Introduction
This Code of Conduct Policy was last modified on [June 1, 2023]
Every director, officer, employee, ambassador, volunteer, contractor and consultant of Operation
Eyesight Canada Inc. and the following organizations – Operation Eyesight Universal India Liaison Office,
Operation Eyesight East Africa (Kenya), Operation Eyesight Universal (USA), Operation Eyesight Zambia
and Operation Eyesight Ghana (hereinafter referred to as “Operation Eyesight”) - occupies a position of
trust.
Each individual that performs work on behalf of Operation Eyesight, including directors, officers,
employees, ambassadors, volunteers, contractors and consultants, will hereinafter be referred to as
“Representative(s)”.
In varying measures, such Representatives represent Operation Eyesight in their relations with others,
whether with customers, patients, donors, suppliers, partners, employees, volunteers, members,
nongovernment organizations, governments or the general public.
Whatever the area of activity and whatever the degree of responsibility, everyone is expected to act in a
manner that willenhance Operation Eyesight’s reputation for honesty, transparency, integrity,the respect
of the Human Rights of others and the faithful performance of undertakings and obligations.
Every Representative of Operation Eyesight has the responsibility to obey the law and act ethically. To
that end, this Code of Conduct (“Code”) is a guide that is intended to sensitize such individuals to
significant legal and ethical issues that arise frequently and to the mechanisms available to report illegal
or unethical conduct. It is not, however, a comprehensive document that addresses every legal or ethical
issue that a Representative may confront, nor is it a summary of all laws and policies that may apply.
Ultimately, no code of conduct can replace the thoughtful behaviour of an ethical person.
If you have any questions about this Code, or are unclear about a particular course of action, you
should consult your manager, the HR Manager or the Executive Director.
If you are concerned about conduct you believe violates the Code, any Operation Eyesight policies or the
law, contact the Chair of the Governance Committee of Operation Eyesight Canada Inc. You can also use
the Whistleblower Policy to make a complaint or raise a concern.
Scope
This Code applies to each Representative of Operation Eyesight
The provisions of this Code, as set forth, are mandatory and full compliance is expected under all
circumstances.
This Code affirms the commitment of Operation Eyesight to uphold the highest ethical standards, to
respect the Human Rights of others as set out in the United Nations Declaration of Human Rights and the
United Nation Convention on Children and to set the basic norms of behaviour for all Representatives in
their Operation Eyesight activities and in their personal lives.
Failure to comply with this Code can have severe consequences. Conduct that violates this Code may
violate federal, provincial or municipal law and can subject Operation Eyesight and its Representatives to
prosecution and legal sanctions. Offenders will be appropriately disciplined, up to and including
termination of employment or contract
I. Compliance with the Law
Operation Eyesight and its Representatives shall comply with all lawful requirements, both domestically
and foreign, applicable to the activities of Operation Eyesight.
Wherever there is doubt about the application or interpretation of any legal requirement, the
Representative should seek the advice of their manager, the HR Manager or the Executive Director.
Ignorance of the law is not, in general, a defense should such laws be contravened.
Accordingly, every Representative must ensure that they are aware of, and that their conduct cannot be
interpreted as being in contravention of, the laws governing the affairs of Operation Eyesight in the
jurisdictions where Operation Eyesight carries on activities.
II. Gifts and Entertainment
Representatives shall not furnish, directly or indirectly, on behalf of Operation Eyesight, expensive gifts or
provide excessive entertainment or benefits to other persons.
Those Representatives whose duties permit them to do so, may furnish modest gifts, favors and
entertainment to persons, other than public officials, if the following tests are met:
they are not in cash or other negotiable instruments;
they cannot reasonably be interpreted as an improper payment or inducement and are of
modest value;
they are made as a matter of general and accepted business practice;
they do not contravene any law and in addition are made in accordance with generally accepted
local business practices; and
if subsequently disclosed to the public, their provision would not in any way embarrass
Operation Eyesight or the recipients.
III. Personal Gain
Representatives shall not use their position with Operation Eyesight to obtain personal gain or advantage
from those dealing with or seeking to deal with Operation Eyesight.
Except as hereinafter provided, Representatives should neither seek nor accept gifts, payments, services,
fees, special privileges, vacations, accommodations or loans from any person (except, in the case of loans,
from persons in the business of lending and then only on conventional terms) or from any organization or
group that does or is seeking to deal with Operation Eyesight
However, Representatives may accept modest gifts, favors or entertainment provided that in so doing,
standards consistent with the tests relating to the furnishing of gifts as set out in Section II are met and
do not violate the applicable policies of Operation Eyesight.
IV. Dealings with Public Officials
All dealings between the Representatives of Operation Eyesight and public officials are to be conducted
in a manner that will not compromise the integrity or impugn the reputation of any public official or
Operation Eyesight.
Even the appearance of impropriety in dealing with public officials is improper and unacceptable. Any
participation, whether directly or indirectly, in any improper profit sharing arrangement, illegal gratuities,
indirect contributions, improper inducements or similar payments is not permitted, notwithstanding that
they might further the interests of Operation Eyesight.
Maintenance of a high standard of integrity is of the utmost importance to Operation Eyesight.
V. Political Contributions
The use of any funds, goods or services of Operation Eyesight as contributions to political parties,
candidates or campaigns is not permitted.
Contributions include money or anything having value, such as loans, services, excessive entertainment,
trips and the use of facilities or assets of Operation Eyesight. Further, no director, officer, employee or
volunteer is to be reimbursed for any contributions that he or she might make.
Operation Eyesight encourages political activity and political involvement by individuals acting on their
own behalf, but not as representatives or agents of Operation Eyesight.
VI. Conflict of Interest
Representatives must avoid all situations in which their personal interests conflict with or might conflict
with their duties to Operation Eyesight.
Such individuals should seek to avoid acquiring any interests or participating in any activities that tend to:
deprive Operation Eyesight of the time or attention required to perform their duties properly; or
create an obligation or distraction that would affect their judgment or ability to act in the best
interest of Operation Eyesight.
Representatives of Operation Eyesight are prohibited from:
taking for themselves personal opportunities that properly belong to Operation Eyesight;
using Operation Eyesight property, information or position for personal gain; and
competing with Operation Eyesight.
All Representatives owe a duty to advance the legitimate interests of Operation Eyesight when the
opportunity to do so arises.
VIII. Recording of Transactions and Disclosure of Funds and Assets
Representatives must protect the assets of Operation Eyesight and ensure their efficient use.
Theft, fraud, carelessness and waste have a direct impact on profitability and are unacceptable. All assets
of Operation Eyesight should be used only for legitimate business purposes. Any misuse or infringement
of assets of Operation Eyesight should be reported to your manager, the HR Manager or the Executive
Director.
The books and records of Operation Eyesight must fully and fairly disclosed, in an accurate, timely and
understandable manner, all transactions and dispositions of the assets of Operation Eyesight.
Representatives must document and record all transactions in accordance with the Company’s internal
control procedures and in compliance with all applicable accounting principles, laws, rules and regulations.
Under no circumstances should a Representative create misleading records or falsify documents.
All funds and assets are to be recorded and disclosed.
The use of the funds or assets of Operation Eyesight for any unlawful or improper purpose (including for
unauthorized personal gain) is strictly prohibited, and those responsible for accounting and recordkeeping
functions are expected to be vigilant regarding the financial records of Operation Eyesight.
IX. Respectful Work Environment and Child Protection
Operation Eyesight and its Representatives, collectively and individually, commit to providing a physically
and psychologically safe work environment free of discrimination and harassment, and in which
individuals are accorded equality of opportunity based upon merit and ability.
Operation Eyesight and its Representatives, collectively and individually, commit to creating and
maintaining a safe environment for the children with whom each Representative interacts. The child’s
welfare is most important and reasonable steps must be taken to prevent them from being harmed.
Operation Eyesight will not tolerate any Representative to knowingly engage in, or support, any type of
child abuse.
Discriminatory or harassing behaviours based on any protected ground – race, place of origin, colour,
mental or physical disability, family or marital status, age, sexual orientation, ancestry, religious beliefs,
gender, gender identity, gender expression or source of income – will not be tolerated.
Discrimination, harassment, sexual harassment or bullying will not be tolerated within Operation Eyesight
and any complaint of discrimination, harassment, sexual harassment or bullying will be taken seriously
and will be investigated. All Representatives are entitled to a workplace free from discrimination,
harassment, sexual harassment or bullying, understanding that proper management of employees is not
bullying or harassment.
Operation Eyesight is committed to the United Nations Declaration of Human Rights and the United
Nations Convention on Children and expects adherence to those principles by each Representative of
Operation Eyesight.
It is not a discriminatory practice to make a distinction between persons based on bona fide occupational
requirements. Such distinctions should not be undertaken without first obtaining express authorization
from your manager, the HR Manager or the Executive Director.
It is the responsibility of all individuals to contribute to a work atmosphere that protects the children that
we work with and is free from harassing, bullying, abusive, disrespectful, disorderly, and disruptive
behaviour or other unprofessional conduct.
X. Health and Safety
Operation Eyesight is committed to providing its Representatives with a safe and secure workplace that
meets or exceeds the laws and requirements with respect to occupational health and safety.
Management is responsible for eliminating physical and psychological safety hazards from the workplace
and training employees to work safely.
In turn, all Representatives are expected to do their part to promote a safe work environment by
complying with safe work procedures, complying with all applicable health and safety laws and
requirements, reporting unsafe conditions to their manager, and taking steps to protect themselves and
others from dangerous conditions.
All Representatives shall report to work, and remain at work, fit for duty and not impaired by alcohol or
drugs or any medication that may impact their ability to work safely
All Representatives agree to comply with any Security Plan issued by Operation Eyesight.
XI. Protection of People
Operation Eyesight recognizes our obligation and responsibility to operate in a manner consistent with
the principles of human rights and we are committed to the prevention of and response to sexual
exploitation and abuse.
Operation Eyesight will not tolerate sexually abusive or exploitative acts committed in any of the areas
that we work in by our Representatives or anyone else associated with our organization or the delivery of
our programs. All Representatives are bound to uphold this policy and to report people or incidents that
they believe are in contravention of this clause or any other area of the Code of Conduct.
XII. Protection of the Environment
Representatives shall treat the protection of the environment as an integral factor in all decision making.
XIII. Computing Technology
Operation Eyesight provides computer hardware, software, internet, email and external data
communications to their Representatives and in turn, the Representatives must exercise the same
discretion as when using other business tools such as office telephones and facilities.
Users are expected to efficiently and securely utilize these tools only for Operation Eyesight business
purposes, while protecting corporate data and information and exercising appropriate business conduct
at all times.
Operation Eyesight computing technology is for business purposes, and personal commercial use is not
allowed. Users will not create or transmit any unsolicited commercial, advertising or recreational
material, or use any system resources for political activities or to advance the commercial interests of any
party other than Operation Eyesight.
Operation Eyesight’s computers and Internet connections are intended to be used for business purposes.
Users will not create, access or transmit any material, data, text, audio, images, or material that is capable
of being converted, which is offensive, obscene, indecent, libelous, slanderous, harassing, annoying or
defamatory. Users are expected to discourage others from transmitting such information to their Internet
address. Users must comply with all laws including those with respect to all forms of intellectual property
rights, trademarks, copyrights, criminal activity and harassment.
XIV. Improper Influence on Conduct of Audits
No Representative shall fraudulently influence, coerce, manipulate or mislead any internal auditor or
independent public or certified accountant engaged in the performance of an audit of the financial
statements of Operation Eyesight for the purpose of rendering such financial statements materially
misleading.
XV. Duty to Report
Every Representative has a duty to adhere to this Code and all applicable policies.
In most cases, your manager is the best person to address questions or concerns. However, if you are
not comfortable speaking to your manager or you are not satisfied with the response, you are
encouraged to speak to the HR Manager or the Executive Director.
Any Representative may report questionable accounting or auditing matters on an anonymous basis by
submitting a written complaint to the Chair of the Audit and Finance Committee on Operation Eyesight’s
Board of Directors
All other complaints should be brought forward, in person or anonymously, to the Chair of the
Governance Committee of Operation Eyesight Canada Inc., who has the responsibility to investigate all
reported violations or suspected violations.
Once a complaint has been received, Operation Eyesight will activate a prompt, thorough and
confidential investigation that treats all parties with respect and fairness, in line with agreed-to
investigation processes.
Operation Eyesight will not permit any form of intimidation, retaliation, harassment or retribution against
an individual who has truthfully and in good faith:
reported violations in accordance with this section;
lawfully provided information or assistance in an investigation regarding any conduct which the
individual reasonably believes constitutes a violation of applicable laws when the information or
assistance is conducted by a regulatory or law enforcement agency or a person with management
authority over employees or other persons working for Operation Eyesight with authority to
investigate, discover or terminate for misconduct;
filed, caused to be filed, testified, participated in or otherwise assisted in a proceeding related to
a violation of applicable laws; or
provided a law enforcement officer with truthful information regarding the commission or
possible commission of an offence,
unless the individual reporting is one of the violators.
