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Annex 02: Code of Conduct

Table of Contents:

Chapter 1: Introduction

Chapter 2: Purpose and ScopeChapter

3: Guiding Principles

Chapter 4: Professional Conduct and Ethical StandardsChapter

5: Responsibilities of Employees, Volunteers, and PartnersChapter

6: Conflict of Interest

Chapter 7: Compliance with Laws and RegulationsChapter 8: Reporting ViolationsChapter 9: Disciplinary ActionsChapter 10: Review and Updates

Chapter 1: Introduction

1.1 OverviewThe Code of Conduct is a foundational document outlining the ethical principles, values, and standards that guide all activities and interactions within Refugee Pathways & Integration Canada (RefPIC). It is designed to ensure that employees, volunteers, and partners act with the highest level of professionalism, integrity, and respect. By fostering a culture of accountability and transparency, this Code reinforces RefPIC’s mission to empower refugees, displaced persons, and host communities through programs that promote economic independence, social cohesion, and resilience.

1.2 Importance of Adherence to the CodeAdherence to this Code is essential to maintaining trust with stakeholders, including beneficiaries, donors, and partners. By following the Code, RefPIC staff and volunteers demonstrate their commitment to ethical practices, respect for human dignity, and compliance with local and international laws. Non-compliance can undermine the organization’s credibility, jeopardize its mission, and harm the communities it serves.

Chapter 2: Purpose and Scope

2.1 Purpose of the CodeThe purpose of the Code of Conduct is to:(a) Establish clear standards of behavior and accountability for all individuals involved in RefPIC’s operations.(b) Safeguard the rights and well-being of refugees, displaced persons, and host communities.(c) Ensure compliance with applicable laws, regulations, and international frameworks such as the Global Compact on Refugees (GCR).(d) Promote a safe and inclusive environment that values diversity, equity, and inclusion.

2.2 Scope of ApplicationThis Code applies to:(a) All RefPIC employees, volunteers, board members, and consultants, regardless of their location or role.(b) Partner organizations and contractors engaged in RefPIC’s activities, who must adhere to the principles outlined herein.(c) Any individual or entity representing RefPIC in interactions with beneficiaries, governments, donors, or other stakeholders.

Chapter 3: Guiding Principles

3.1 IntegrityIntegrity is the cornerstone of RefPIC’s operations. All individuals associated with the organization must:(a) Uphold honesty and moral principles in all actions and decisions.(b) Avoid conflicts of interest and disclose any situation that could compromise impartiality.(c) Protect organizational resources from misuse or misappropriation.

3.2 TransparencyTransparency ensures accountability and fosters trust. RefPIC staff and partners must:(a) Provide accurate and timely information about operations, finances, and program outcomes.(b) Engage openly with stakeholders and beneficiaries to ensure their needs and concerns are addressed.(c) Maintain clear and accessible communication channels for reporting and feedback.

3.3 RespectRespect is central to fostering positive relationships with beneficiaries, partners, and colleagues. All individuals must:(a) Treat everyone with dignity, fairness, and compassion, regardless of their background or status.(b) Avoid discriminatory practices or behaviors that may harm or alienate others.(c) Promote a workplace culture that values diversity and inclusivity.

3.4 AccountabilityAccountability ensures that RefPIC operates responsibly and effectively. Staff, volunteers, and partners must:(a) Take ownership of their actions and decisions.(b) Actively participate in monitoring and evaluation processes to improve program impact.(c) Comply with organizational policies, donor requirements, and applicable legal frameworks.

Chapter 4: Professional Conduct and Ethical Standards

4.1 Expectations for Employees and VolunteersEmployees and volunteers are expected to:(a) Demonstrate professionalism in all interactions and uphold the values of the organization.(b) Prioritize the safety and well-being of beneficiaries, particularly vulnerable groups such as women and children.(c) Follow established protocols for safeguarding, reporting, and managing resources.(d) Foster a collaborative and supportive work environment that encourages innovation and teamwork.

4.2 Commitment to Upholding Ethical StandardsRefPIC is committed to maintaining the highest ethical standards in its operations. All individuals representing the organization must:(a) Abide by the principles outlined in this Code of Conduct at all times.(b) Participate in mandatory training sessions on ethics, safeguarding, and accountability.(c) Report any observed or suspected violations of this Code through established reporting mechanisms.(d) Respect confidentiality and privacy when handling sensitive information.

Chapter 5: Responsibilities of Employees, Volunteers, and Partners

5.1 Roles and ObligationsEvery individual associated with Refugee Pathways & Integration Canada (RefPIC) has specific roles and obligations to uphold the organization’s mission and values.(a) Employees: Employees are expected to perform their duties with professionalism, integrity, and dedication, adhering to organizational policies and this Code of Conduct. They are also responsible for fostering a safe and respectful environment for all.(b) Volunteers: Volunteers play a vital role in RefPIC's operations. They must act in the best interests of the organization, respecting the rights and dignity of beneficiaries and colleagues. Volunteers are also required to complete any training relevant to their roles.(c) Partners: RefPIC’s partner organizations are expected to align with the principles of this Code in all collaborative efforts. This includes respecting safeguarding protocols, adhering to anti-corruption measures, and ensuring compliance with all relevant laws and policies.

5.2 Standards of Accountability(a) Transparency: All individuals must communicate openly about their actions, decisions, and use of resources.(b) Responsiveness: Employees, volunteers, and partners must respond promptly and appropriately to feedback, complaints, and emergencies.(c) Ethical Decision-Making: Every decision should be guided by the principles outlined in this Code, ensuring fairness, respect, and adherence to organizational goals.(d) Performance Reviews: Regular evaluations will assess adherence to the Code, with mechanisms in place to address any identified gaps or violations.

Chapter 6: Conflict of Interest

6.1 Defining Conflict of InterestA conflict of interest arises when personal, financial, or other interests interfere with the ability of an individual to act in the best interest of RefPIC. Examples include:(a) Personal relationships influencing hiring, procurement, or decision-making.(b) Financial interests in a vendor or partner organization.(c) Activities outside of work that conflict with RefPIC’s mission or reputation.

6.2 Procedures for Managing Conflicts(a) Disclosure: All employees, volunteers, and partners are required to disclose potential conflicts of interest to their supervisors or designated officers.(b) Assessment: Disclosed conflicts will be reviewed by a conflict-of-interest committee, which will determine appropriate actions to mitigate risks.(c) Mitigation Measures: These may include recusal from decision-making processes, reassigning responsibilities, or, in severe cases, terminating the relationship with the individual or partner organization.(d) Record Keeping: All disclosed conflicts and their resolutions will be documented for transparency and accountability.

Chapter 7: Compliance with Laws and Regulations

7.1 Adherence to National and International LawsRefPIC operates in full compliance with the laws of Canada and any host countries where it conducts activities. Key areas of compliance include:(a) Labor Laws: Adhering to fair labor practices and ensuring safe working conditions.(b) Human Rights Standards: Respecting and promoting the principles of the Universal Declaration of Human Rights.(c) Financial Regulations: Maintaining transparency and accountability in financial transactions to prevent fraud and mismanagement.(d) Privacy Laws: Safeguarding the personal information of beneficiaries, employees, and partners in accordance with applicable data protection laws.

7.2 Consequences for Non-Compliance(a) Internal Disciplinary Measures: Non-compliance with laws and regulations will result in disciplinary actions, ranging from warnings to termination.(b) Legal Consequences: Violations that constitute legal offenses will be reported to appropriate authorities, and the responsible individuals will face prosecution as mandated by law.(c) Partnership Review: Partners found in violation of laws or regulations will have their agreements reviewed and potentially terminated.

Chapter 8: Reporting Violations

8.1 Channels for Reporting MisconductRefPIC provides multiple channels to report violations of the Code of Conduct:(a) Designated Officer: Reports can be made directly to a designated safeguarding or compliance officer.(b) Confidential Hotline: A confidential hotline is available for employees, volunteers, and beneficiaries to report misconduct anonymously.(c) Online Reporting System: A secure online platform is accessible for submitting complaints or concerns.

8.2 Confidentiality and Protection Mechanisms(a) Confidentiality: All reports will be handled with strict confidentiality to protect the identity of the complainant and ensure a fair investigation process.(b) Non-Retaliation Policy: RefPIC strictly prohibits retaliation against individuals who report violations in good faith. Any act of retaliation will result in disciplinary action.(c) Support for Complainants: Complainants will have access to counseling, legal guidance, or other forms of support as necessary.

This framework establishes a robust mechanism for addressing violations while protecting the rights and dignity of all involved. Subsequent chapters will address disciplinary actions, training programs, and the process for periodic reviews.

Chapter 9: Disciplinary Actions

9.1 Procedures for Investigating ViolationsRefugee Pathways & Integration Canada (RefPIC) has established clear procedures to ensure that violations of the Code of Conduct are investigated promptly, fairly, and transparently.(a) Initial Assessment:Upon receiving a report of misconduct, the designated compliance officer will conduct a preliminary assessment to determine the validity and severity of the claim.(b) Investigation Team:A neutral and qualified investigation team will be appointed to examine the allegations. The team will include individuals with no direct involvement or conflict of interest in the case.(c) Investigation Process:(i) Collect and review all relevant evidence, including documents, witness statements, and other materials.(ii) Conduct interviews with the complainant, witnesses, and the accused individual(s).(iii) Ensure adherence to principles of confidentiality and fairness throughout the investigation.(d) Reporting:A comprehensive investigation report will be prepared, outlining findings, conclusions, and recommended actions. This report will be submitted to the senior leadership team or a designated disciplinary committee for final review.

9.2 Sanctions and PenaltiesSanctions for violations of the Code of Conduct are proportionate to the severity of the misconduct and include the following:(a) Verbal or Written Warnings: For minor infractions, a warning will be issued with guidance for corrective behavior.(b) Mandatory Training or Counseling: Individuals may be required to attend specific training sessions or counseling to address behavioral issues.(c) Suspension: Temporary suspension from duties, pending further investigation or corrective measures.(d) Termination of Employment or Partnership: Serious violations, including those involving fraud, harassment, or gross misconduct, may result in immediate termination.(e) Legal Action: Violations that constitute criminal offenses, such as fraud or abuse, will be reported to law enforcement authorities, and RefPIC will cooperate fully in any legal proceedings.(f) Restitution: If misconduct results in financial loss or damage, the responsible party may be required to make restitution.

RefPIC reserves the right to impose additional penalties as deemed appropriate based on the specifics of the case and applicable laws.

Chapter 10: Review and Updates

10.1 Periodic Review of the CodeThe Code of Conduct will be reviewed on an annual basis to ensure its continued relevance, effectiveness, and alignment with evolving organizational needs and legal requirements.(a) Review Committee:A designated committee, comprising representatives from leadership, compliance, and field operations, will conduct the review.(b) Stakeholder Engagement:Feedback from employees, volunteers, partners, and beneficiaries will be solicited to identify gaps or areas for improvement.(c) Reporting:The findings of the review process will be documented in an annual report, including recommendations for updates or amendments.

10.2 Amendments and Updates(a) Approval Process:Proposed amendments to the Code must be approved by RefPIC’s senior leadership team and, if necessary, the Board of Directors.(b) Communication:All amendments will be communicated to employees, volunteers, and partners through formal channels, including email updates, staff meetings, and the organization’s website.(c) Training and Implementation:Mandatory training sessions will be conducted to ensure all stakeholders are familiar with updates to the Code. Implementation timelines will be clearly defined to facilitate a smooth transition.

The review and update process reflects RefPIC’s commitment to maintaining the highest standards of integrity, accountability, and transparency in all aspects of its operations. Regular evaluation and adaptation of the Code ensure that it remains a living document that supports the organization’s mission and values.

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