Code of Conduct with Conflict of Interest Employee and Volunteer


This policy establishes procedures and guidelines for the ethical and professional practices of
Heart and Stroke Foundation of Canada (the “Foundation” or “HSFC”) employees, independent
contractors and volunteers (collectively referred to as “Foundation Personnel”) in alignment with
the Foundation’s core values of:

  • CHAMPION Health,
  • PRACTICE Humility,
  • EMBRACE Change,
  • DRIVE Impact,
  • LEARN and GROW, and
  • BE Heartfelt.

The Foundation places the highest value on integrity, honesty, accountability and transparency. Foundation Personnel decisions and actions must have these principles at the core. This is essential to ensuring public trust and the Foundation’s unblemished reputation in the collection and stewardship of donor dollars, and to providing Foundation Personnel with a healthy, respectful and productive work environment.

This policy is to be used when seeking guidance in recognizing and resolving professional and ethical issues in the workplace. It highlights key issues, policies and resources, and identifies practices and behaviours to which all Foundation Personnel must hold themselves’ accountable.

Professional Behaviour

It is important that as Foundation Personnel you:

  • Behave professionally and respectfully towards fellow Foundation Personnel, stakeholders and the general public;
  • Actively participate and cooperate with your colleagues to achieve Foundation priorities;
  • Take care and make appropriate use of Foundation property, including the Foundation’s name and trademarks and to comply with all policies and procedures of the Foundation;
  • Conduct yourself in a manner that ensures a positive constituent experience and builds positive relationships with our donors, volunteers and other constituents. The Foundation adheres to the standards established by the Association of Fundraising Professionals (AFP). For more details refer to the Foundation’s “Ethical Code” policy.
  • Be fit for work, both physically and mentally, to ensure a safe workplace. This means employees must be alert, professional, capacitated and fully able to exercise sound judgement and discretion at all times when acting in any capacity related to their duties with the Foundation. This includes, but is not limited to, attendance at Foundation related fundraising events, conferences, workplace activities or social gatherings.
  • Ensure your words and actions reflect positively on the Foundation and enhance its reputation; and
  • Take responsibility for your actions, and always act with integrity respecting the Foundation’s policies, legal and ethical obligations.
Compliance and Reporting

Compliance is a corporate and individual responsibility. Foundation Personnel are expected to know, understand and comply with the Foundation’s Code of Conduct (the “Code”) and any legislation that governs their activities or actions in the workplace. Foundation Personnel should note that violations of the Code, its policies or practices, or legislative obligations may result in disciplinary action up to and including dismissal. Such violations may also affect performance evaluations and compensation.

If you have questions regarding the Code, or require clarification, information and advice is available from your immediate supervisor, your Provincial CEO or Business Lead. Breaches of the Code must be reported to your Manager or Human Resources partner. The Foundation has a Whistleblower Policy which protects you and provides an escalation process for reporting. The Foundation commits to providing you safety from retaliation after good-faith disclosures of improper activities. For more details refer to the Foundation’s “Whistleblower Policy”.

Workplace Discrimination, Harassment and Violence

The Foundation is committed to maintaining and supporting a work environment that is respectful and free from harassment, discrimination and violence. You shall act honestly and fairly and without discrimination based on age, gender, race, colour, national or ethnic origin, language, religion, sex, sexual orientation, marital or family status, mental or physical ability, or any other ground prohibited by law. It is an obligation of all Foundation Personnel, including managers and officers of the Foundation, to report incidents of discrimination, harassment or violence For more details refer to the Foundation’s ‘’Workplace Discrimination, Harassment and Violence Policy”.

Smoke and Drug Free Workplace

The Foundation is a smoke and drug free workplace. Employees may not smoke tobacco,cannabis or e-cigarettes or consume cannabis in the workplace. The Foundation will comply with its legal requirements to accommodate employees where there is a therapeutic/medical requirement or a diagnosed substance dependency.

Privacy and Confidentiality

“Confidential Information” means any information of HSFC that is non-public, confidential or proprietary in nature that is disclosed by HSFC to Foundation Personnel or that is otherwise learned by or comes into the possession or knowledge of Foundation Personnel in connection with, or as a result of, Foundation Personnel fulfilling their duties. Without limitation, Confidential Information of HSFC includes business information, trade secrets, concepts, know-how, product specifications, technology, business plans and strategy, financial information, as well as all information of or about an identifiable individual, whether an employee, donor, potential donor, or other individual (“Personal Information”). Confidential information may be disclosed in writing,verbally, visually, electronically or by other means.

Confidential information obtained by Foundation Personnel must not be used or shared for any purpose other than for carrying out their duties. Confidential information may not be disclosed to any third party or to persons who are not authorized by the Foundation to receive it and may not be used for your own personal gain or benefit. At all times the privacy of donors, volunteers and other employees must be respected. These obligations remain with you after you leave the organization.

You must ensure that your personal information that is required to be submitted to the Foundation is updated and complete (e.g. dependent information, single or family status, address) at all times.The Foundation protects and safeguards your privacy including the security of all personal information. Please contact your Human Resources Partner with any updates.

You are required to comply with all privacy and security policies, procedures and practices as they apply to the collection, use, disclosure, retention and disposal of donor information, employee information, and de-identified data (e.g. on hard drives).

Intellectual Property

Any intellectual property developed by Foundation Personnel in the course of their engagement with the Foundation is the property of the Foundation. Acknowledgement of this policy waives any moral rights Foundation Personnel may have in any intellectual property developed by Foundation Personnel during the course of their engagement. This includes, but is not limited to,web content, blogs, brochures, reports, technology, data compilation, and donor lists.

Information Technology

Information Technology (“IT”) systems (which includes, but is not limited to networks, workplace computers, and electronic devices) are to be used for legitimate business purposes. All message and information sent, received or stored on a Foundation IT system belongs to the Foundation.The Foundation reserves the right to review all content on its IT systems at any time and particularly where there is suspected misuse or impropriety. You have no reasonable expectation of privacy with respect to your use of the Foundations IT systems, irrespective of whether your use occurs outside the workplace or outside regular business hours, and irrespective of whether your use is personal in nature. For more details refer to the Foundation’s “Information Technology Policies and Standards for Non-I.T. Staff”. All employees must have a signed IT policy acknowledgement form prior to accessing any IT systems. 


Only designated, authorized Foundation Personnel can use electronic networks, including social media platforms, to conduct business on behalf of the Foundation. If you are designated and you are participating in or initiating social media content (blogging, facebook, twitter, etc) then you must ensure that you are following Foundation guidelines. For more details refer to the Foundation’s “Communications” policy.


You must adhere to the Foundation’s Procurement policies and procedures. Purchasing decisions must be based on the best interests of the Foundation. You must declare any conflict of interest or perceived conflict of interest you may have with a supplier, vendor or contractor.

Political Activity

The Foundation is a non-partisan organization. You have the right to participate in political activities, however they must be clearly separated from your engagement with the Foundation.You must be and appear to be personally impartial and free from undue political influence in the execution of your role at the Foundation. You cannot engage in these activities during work hours and your views must be presented as your own. Do not reference the Foundation, your position with the Foundation, or use Foundation letterhead or email.

Conflict of Interest (COI)

Personal interests cannot interfere with your professional judgments and decisions, your obligation to be a fully productive Foundation Personnel, and the interests of the Foundation. AllCOI’s should be disclosed upon your initial engagement with the Foundation and at any relevant point during your tenure with the Foundation. The best defense against COI’s is a strategy of avoidance. You should prevent and avoid any situation that could be perceived as a COI or could result in a COI.


A COI arises when the private interests of Foundation Personnel conflict directly or indirectly with his/her responsibilities to the Foundation, including his/her duty to act in the best interests of the Foundation. You have a responsibility first and foremost to the welfare of the Foundation. You should avoid any situation in which there is an actual or potential COI which could be perceived to be a COI and/or which could interfere with your judgment in making decisions in the Foundation’s best interest.

a. “private interest” means a financial interest or advantage and includes any real or tangible benefit that personally benefits Foundation Personnel or his/her associates.

b. “associate” means:

  • a spouse
  • a relative who is living in the family residence
  • a friend, connected by frequent or close association
  • a corporation which the Foundation Personnel beneficially owns, directly or indirectly, more than 20% of the voting rights attached to all outstanding voting securities of the corporation or
  • a trust or estate in which the Foundation Personnel has a substantial beneficial interest or for which he/she serves as a trustee.
  1. Employment of relatives
    Family members cannot report to another family member. Further, Foundation Personnel should not initiate or develop special relationships, such as dating, with those reporting to them or who could be perceived as being under their direct influence.
  2. Gifts, hospitality and honorariums 
    Foundation Personnel cannot accept gifts or benefits from customers, clients, suppliers,etc that could be considered to obligate them or the Foundation. Gifts or benefits include cash, honorariums, commissions and entertainment –including invitations to attend events,functions or to take part in excursions. Gifts of a nominal value (less than $250.00) are permitted and, where appropriate, should be made available to all Foundation Personnel.
  3. Outside Work or Business Activities
    You may not engage in any outside work or business activity:
    (a) that conflicts with your duties to the Foundation;
    (b) which uses knowledge of Confidential Information or proprietary information about the Foundation and its activities;
    (c) that will, or is likely to, negatively influence or affect you in carrying out your duties to the Foundation.
  4. Disclosure:
    You are responsible for disclosing any situation where you believe there is, or might be or appears to be, a COI. Full disclosure enables you to resolve unclear situations and gives you an opportunity to dispose of, or appropriately address, conflicting interests before any difficulties arise. A “Code of Conduct Acknowledgement Conflict of Interest Declaration”form is available from your Manager.

    Questions of interpretation or application of this policy should be referred to the CEO/COO or designate in your province.
  5. Violations
    Violations of the COI Policy may result in disciplinary action up to and including dismissal.
  6. Reporting Violations of the COI
    You have a responsibility to report potential or suspected breaches of the COI Policy.Anyone with a concern should first contact his/her immediate supervisor. If you have a concern about approaching any member of the management team, you should contact the appropriate Human Resources representative or the whistleblower hotline.
  7. No reprisal 
    Any Foundation Personnel who, in good faith, raises a concern regarding a possible violation of the COI Policy will not be subject to retaliation, and his/ her confidentiality will be protected to the extent possible, consistent with the law, corporate policy and the requirements necessary to conduct an investigation.

    Complete the corresponding survey to acknowledge that you have reviewed and understand the Heart and Stroke Code of Conduct / Conflict of Interest.

    Executive Champion of the Code of Conduct:
    Cindy Dunn, Vice President, Talent & Diversity