Code of Business Conduct and Ethics


General Principles

As a fundamental principle, NICSA adheres to the highest ethical standards. NICSA will comply with the laws and regulations applicable to its business activities. Further, as a representative of the financial industry, NICSA must have a reputation for absolute integrity. Each NICSA staff member, board member and volunteer is responsible for continuing to uphold these high ethical and professional standards.

Fair representation

Staff members and board members should not knowingly misrepresent, or cause others to misrepresent, facts about NICSA to its members or to any member of the public.

Protection and proper use of NICSA assets

Staff members and board members should endeavor to protect NICSA’s assets and ensure their efficient use. Theft, carelessness, and waste have a direct impact on NICSA’s ability to serve its members. Any suspected incident of fraud or theft should be immediately reported to the President or to the Chair of the Board of Directors.


NICSA staff members and board members must maintain the confidentiality of confidential information entrusted to them by NICSA, except when disclosure is authorized by the NICSA or required by laws or regulations.


NICSA requires honest and accurate recording and reporting of information in order to conduct its business and to make responsible business decisions. All of NICSA’s books, records, accounts and financial statements must be maintained in reasonable detail, must appropriately reflect NICSA’s transactions and must conform both to applicable legal requirements and to NICSA’s system of internal controls.

NICSA’s record retention policy is available from the President.

About this Code

This Code of Business Conduct and Ethics covers a wide range of business activities, practices and procedures. It does not cover every issue that may arise in the course of NICSA’s business, but it sets out basic principles designed to guide staff members, board members and volunteers. All of NICSA’s staff members, board members and volunteers must conduct themselves in accordance with this Code and seek to avoid even the appearance of improper behavior.

If you are in a situation that you believe may violate or lead to a violation of this Code, you should follow the guidelines described in the section titled, “Complying with this Code.” Any staff member who violates the requirements of the Code will be subject to disciplinary action which may include termination of employment.

Waivers of this Code

Any waiver of this Code for board members may be made by NICSA’s Board of Directors or by its Finance Committee. The Finance Committee will promptly report to the full Board on any waivers granted.

Policies that form part of this code.

The following policies are included as part of this code. Click on the links below for more detail about each:


Complying with this Code

We must all work to ensure prompt and consistent action against violations of this Code. However, in some situations it is difficult to know right from wrong. Since we cannot anticipate every situation that will arise, it is important that we have a way to approach a new question or problem. These are the steps to keep in mind:

Make sure you have all the facts. In order to reach the right solutions, we must be as fully informed as possible.

Ask yourself: What specifically am I being asked to do? Does it seem unethical or improper? This will enable you to focus on the specific question you are faced with, and the alternatives you have. Use your judgment and common sense; if something seems unethical or improper, seek guidance before acting.

Discuss the issue with your supervisor or the President. This is the basic guidance for all situations in many cases. Remember that it is their responsibility to help solve problems.

Seek help from the Board of Directors. In the rare case where it may not be appropriate to discuss an issue with your supervisor or the President, or where you do not feel comfortable approaching your supervisor or the President with your question, you should contact the Chair of the Board or another member of the Board of Directors. The names of the Chair and of the other members of the Board of Directors, with their corporate affiliations, are available on the NICSA website.

You may report ethical violations in confidence and without fear or retaliation. If your situation requires that your identity be kept secret, your anonymity will be protected as much as possible, consistent with the need to conduct an adequate investigation and to the extent permitted by law. The Company does not permit retaliation of any kind against employees for good faith reports of ethical violations.


Always ask first, act later. If you are unsure of what to do in any situation, seek guidance before you act.

Annual Distribution and Acknowledgement

This Code will be circulated to all staff members, board members and volunteers annually.

At that time, each NICSA staff member will be annually required to sign a written acknowledgement that s/he has received a copy of this Code, has carefully read the Code and will abide by its terms. A violation of this Code may be cause for significant sanctions, which may include termination of employment.

In accordance with the by-laws, board members will provide an annual statement providing information on the his/her (or his/her employer’s) business involvements with NICSA, their other board memberships and the total amount received by the board member (or his/her employer) from NICSA for services or goods provided.

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