foundation undertakes substantial due diligence to ensure that the proposed grantee organization has the capacity, structure, values and resources to accomplish the purpose of the grant and that the Foundation's grant funds will be used for the intended charitable purpose.
• Once a grant is made, the Foundation does not control the actions of its grantees yet it continues to have a keen interest in the outcome of the grant and the manner in which grant funds are spent.
• The fact that the Foundation has made a grant may be perceived by some as an endorsement by the Foundation of the grantee and its work.
• The actions of a grantee or actions of third parties affecting a grantee can impact the Foundation, its reputation and its ability to do its work. There are times therefore where the Foundation may choose to act in response to actions by or with respect to grantees.
• The Foundation is required by applicable law to take action in certain situations to ensure that its funds are used solely for charitable purposes.
• The facts and circumstances of each case will be different. Rather than adopt prescriptive rules, the Foundation's policies generally reflect decision making frameworks that allow decisions to be made in the context of specific cases under generally stated principles.

We hope that these policies and procedures provide our grantees and the public a better understanding of how the Foundation approaches its relationship with its grantees on these issues.

MACARTHUR'S RESPONSE TO ANTI-TERRORISM FINANCING GUIDELINES

As is now the case with most charities in the United States who make grants to organizations based outside the United States, the Foundation checks the names of foreign based grantees, and the principal officers and directors of such grantees, against one or more lists maintained by the U.S. government, the European Union, and the United Nations, which contain the names determined by such entities to be terrorist organizations or individual terrorists.  This process is a result of legislation passed by the U.S. Congress, Executive Orders issued by the President, and suggested guidelines issued by the U.S. Department of the Treasury. The Foundation developed language for its grant agreement and an accompanying memorandum:

Anti-Terrorism Grant Language