Code of Conduct
PEAK Grantmaking advances grantmaking so grantmakers and grantseekers can best achieve their missions.
We connect members of the grantmaking profession, offer educational opportunities for grants management professionals at all levels, and guide grantmakers in strengthening practices – improving outcomes for grantmakers and grantseekers alike.
A code of ethics is a set of principles to guide a nonprofit organization’s decision making and activities, as well as the behavior of its employees, volunteers, and board members. The purpose of adopting a formal code is to provide employees, volunteers, and board members with guidelines for making ethical choices in the conduct of their work on behalf of the organization. Honesty, integrity, and fair practices create a solid foundation that earns the public’s trust. A code of ethics is the expression of that solid foundation.
Employees, board members, and volunteers of PEAK Grantmaking will conduct themselves and all organizational dealings with integrity, accountability, and respect, following these codes of ethics:
- Act in the best interest of PEAK Grantmaking
- Communicate openly and honestly
- Ensure proper use of PEAK Grantmaking assets
- Maintain confidentiality
- Disclose (potential) conflicts
- Comply with applicable laws/regulations, and internal controls regarding PEAK Grantmaking policies and procedures
- Report concerns in a timely manner
Whistleblower Protection Policy
PEAK Grantmaking is committed to openness and ethical behavior, and its Board monitors adherence to all applicable local, state, and federal laws and regulations. PEAK Grantmaking values honesty and maintaining the highest ethical standards.
The whistleblower policy is intended to provide a mechanism for the reporting of alleged illegal activity or misuse of PEAK Grantmaking assets while protecting the persons who make such reports from retaliation.
It is the responsibility of all employees, Board members, and volunteers to report suspected misuse of funds, theft, fraud, and other financial irregularities, as well as perceived legal non compliance or wrongdoings. In no case will retaliation of any kind be tolerated against the person making a good faith report.
Reports should be made to the Board Secretary, who is responsible for prompt investigation. If the Secretary is involved in the matter being reported, then the report can be made to any other member of the Executive Committee. Reports can be made anonymously. The Board Secretary (or other member of the Executive Committee) will present investigation findings to the Executive Committee for determination of any further action regarding the matter. As appropriate, a summary of the investigation will be disclosed to the full Board.
Reports of retaliation will be investigated promptly in a manner to protect confidentiality as much as practicable, consistent with a full and fair investigation. The party conducting the investigation will notify the person making the report when the investigation has been completed.
Conflicts of Interest Policy
The purpose of this conflict of interest policy (the “Policy”) is to provide guidance in identifying and managing actual or potential conflicts of interest involving PEAK Grantmaking with respect to any transaction or arrangement that might benefit the private interest of a staff member, officer, or director of PEAK Grantmaking, might result in a possible excess benefit transaction, or might create an appearance of impropriety. A conflict of interest includes any interest of the board member or staff person or their immediate family members. This Policy provides for disclosure of potential conflicts of interest and resolution through appropriate procedures. This Policy is intended to supplement, but not replace, any applicable state and federal laws governing conflicts of interest applicable to nonprofit and charitable corporations.
It is PEAK Grantmaking’s policy to evaluate such conflicts as transparently as possible and in a manner appropriate to the circumstances. Common sense will be a key factor in this process; however, it is paramount that PEAK Grantmaking board members and staff take preemptive action whenever possible by openly communicating actual or potential conflicts.
It is expected that staff and board members will hold the interests of PEAK Grantmaking to be primary in all related business and ethical relationships, and will discharge their duties for PEAK Grantmaking in good faith and with the degree of care that an ordinary prudent person in a like position would exercise under similar circumstances. No activity undertaken by staff or board members should conflict, or might reasonably be thought by others to conflict, with the proper performance of PEAK Grantmaking duties and responsibilities. It is important that neither staff nor board, nor their immediate family members, use or appear to use their affiliation with PEAK Grantmaking for personal or professional gain or to promote their affiliated organizations.
Interested Person. Any director, officer, or employee who has a direct or indirect financial interest, as defined below, is an interested person.
Immediate Family. Defined as spouse, domestic partner, sibling, or parents, as well as children, grandchildren, and great-grandchildren or their respective spouses.
Financial Interest/Personal Gain. A person has a conflict of interest if the person benefits, directly or indirectly (through business, investment, or immediate family) from:
- A financial interest, including an ownership or investment interest, or serves or anticipates serving as a director or officer of any entity with which PEAK Grantmaking has a transaction or arrangement (including, but not limited to, transactions or arrangements for the sale of goods or services or for the purchase of goods or services);
- A compensation arrangement with PEAK Grantmaking or with any entity or individual with which PEAK Grantmaking has a transaction or arrangement (e.g., a PEAK Grantmaking employee has a conflict of interest with respect to the determination of his or her own compensation); or
- A potential ownership or investment interest in, or compensation arrangement with, any entity or individual with which PEAK Grantmaking is negotiating a transaction or arrangement.
Compensation includes direct and indirect remuneration, as well as complimentary gifts, tickets, or favors that have more than a nominal value and are unrelated to any particular transaction and which might be considered to compromise objectivity and create an influence on the interested person.
A financial interest is not necessarily a conflict of interest. A person who has a financial interest may have a conflict of interest only if the Board of Directors or committee thereof determines that a conflict of interest exists.
Duty to Disclose. In connection with any actual or possible conflict of interest, an interested person must disclose the existence of a conflict of interest, financial or otherwise, and be given the opportunity to disclose all material facts to board members and members of committees with powers delegated by the Board to consider the proposed transaction or arrangement.
An interested person who is in doubt as to the existence of a conflict of interest is requested to disclose all facts pertaining to the transaction or arrangement before undertaking the transaction or arrangement or making any decision in the matter.
Procedures for Addressing a Conflict of Interest. PEAK Grantmaking shall adhere to the following procedures to address any conflict of interest identified by the Board or a delegated committee thereof.
I. Background & Purpose
PEAK Grantmaking advances grantmaking so that grantmakers and grantseekers can best achieve their missions.
The PEAK Grantmaking Investment Fund (hereafter referred to as the “Fund”) was created to provide financial support to PEAK Grantmaking (the “Institution”). The purpose of this Investment Policy Statement is to establish guidelines for the Fund’s investment portfolio (the “Portfolio”). The Fund refers to the assets available for long term investment. This document articulates a specific set of investment policies and provides a set of guidelines that will permit PEAK Grantmaking’s Finance Committee to oversee the investment of PEAK Grantmaking’s assets. It details the authority and responsibility for the safekeeping and effective management of PEAK Grantmaking’s funds.
II. Role of the Finance Committee
The Finance Committee (the “Committee”) is acting in a fiduciary capacity with respect to the Portfolio, and is accountable to the Board of PEAK Grantmaking, for overseeing the investment of all assets owned by, or held in trust for, the Portfolio.
- This Investment Policy Statement sets forth the investment objectives, and investment guidelines that govern the activities of the Committee and any other parties to whom the Committee has delegated investment management responsibility for Portfolio assets.
- The investment policies for the Fund contained herein have been formulated consistent with the Institution’s tolerance for assuming investment and financial risk, as reflected in the majority opinion of the Committee.
- Policies contained in this statement are intended to provide guidelines, where necessary, for ensuring that the Portfolio’s investments are managed consistent with the short-term and long-term financial goals of the Fund.
- The Committee will review this Investment Policy Statement at least once per year and will recommend, when necessary, changes for PEAK Grantmaking Board approval.
III. Responsibilities of Management
Management shall be responsible for the day-to-day administration and implementation of policies established by the Board and/or the Finance Committee concerning the management of institutional funds. Management shall also be the primary liaison between any investment consultants and/or other outside professionals that may be retained to assist in the management of such funds. Specifically, management shall:
- Oversee the day-to-day operational investment activities of all institutional funds subject to policies established by the Finance Committee
- Contract with any necessary outside service providers, such as: investment consultants, investment managers, banks, and/or trust companies and/or any other necessary outside professionals.
- Ensure that the service providers adhere to the terms and conditions of their contracts; have no material conflicts of interests with the interests of PEAK Grantmaking Inc.; and, have performance monitoring systems sufficient to provide the Finance Committee with timely, accurate and useful information.
- Monitor asset allocation and rebalance assets, as directed by the Finance Committee and in accordance with approved policies; and, tend to all other matters deemed to be consistent with due diligence with respect to prudent management of institutional funds.
- Comply with official accounting and auditing guidelines regarding due diligence and ongoing monitoring of investments, especially alternative investments. Prepare and issue status reports to the Board and the Finance Committee at each board and committee meeting.
IV. Investment Objective
The overall investment objective of the Fund is to maximize the return on invested assets while minimizing risk and expenses. This is done through prudent investing and planning, as well as through the maintenance of a diversified portfolio.
V. Portfolio Investment Policies
- Asset allocation policy
- The Committee recognizes that the strategic allocation of Portfolio assets across broadly defined financial asset and sub-asset categories with varying degrees of risk, return, and return correlation will be the most significant determinant of long-term investment returns and Portfolio asset value stability.
- The Committee expects that actual returns and return volatility may vary from expectations and return objectives across short periods of time.
- Fund assets will be managed as a balanced portfolio composed of two major components: an equity portion and a fixed income portion. The expected role of Fund equity investments will be to maximize the long-term real growth of Portfolio assets, while the role of fixed income investments will be to generate current income, provide for more stable periodic returns, and provide some protection against a prolonged decline in the market value of Portfolio equity investments.
- Outlined below are the long-term strategic asset allocation guidelines, determined by the Committee to be the most appropriate, given the Fund’s long-term objectives and short-term constraints. Portfolio assets will, under normal circumstances, be allocated across broad asset and sub-asset classes in accordance with the following guidelines:
Asset Allocation Lower Target Upper Equity 40% 50% 60% Fixed Income 60% 50% 40% Cash & Cash Equivalents 0% 0% 0%
Rebalancing shall be done on a semi-annual basis or more frequently if deemed necessary by the Committee.
- Diversification policy
Diversification across and within asset classes is the primary means by which the Committee expects the Portfolio to avoid undue risk of large losses over long time periods. To protect the Portfolio against unfavorable outcomes within an asset class due to the assumption of large risks, the Committee will take reasonable precautions to avoid excessive investment concentrations. Specifically, the Committee will look to low cost investment vehicles seeking to match a broadly defined market, or invest in a “fund of funds” that invest in other investment funds strategically designed to correlate to the Portfolio’s target asset allocation.
Any income generated from PEAK Grantmaking’s investment vehicles will be automatically reinvested in that vehicle.
- Other investment policies
Unless expressly authorized by the Committee, the Portfolio and its investment managers are prohibited from:
- Purchasing securities on margin or executing short sales.
- Pledging or hypothecating securities, except for loans of securities that are fully collateralized.
- Purchasing or selling derivative securities for speculation or leverage.
- Engaging in investment strategies that have the potential to amplify or distort the risk of loss beyond a level that is reasonably expected, given the objectives of their Portfolio.
VI. Monitoring Portfolio Investments and Performance
The Committee will monitor the Portfolio’s investment performance against the Portfolio’s stated investment objectives. At a frequency to be decided by the Committee, it will formally assess the Portfolio and the asset allocation that make up its underlying investments.
An annual report of the investment accounts will be presented to the Board.