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Our Code
of Ethics



This statement sets forth the legal and ethical considerations applicable to the AMERICA FOR BULGARIA FOUNDATION and its directors, officers, employees, consultants and other agents (the 'Foundation'), and all parties doing business with the Foundation or its entities to which the Foundation makes donations or grants, and other third parties doing business with the Foundation ('Third Parties').

1.

It is the responsibility of the Foundation and Third Parties to comply with all applicable laws of the United States, the Republic of Bulgaria ('Bulgaria'), and all other countries in which they transact business and to conduct their affairs in accordance with the highest ethical principles.


2.

In all matters concerning the Foundation, the Foundation and all Third Parties should avoid both actual conflicts of interest and the appearance of impropriety.

а. All employees of the Foundation should disclose to their supervisor any interest that they may have in any grant, financial support or other transaction, or in any grant applicant or recipient, considered by the Foundation and should not participate in decision making with respect to that transaction.

b. Directors, officers, and employees of the Foundation shall not participate in any decision making of the Foundation with respect to any grant, financial support or other transaction with any person, donee, grant applicant or recipient or business entity with whom the director, officer or employee is negotiating or has any arrangement concerning prospective employment.

c. Grant applicants to the Foundation shall be required to disclose to the Foundation any relationships with the Foundation and its affiliates, directors or employees, and the officers of the Foundation shall ensure that the form of grant application requires such disclosure.


3.

The Foundation and all Third Parties should not use, for financial or other advantage, confidential information to which they have access by virtue of their positions in or relationships with the Foundation.


4.

It is the policy of the Foundation that neither it nor any of its directors, officers, employees, consultants and agents shall accept any gratuities, gifts, or other things that exceed nominal value from any party having or seeking to have a business or donative relationship with the Foundation. Gifts received that are unacceptable under the policy must be returned to donors. In any event, directors, officers, employees, consultants and agents of the Foundation who are either offered or receive such gifts should notify the Foundation of the gifts and their return.


5.

Neither the Foundation nor Third Parties, in matters relating to the Foundation, should, without the advance approval of the board of directors or the president of the Foundation, provide any payment in excess of EUR 100, including gifts, gratuities, entertainment, meals or travel (other than reimbursement in respect of services or advice rendered to the Foundation on arms-length terms), to government employees in the United States, Bulgaria and other countries at national, state or local levels.


6.

All employees of the Foundation shall disclose to the Foundation the amount and source of earned income they receive from parties other than the Foundation (including speaking fees, honoraria, commissions and all other types of earned sources of income) for any activity of such party related to activities of the Foundation or any activity of such party that is similar in nature to the activities of the Foundation.


7.

Whenever a Foundation director, officer or employee or a Third Party is uncertain whether its conduct would be illegal or inappropriate, would give rise to a conflict of interest or would otherwise raise questions of impropriety or the appearance thereof, that person should consult with the president of the Foundation.


8.

Whenever a Foundation director, officer or employee or a Third Party has ethics concerns regarding possible violations of the Foundation's ethical principles, violations of law or regulations, accounting and auditing issues, fraud or other corporate misconduct, that person should consult with the president of the Foundation, or, alternatively, that person may communicate directly with the Chairman of the Foundation's Audit Committee, Mr. Chris Matlon, via email at: cmatlon@us4bg.org. Mr. Matlon's alternate is Mr. Lynn Daft, also a member of the Audit Committee, at: ldaft@us4.bg.org.


All communications of ethics concerns will be treated as confidential and will be promptly addressed.

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