GPM® Code of Ethics 

As GPM staff, Ambassadors, partners, and certificate holders, we recognize the importance of behaving ethically. Our Code of Ethics makes public the values to which we are committed and embodies the responsibilities we promise to uphold.

  1. To decouple social and environmental degradation from economic growth through the advancement of the integration of sustainability and project management.
  2. To promote the Principles of Sustainable Change Delivery through in own practices.
  3. To strive to set the bar higher for standards of integrity, dedication to our discipline, and the professional conduct that is expected of subject matter experts and leaders.
  4. To be transparent in representing our project management experience, abilities, recognition, and areas that are still being developed.
  5. To constantly strive to improve ourselves and acquire new skills in the realm of project/program management and overall leadership.
  6. To serve as role models in our local communities and expand our field of influence to create positive impacts wherever we are.
  7. To treat all persons fairly regardless of their race, religion, gender, disability, age, national origin, or other differences.
  8. To serve as mentors to those who aspire to enter the discipline and to continue to seek from those who have gone before us.
  9. To uphold and support the ten principles of the UN Global Compact.

Supportive Policies

Conflicts of Interest

Those subject to the Code must avoid any situation in which they have, or appear to have, an interest that conflicts with the best interests of GPM. Conflicts of interest can arise in situations where the colleague or a member of the colleague's immediate family have an interest or relationship (financial, employment, or otherwise) that may have an adverse effect on GPM or may unduly influence the colleague's exercise of independent judgment due to considerations of personal gain or benefit.

While it is impossible to list every situation in which an actual or apparent conflict of interest may exist, GPM considers the following activities to be conflicts of interest. As such, colleagues are prohibited from engaging in these activities without receiving prior written approval from the President or their designee:

  • Competing, either directly or indirectly, with GPM.
  • Having an interest, either direct or indirect, in competitors, suppliers, or customers of GPM, other than non-substantial, passive ownership of securities. What constitutes a "substantial" interest will depend on facts such as the size of the entity, whether it is a public or private company, the type and dollar amount of business the entity does with GPM, the nature of its competition with GPM, and the significance of the investment considering the colleague's other financial resources.
  • Serving as a colleague, consultant, officer, or director of, or receiving income from, any person or organization that the colleague knows, or reasonably should know, does business with GPM, seeks to do business with GPM, or directly competes with GPM.
  • Engaging in non-GPM employment or consulting work that may conflict with GPM's business interests or prevent the colleague from satisfactorily performing the colleague's responsibilities to GPM.
  • Accepting gifts or entertainment from a person or organization that does business with GPM or seeks to do business with GPM except as permitted under the section entitled "Gifts and "
  • Trading in the stock of any company or dealing for personal gain on the basis of material, non-public information learned in the course of employment with GPM.
  • Personally exploiting a corporate opportunity or receiving any personal benefit from a business transaction in which GPM engages.

Gifts and Entertainment

The exchange of gifts and entertainment can create improper influence (or the appearance of improper influence) and must be in accordance with this policy.

Gifts and entertainment means anything of value, e.g. loans, favorable terms on a product or service, prizes, use of another company's vehicles, tickets, gift certificates, use of vacation facilities, stocks, other securities or participation in stock offerings. Entertainment is considered a gift, subject to these guidelines, when the giver or representative from the giving organization will not accompany you to the event. Gifts and entertainment between GPM colleagues and others fall into three categories:

Acceptable for self-approval

Some gifts and entertainment are sufficiently modest that they do not require prior approval. Think through the intent (e.g., Is it normal courtesy or to build a business relationship versus influencing the recipient's objectivity in making a business decision?), materiality, frequency and transparency (e.g., Would you be embarrassed if your manager, colleagues or anyone else outside GPM became aware?). The following are usually acceptable without prior approval:

  • Meals: Modest occasional meals with someone with whom we do business.
  • Entertainment: Occasional attendance at ordinary sports, theater and other cultural events.
  • Gifts: Gifts of nominal value such as pens, calendars, or small promotional items.

Never acceptable

Other types of gifts and entertainment are never permissible. They are:

  • Any gift or entertainment that would be illegal.
  • Any payment, offer, or promise to pay, either directly or through an intermediary, money or anything of value, to any foreign official, foreign political party or party official, or any candidate for foreign political office, for the purpose of inducing the recipient to misuse their official position to direct business to the payor or to any other person.
  • Gifts or entertainment involving parties engaged in a tender or competitive bidding process.
  • Any gift of cash or cash equivalent (such as gift certificates or loans).
  • A gift or entertainment that you pay for personally to avoid having to seek approval.
  • Any entertainment that is indecent or sexually-oriented or might otherwise adversely affect GPM's reputation.

May be acceptable with prior approval

For anything that does not fit into the other categories, the gift or entertainment may or may not be permissible. You must get approval from your manager or Strategic Leadership Team member as appropriate for the following:

  • Entertainment that exceeds $150 USD or equivalent
  • Gifts valued at more than $100 USD or equivalent
  • Lavish meals that cost more than $150 USD or equivalent per person
  • Special events such as a World Cup game or major golf tournament (these usually have a value of more than $150 USD)
  • Travel or overnight accommodation, as this normally raises the personal benefit to material levels

Any entertainment valued at more than $500 USD (or gifts over $250 USD) must be approved by the GPM President.

In some departments or regions, more restrictive guidelines or rules on gifts and entertainment may apply. Colleagues must be careful not to accept gifts or entertainment that do not comply with these guidelines or rules.

Other important things to know about gifts and entertainment

It is acceptable to receive a gift that exceeds a designated monetary limit if it would be insulting to decline, but the gift must be reported to management who will decide whether it:

  • May be retained by the recipient
  • Will be retained for the benefit of GPM
  • Will be sold and the money donated to charity
  • Will be returned to the donor

You must immediately return any gift of cash or a cash equivalent such as a bank check, money order, or negotiable instrument.

Anti-Corruption

The nature of GPM's business requires colleagues and third parties with whom we do business to interact regularly with government officials and private sector customers. Applicable anti-corruption laws (e.g., the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions, the US Foreign Corrupt Practices Act (FCPA), the International Travel Act, the UK Bribery Act, and Canada's Corruption of Foreign Public Officials Act (COFPA)) establish certain rules and restrictions on those interactions in all countries where GPM does business.

GPM prohibits paying, offering to pay, promising to pay or authorizing the payment of money or anything of value, directly or indirectly, to any government official or private sector customer in order to secure an improper business advantage. GPM also strictly prohibits any colleague from soliciting or accepting a bribe from any individual or entity as a GPM colleague. International law prohibits all of the above-anti-bribery laws that are not just restricted to offers of improper payment to government officials. Additionally, requests for improper payments are often accompanied by illegal activities such as tax evasion, money laundering or anti-competitive behavior, including, but not limited to, price-fixing, fraud, and bid-rigging. GPM strictly prohibits colleagues from knowingly facilitating or assisting government officials or private sector clients in violating the law.

Third Party Due Diligence

GPM is legally responsible for any corrupt actions by third parties contracted to represent GPM or otherwise perform services on its behalf. As such, GPM must understand the qualifications and associations of its third-party partners to ensure that it only does business with reputable third parties who act with integrity and deliver quality products and services. Prior to contracting with a third party for goods or services, appropriate due diligence must be conducted.

GPM's Due Diligence Questionnaire must be completed prior to contracting and vetted with the Compliance Director if any of the following apply:

  • The third party will join GPM's Partner Plus Program
  • The third party will serve as a system integrator, consortium member or contracting partner on a government or state-owned project or tender
  • The third party scores 5 or higher on the Third Party Risk Matrix in Appendix 1 of the Global Anti-Corruption Policy

Additionally, contracts to retain third parties must contain a contractual commitment to comply with all laws and regulations including, but not limited to, anti-corruption laws such as the US FCPA, the International Travel Act, the UK Bribery Act and Canada's COFPA. 

While the following risk factors do not automatically disqualify a third party from working with GPM, you should carefully consider whether to establish a relationship with a third party that exhibits one or more of the following characteristics as these may be indicative of corrupt behavior:

  • Third party does business in a high-risk country as defined in the Third Party Risk Matrix;
  • Third party has a reputation for improper, illegal, or unethical conduct;
  • Third party refuses to provide requested information during the due diligence process;
  • Third party refuses to provide assurances that it will comply with applicable anti-corruption laws;
  • Third party refuses to execute a written contract;
  • Third party charges a rate or fee that is unusually high compared to market rates;
  • Third party makes unusual payment requests (e.g., requests for cash payments, advance payments, deposits to multiple accounts or deposits to offshore accounts);
  • Third party requests approval or reimbursement of unusual expenditures amounts significantly above budgeted or projected costs or payments in cash;
  • Third party has direct family or business ties to a government official or government agency;
  • Third party makes large and/or frequent political contributions;
  • Third party uses unnecessary third parties, agents or intermediaries; or
  • Third party suggests payments are needed to "get the business."

GPM values its reputation for ethical behavior and recognizes that engaging in bribery or other corrupt behavior would undermine customer and colleague trust. No GPM colleague or third party will ever suffer adverse consequences for refusing to pay a bribe or for refusing to engage in otherwise corrupt behavior, even if GPM loses business as the result of such refusal.

Supplier Due Diligence

For direct and indirect suppliers, additional due diligence requirements may exist. Depending on the type of service or product the third party will provide, due diligence may be required to ascertain whether the third party has adequate information security controls and data privacy protections or to ensure the third party complies with relevant government regulations. An assessment may also be required to determine whether the new third-party service or product is needed as GPM works where possible to leverage existing business relationships.

Fair Competition

GPM is committed to conducting business in compliance with laws governing competition. Violation of these laws may result in civil and criminal liability not just for the Company but also for the individuals involved.

Engaging in any of the following activities is strictly prohibited:

  • Any agreement, understanding, plan or arrangement with a competitor relating to pricing or any matter relating to or affecting pricing or any element of price (e.g., pricing methods or policies, bids, discounts, promotions, terms or conditions of sale (e.g., warranties), costs, and profits). GPM independently determines the prices for its products, and If any confidential information about a competitor's prices is obtained, it should not be used. Additionally, GPM customers who resell GPM's products and services must independently determine the prices they will charge.
  • Any agreement, understanding, plan or arrangement with a competitor to allocate customers or markets or control production or availability of products or services.
  • Any agreement, understanding, plan or arrangement with a competitor to limit business or refrain from doing business with a particular company.

International Trade

GPM colleagues who arrange, approve or effect any export or import of products, services, or information must coordinate with Global Trade Compliance to ensure that the transaction is compliant with all applicable legal requirements, and that all documentation and record-keeping requirements have been satisfied.

Antiboycott Laws

GPM must comply with laws that prevent US companies from being used to implement foreign policies of other nations that run counter to US policy. As a result, GPM is prohibited from refusing or agreeing to refuse to do business with or in a boycotted country, with any business organized under the laws of a boycotted country, with any national or resident of a boycotted country, or with any person who has dealt with a boycotted person or country, when refusal is due to an unsanctioned foreign boycott.

US regulations require that the mere receipt of a boycott request be reported in a timely manner. GPM must report a request even if the Company does not comply with the requested action or the request is withdrawn. If you receive a boycott-related request, immediately contact the Legal Department.

Confidential Information and Asset Protection

GPM colleagues must commit to protecting the confidentiality of the Company's proprietary information as well as confidential information received from third parties. Confidential information is not to be disclosed unless there is a business need to do so and the party who will receive the confidential information has signed an appropriate nondisclosure agreement. All confidential information disclosed under an appropriate nondisclosure agreement must be clearly labeled as "confidential" at the time of disclosure.

Identifying Confidential Information

GPM confidential information is any information that GPM does not wish to have displayed publicly or that the Company has determined has economic value to GPM. Examples include:

  • Business processes
  • Project Documents
  • Financial documents
  • Business strategies
  • New product and service introduction plans
  • Customer lists
  • Personally identifiable information (e.g., credit card numbers, payroll information, driver's license numbers, and passport ids)
  • Source code
  • Unpublished patent applications
  • Product roadmaps and development projects

Colleagues should be careful to protect confidential information in meetings that include individuals outside of GPM, correspondence (including email), telephone calls and at restaurants, trade shows and in other circumstances where third parties could overhear or obtain confidential information.

Accounting, Reporting, and Auditing Controls

GPM maintains an adequate and uniform system of accounting, reporting, and auditing controls in order to protect GPM's assets and ensure the accuracy and reliability of its financial records. GPM's financial reports must reflect a full, fair, accurate, timely and comprehensible disclosure of GPM's financial position and results.

As a result, all colleagues are responsible for keeping accurate accounts, books, ledgers, journals, and records. In addition, colleagues must:

  • Not allow the establishment of any undisclosed or unrecorded funds or assets
  • Ensure that all documentation under which funds are disbursed accurately states the purpose for which the funds are paid and that such documentation is not misleading
  • Decline to authorize the payment of corporate funds with the intent or belief that any part of such payment will be used for any purpose other than that described by the documents supporting such payment
  • Follow all generally accepted accounting principles and all applicable laws and accounting
  • Ensure that all accounting information is both truthful and accurate
  • Report any accounting or bookkeeping violations immediately upon discovery

Data Privacy

As a business and an employer, it is necessary for GPM to process personal data about colleagues, contingent workers, customers, suppliers and other third parties with whom we engage to provide products or services on our behalf. With the introduction of the European General Data Protection Regulation (GDPR) and other applicable laws governing data protection, GPM is subject to enhanced requirements for processing personal data.

Personal data is data relating to a living individual who can be identified (directly or indirectly) from that data (or from that data combined with other information in GPM's possession or available to GPM). Personal data can be factual (e.g., name, address, date of birth) or it can be an opinion about the individual and their actions or behavior (e.g., colleague performance assessment). Personal data can also include identification numbers, location data, online identifiers, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social status of an individual.

Processing describes activities performed with respect to personal data such as collecting, recording, organizing, structuring, storing, adapting, altering, retrieving, consulting, disclosing by transmission, disseminating or otherwise making available, aligning or combining, restricting use, erasing or destroying data. Processing also includes transferring or disclosing personal data to third parties.

If you are responsible for developing new GPM products and service offerings, contact the Legal Department and Information Security to consider what personal data the product or service will process at the outset of development and build in appropriate technical and organizational safeguards regardless of whether the product is on-premise or cloud-based/hosted. Personal data may be processed by the product itself or it may be processed for purposes of providing customer service and support. Not only does GPM comply with its own obligations under existing data privacy laws, but the Company strives to assist its customers in meeting their obligations by designing products and services that make compliance simple.

In addition to GPM's obligations to lawfully process personal data, the Company also has an obligation to ensure that any third parties used to process data on our behalf do so in accordance with our instructions and in compliance with relevant data privacy legislation. Contact Legal if you engage a third party that will process personal data on behalf of GPM. We must ensure (typically through a mutually-agreed upon data processing agreement) that the third party has adequate measures in place to safeguard the personal data we provide to them for processing.

Public Relations and Social Media

GPM appreciates the value of thoughtful engagement with the public. For that reason, GPM has designated spokespeople who may formally represent the Company in the media, with analysts or on social forums.

Colleagues engaging in personal social media or other online activities are responsible for acting professionally and ethically when referring to GPM or information related to employment with the Company. Colleagues are prohibited from posting discriminatory, harassing or threatening content or divulging non-public, sensitive information about the Company that is financial, legal or operational in nature or that contains customer or other information governed by GPM's data protection policies. Colleagues are expected to act responsibly, respectfully and with due care.

Respectful Workplace

GPM is committed to creating and maintaining a quality working environment in which all individuals are treated with respect and dignity. Everyone has the right to work in a professional atmosphere that promotes equal employment opportunities and prohibits discrimination and harassment. GPM strictly adheres to all applicable labor and employment laws in every country in which we operate.

Even minor, unintentional inequities can, if they become a pattern of behavior, have a negative effect on workplace culture. Be mindful of behavior that may constitute discrimination including, but not limited to, the following:

  • Applying expectations differently amongst colleagues
  • Yielding to internalized stereotypes
  • Excluding a colleague, interrupting them, or providing them with less support (including, but not limited to, non­ verbal behaviors)
  • Engaging in patronizing or paternalistic conduct
  • Dismissing the contributions of a colleague

GPM strives to provide an inclusive environment where colleagues feel appreciated for their unique characteristics and are comfortable sharing their ideas and authentic selves. Our diversity and inclusion program is aimed at celebrating, educating, and empowering all colleagues and cultures we represent.

Workplace Violence

It is GPM's policy and the responsibility of every colleague to maintain a safe workplace free from threats and acts of violence. Colleagues, contractors, and vendors associated with GPM are prohibited from making threats or engaging in aggressive or violent activities. This includes, but is not limited to, bullying behavior that undermines, patronizes, humiliates, intimidates, or demeans the recipient; stalking in person, in writing, by telephone or in electronic format; making threats; or engaging in physical attacks or property damage. The possession of weapons in the workplace while conducting Company business or at any Company-sponsored function is strictly prohibited.

Impairment-Free Workplace

GPM is committed to providing a safe and drug-free work environment for our customers and colleagues. With this goal in mind, the Company explicitly prohibits colleagues and contractors from:

  • The use, possession, solicitation of, or sale of narcotics or other illegal drugs, alcohol, or prescription medication without a prescription on Company or customer premises or while performing a GPM assignment.
  • The presence of any detectable amount of prohibited substances in the employee's system while at work, while on the premises of the Company or its customers, or while on Company business. "Prohibited substances" include illegal drugs, alcohol, or prescription drugs not taken in accordance with a prescription given to the employee.
  • Possession, use, solicitation of, or sale of legal or illegal drugs or alcohol, or being impaired or under the influence of legal or illegal drugs or alcohol while away from Company or customer premises, if such activity or involvement adversely affects the colleague's work performance, the safety of the colleague or of others, or puts at risk the Company's reputation.

Colleagues are expected to report unsafe working conditions, including any suspicions that a colleague may be impaired in the workplace. Be aware that what looks like impairment may also be due to medical conditions (e.g., diabetes, epilepsy, or a stroke), the use of medications taken as prescribed, psychological factors, and/or fatigue which is why it is important to report your concern and allow the Company to conduct an independent investigation. 

Quality

GPM is committed to maintaining high-quality standards for our products and services. This is achieved through a culture of continuous improvement and identifying and implementing effective practices and processes to provide products and services that support customer and shareholder objectives.

In support of that effort, GPM has audited annually to International Standard ISO 9001:2015 standards. In addition, cross-functional teams work continuously through efforts such as the D5 development process, assessment and control of the supplier base, manufacturing control processes, and customer feedback loops to ensure GPM can monitor relevant components of Quality and continue to improve the way we do business.

Workplace Environmental Health and Safety

Environmental

GPM is committed to being an outstanding corporate citizen and to minimizing the impact of our business, products, and services on the environment. GPM accomplishes this through operation of an Environmental Management System (EMS) that is audited annually to International Standard ISO 14001:2015. This ISO standard sets forth the elements of an organizational structure that ensures adherence to applicable environmental standards and regulations as well as monitors and sets goals for continuous improvement.

Health and Safety

At GPM, Safety is a high priority. For the well-being of each individual and the organization, all colleagues must be conscious of safety risks and take reasonable steps to mitigate those risks where possible. Maintaining a culture of safety requires a team effort to identify and correct unsafe conditions. Colleagues are encouraged to report hazards and safety concerns to their managers so that GPM can continue to build and maintain a safe and efficient workplace.

Reporting a Concern

GPM is committed to the highest possible standards of ethical, moral and legal business conduct. In conjunction with this commitment, you must report serious concerns of wrongdoing or danger in relation to business activities that could have a large impact on the Company, such as actions that:

  • Are unlawful
  • Are not in line with company policy, including the Code of Ethics
  • May lead to incorrect financial reporting
  • Otherwise amount to serious improper

Anti-Retaliation Policy

GPM will not tolerate harassment or victimization of an individual based on knowledge or suspicion that the individual has reported a concern either through the Ethics Hotline or directly to management, Legal or Human Resources. If you feel that you have been retaliated against for raising a complaint in good faith, you should immediately notify your manager or Human Resources.

Compliance

Failure to comply with the provisions of this Code of Ethics may result in disciplinary action, up to and including termination.

Conclusion

Thank you for everything you do to ensure we remain a trusted partner to our customers and to one another. If you have questions about the Code of Ethics, please email us at This email address is being protected from spambots. You need JavaScript enabled to view it.