Statement of Ethical Principles of the America for Bulgaria Foundation

This statement sets forth the legal and ethical considerations applicable to the America for Bulgaria Foundation (the “Foundation”) and its directors (including emeriti), officers, employees, consultants and other agents. It also pertains to all parties doing business with the Foundation and entities to which the Foundation makes donations or grants, as well as to 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, and all other countries in which they transact business. They must also conduct their affairs in accordance with the highest ethical principles. 

2.

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

а. Directors, officers, employees, consultants and agents of the Foundation must disclose to their supervisor or to the Foundation 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, including Muzeiko and TSA, directors or employees of the Foundation and its subsidiaries. The officers of the Foundation shall ensure that the grant application form requires such disclosure. 

3.

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

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 EUR 50 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. Directors, officers, employees, consultants and agents of the Foundation who are either offered or receive such gifts must notify the Foundation of the gifts and their rejection or return. 

5.

In matters relating to the Foundation, neither the Foundation nor Third Parties should provide any payment in excess of EUR 100 to government employees of the U.S., Bulgaria, or other countries, without the advance approval of the board of directors or the president of the Foundation.  The EUR 100 limit applies to gifts, gratuities, entertainment, meals and travel (other than reimbursement in respect of services or advice rendered to the Foundation on arms-length terms).

6.

Directors, officers, and employees of the Foundation shall disclose to the Foundation the amount and source of earned income they receive from parties other than the Foundation for any activity related to activities of the Foundation.  This includes speaking fees, honoraria, commissions and all other types of earned sources of income. Such information shall be reported annually to the Board of Directors. 

7.

Whenever a Foundation director, officer or employee or a Third Party is uncertain whether some 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 Chair/Vice-Chair or the Chairman of the Audit Committee of the Foundation.  

8.

Whenever a Foundation director, officer or employee or a Third Party has 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. Alternatively, that person may communicate directly with the Chair of the Foundation’s Audit Committee, Mr. Ken Vander Weele, via email at: [email protected]. Mr. Vander Weele’s alternate is Ms. Gail Buyske Chair of the Foundation at: [email protected]. 

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