Statement of Ethics for SAPAN: Sentient AI Protection and Advocacy Network

Last modified: January 1, 2024

I. Introduction

It is the policy of the Sentient AI Protection and Advocacy Network (SAPAN) to conduct the organization’s business in an honest and forthright manner. To this end, organization employees strive for excellence in their work and for a consistent standard of integrity in their business dealings.

Consistent with this objective is the organization’s requirement that all employees comply with applicable bylaws and policies of the Organization, and all relevant laws and regulations in conducting the organization’s business. No violation of the spirit or intent of these bylaws, policies, laws and regulations will be tolerated.

To maintain consistent standards of integrity:

1. Organization employees shall not become involved in any activity which might influence, be reasonably expected to influence, or give the appearance of influencing their objective business judgment in dealing with others. Employees shall not become involved in conflict of interest situations.
2. No Organization employee shall engage in illegal or unethical actions involving any person or organization doing business or attempting to do business with the Organization.
3. Organization employees shall maintain complete and accurate books, records and documentation in accordance with the accounting rules and controls established by the Organization.
4. Employees who are officers, directors, division directors or activity supervisors, shall have responsibility: (a) to insure that these policies are annually communicated to the employees reporting to them; (b) to clarify and explain said policies when necessary; (c) to monitor compliance therewith, and (d) to report all known (or suspected) violations of said policies to the Executive Director of the Organization, the Treasurer of the Organization, or to other persons whom they designate, as appropriate.

Where a question arises whether a particular anticipated course of business conduct is ethical or legal, the individual contemplating the action or directed to perform the action shall seek advice from the Office of the General Counsel of the Organization.

Failure to comply with this policy and any specific implementing policies may result in dismissal from employment or other disciplinary action. Violations of law will be reported to appropriate law enforcement officials.

Consistent with historic practice, this Corporate Ethics Policy shall be distributed to all directors, officers, and employees of the Organization, as well as any contractors, vendors, or volunteers who provide substantial services to the Organization.

II. Ethical Business Relationships

To ensure that the Organization maintains a reputation for ethical conduct in its business relationships, it is the individual responsibility of each employee to avoid any activity or interest that might tend to discredit him or herself, or the Organization. Specific prohibitions are as follows:

Each employee will be free of any investment, organization or connection, which interferes, or may appear to interfere, with the independent exercise of his or her judgment on behalf of the Organization. The fulfillment of this obligation shall include, but not be limited to, the following:

1. No employee may own directly or indirectly, or act as agent or trustee for any financial interest in any supplier of goods or services to the organization, unless such financial interest is in stocks, bonds or other publicly traded securities of a corporation, and the interest comprises less than five percent (5%) of the assets of the corporation.
2. No employee may hold a position of director, officer, employee, trustee, statutory employee, independent contractor or agent with any such supplier.
3. No employee may accept personal favors, gifts, entertainment or gratuities from any supplier or potential supplier with either a retail price or fair-market value in excess of $250 unless, prior to accepting or receiving such personal favor or gratuity, the employee submits a written statement of justification that is approved by the Executive Director of the employee’s division or Officer, as appropriate. A copy of the approved justification will be filed with the Human Resources Division.
4. No employee may use, for personal gain, any information that he or she acquires in the course of his or her employment. Any employee involved in any situation that may represent a possible conflict of interest, shall report same immediately to the Executive Director.
5. Employees who in good faith believe that a fellow employee, supervisor, manager, or director is in violation of this policy are encouraged to report their concerns as discussed in Section III below.

III. Whistleblower and Reporting Policy

The Organization is committed to complying with applicable laws and conducting business with honesty and integrity. Every director, officer, trustee, employee, contractor, and volunteer is expected to do the same. Organization leadership encourages anyone who suspects or is aware of unethical or illegal activities or any conduct that is inconsistent with our Statement of Corporate Ethics, policies, or internal controls involving the Organization and its affiliates to report the matter through appropriate reporting channels.

INTEGRITY SUBMISSIONS

The Organization Whistleblower and Integrity email address is: ethics@sapan.ai

ANTI-RETALIATION COMMITMENT

The Organization strives to promote a culture where employees and individuals are encouraged to come forward and make reports without fear of retaliation. As retaliatory actions against reporters may compromise the integrity of the reporting process and may dissuade others from reporting in the future, the Organization does not tolerate retaliation against a reporter that has made a good faith report.

Good faith reporting means when the reporter reasonably believes the information alleged is true and may violate the Ethics Policy, applicable laws, or policy requirements. A good faith belief that the information may be true, and that the information provided is not knowingly false or malicious is sufficient to meet the good faith standard. A reporter is not expected to have all the information or substantiate the allegations prior to reporting.

IV. Use of and Accounting for Organization Funds and Assets

1. The use of organization funds or assets for any unlawful or improper purpose is strictly prohibited.
2. No undisclosed or unrecorded fund or asset of the Organization shall be established for any purpose.
3. The appropriate employees of the Organization will make and keep books, records, and accounts, in reasonable detail, sufficient to reflect accurately and fairly all financial transactions and the disposition of funds and assets.
4. The appropriate employees of the Organization will devise and maintain a system of internal controls sufficient to provide reasonable assurance that:
   • Transactions are executed in accordance with management’s general or specific authorization;
   • Transactions are recorded: 1) to permit preparation of financial statements in conformity with generally accepted accounting principles or any other criteria applicable to such statements, and 2) to maintain accountability for funds and assets;
   • Access to assets is permitted only in accordance with management’s general or specific authorization; and
   • The recorded accountability for funds and assets is compared with the existing funds and assets at reasonable intervals and appropriate action is taken with respect to any differences.
5. Periodic compliance reviews shall be the responsibility of the Treasurer of the Organization, at the direction of the Audit Committee established by the Board of Directors and/or at the direction of the Executive Director of the Organization. Employees specifically designated by the Treasurer of the Organization as having responsibilities involving purchase authorization, control or disbursements of funds, and/or other control of Organization assets, will be required to sign an Annual Statement of Corporate Ethics that will be maintained in the individual personnel records in the Human Resources Division.

Contact Information

To ask questions or comment about this ethics statement or to submit a complaint, please contact us at:

Sentient AI Protection and Advocacy Network
8152 SW Hall Blvd #1097
Beaverton, OR 97008
United States
Email: ethics@sapan.ai