www.sechistorical.org

Code of Ethics

Approved by the Board of Trustees: January 12, 2005

Please click here to submit any legal or ethical concerns or questions about the Society. All submissions will be held in confidence.

Mission

The Securities and Exchange Commission Historical Society, through its virtual museum and archive at www.sechistorical.org, shares, preserves and advances knowledge of the history of financial regulation.  The Society is a 501(c)(3) non-profit organization, independent of the U.S. Securities and Exchange Commission.

Introduction

The following code of ethics states the Securities and Exchange Commission Historical Society's policies and procedures for maintaining the integrity of the organization. The objectives of this document are to provide a clear and concise set of statements on ethical policy and to set the standards of conduct which the Society expects from the Board of Trustees, its officers, volunteers working for the Society, its staff, and others. This document sets minimum standards of conduct and performance. At the same time, it also provides a clear statement of what the public may justifiably expect.

Ethical Principles

Maintaining the trust and confidence of all those with whom the Securities and Exchange Commission Historical Society comes into contact is critical to the Society's success. That trust and confidence depends on the Society's reputation for acting ethically and with integrity. Therefore, the Society, its trustees, officers, volunteers and staff shall strive at all time to avoid acting in such a way as would, accidentally or otherwise, tarnish the Society's image and reputation. Specifically, they will:

• discharge the functions of the Society according to the law.
• act with honesty and integrity.
• be inclusive, making every attempt for the Board of Trustees, volunteers, staff and donors to reflect diversity.
• give due recognition to those who have contributed to Society undertakings.
• be impartial, ensuring that they declare and make known personal interests and do not give or receive any inducement which could be seen to conflict with the interests of the Society.
• hold the collections, assets and information of the Society in public trust, using them efficiently and effectively and only in the furtherance of the interests of the Society.
• be objective in presenting the collections and the programs.

Board of Trustees

The primary responsibility for governance, institutional policies, financial stability, and legal accountability of the Securities and Exchange Commission Historical Society rests with the Board of Trustees. The officers and staff are responsible for executing the policies within the parameters set by the Trustees.

Each member of the Board of Trustees:

• must be committed to the Society, and must devote time and attention to the affairs of the institution, to ensure that the Society and the Board act in accordance with the basic governing documents and with applicable law.
• must maintain in confidence information gathered during the course of his/her Society activities when that information concerns the administration or activities of the Society and is not generally available to the public.
• must endeavor to conduct all of his/her activities, including those relating to persons closely associated with him/her and to business or other organizations, in such a way that no conflict will arise between the other interests and the policies, operations, or interests of the Society. The appearance of such conflicts should also be avoided.
• at no time should knowingly misrepresent the mission, objectives, policies, programs, proceedings or motives of the Society.
• must not take advantage of privileged information obtained as a result of their position, or permit others to make use of information otherwise unavailable to the public, for furthering personal interest or gain.

The Board of Trustees as a body:

• is obligated to develop and define the purpose and related policies of the Society.
• holds fiduciary responsibility for the Society, and must ensure that all of the Society's assets are properly and effectively used for public purposes.
• is responsible for the selection and continuing oversight of the Society's chief administrator. The Board of Trustees has an obligation to define the rights, powers and duties of the chief administrator, and should work with this individual in all administrative matters and deal with him/her openly and with candor.

Society Staff

The chief administrator has an obligation to bring before the Board of Trustees and its officers any matters involving policy questions not already determined; and to keep them informed on a timely basis about all other significant or substantial matters, or intended actions affecting the Society.

The chief administrator must carry out the policies established by the Board of Trustees, and adhere to the budget approved by the board. Whenever it is necessary to deviate from established policies or to alter or exceed budget guidelines, he/she should notify the Board in advance and request appropriate approval.

Staff members should communicate with the Board of Trustees through the chief administrator or with his/her knowledge, but a procedure will be in place to allow staff to bring matters or concerns directly to the Board of Trustees.

All Society staff members:

• should represent the mission, objectives, policies, programs and proceedings of the Society in accordance with the direction set by the Board of Trustees.
• owe their primary professional allegiance to the Society. The collections and work of the Society belong to the Society and should primarily be applied in furtherance of its interests. If staff wishes to use the Society's intellectual property for purposes which are not primarily in the furtherance of the Society's interest, then they must first obtain written permission from the Board of Trustees to do so.
• must not take advantage of privileged information obtained as a result of their position, or permit others to make use of information otherwise unavailable to the public, for furthering personal interest or gain.
• must avoid the appearance of unethical or compromising practices in relationships with vendors, contractors and other businesses.
• may serve on boards, commissions or conferences in their professional capacity, so long as the activity does not interfere with their obligations to the Society and is disclosed in writing to the President.

Fundraising

The Society will be truthful in all solicitation information or materials distributed to current and prospective donors, and will inform current and prospective donors of the way in which gifts will be used.

When seeking to raise funds, the Board of Trustees, officers, other volunteer leaders and staff will exercise care not to enter into any obligation with donors which would be seen to be partial to the interests of the donor, but in conflict with any Society policy, priority or objective, or otherwise adversely affect the wider interests of the Society.

All gifts and grants accepted by the Society with restrictions placed by the donor, or gifts and grants designated by the Society for specific purposes, will be expended in accordance with the restrictions or designations.

Privacy concerns of individual and institutional donors will be respected.

Access to the Society's most recent financial statements and annual reports will be made available to current and prospective donors.

Stewardship

The Society will manage funds prudently and responsibly. All financial reports will be factually accurate and complete in all material respects.

The Society will ensure that all spending practices and policies are fair, reasonable and appropriate to fulfilling the mission of the organization. A reasonable percentage of the Society's annual budget will be spent on programs in pursuance of the mission. An appropriate amount will be spent on administrative expenses to ensure effective accounting systems, internal controls, competent staff and other expenditures critical to professional management.

Collections

The collections of the virtual museum and archive will be intellectually responsible, founded on scholarship and consistent with current knowledge. The stewardship of the collections entails the highest public trust and carries with it the presumption of rightful ownership, permanence, care, documentation, accessibility, and responsible disposal.

The Society must:

• ensure that the collections promote the mission of the Society, and must not be self-serving or used for individual financial or intellectual gain.
• weigh carefully the interests of the public, for whom it holds the collections in trust; the donor's intent; and the Society's mission in determining which materials are added to or removed from the collections.
• ensure that the collections are secure and preserved, and that access to the collections is free and available 24/7 on all operating platforms.
• provide documentation and provenance for all materials in the collections.

Programs

The programs of the Society must advance the Society's mission, and be responsive to the interests, needs and concerns of its members, museum visitors, and the public. Programs will be intellectually responsible, founded on scholarship and consistent with current knowledge. Programs will be accessible to and encourage participation of the widest possible audience consistent with the Society's mission and resources.

Programs will promote the public good rather than individual financial gain. Any sponsored programs or revenue-producing programs will be compatible with the mission of the Society.

Relationship of the Securities and Exchange Commission Historical Society and the U.S. Securities and Exchange Commission

The Securities and Exchange Commission Historical Society is independent of and separate from the U.S. Securities and Exchange Commission.

The Society will work to develop and maintain relationships with the Commission and SEC staff, and will encourage Commission and SEC staff involvement as volunteers, as Society donors, as museum visitors and as program audience.

All Society activities and programs done in conjunction with the SEC will be conducted by the Society with respect for the SEC's mandate, as an agency of the U.S. government, to promote impartiality, cultural diversity and accessibility. Society activities and programs done in conjunction with the SEC will not be conducted to promote the interests of any institution or individual.