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 our own practices.
3	To strive to set the bar higher for standards of integrity, dedication to our discipline, and the professional conduct 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 project and 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 guidance from those who have gone before us.
9	To uphold and support the Ten Principles of the UN Global Compact.

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Supportive Policies

The following policies apply to GPM employees, contingent workers, partners, and third parties acting on GPM’s behalf. They establish the specific behavioral and operational standards that give effect to the commitments in the Code above.

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 where a colleague or a member of their immediate family has a financial, employment, or other relationship that may have an adverse effect on GPM or that may unduly influence the colleague’s independent judgment for reasons of personal gain.

The following activities are considered conflicts of interest and require prior written approval from the President or their designee before proceeding:

Competing, either directly or indirectly, with GPM.

Holding a direct or indirect interest in competitors, suppliers, or customers of GPM beyond non-substantial, passive ownership of securities.

Serving as an employee, consultant, officer, or director of, or receiving income from, any organization that does business with, seeks to do business with, or directly competes with GPM.

Engaging in non-GPM employment or consulting that may conflict with GPM’s business interests or prevent satisfactory performance of responsibilities to GPM.

Accepting gifts or entertainment from a person or organization that does business with GPM, except as permitted under the Gifts and Entertainment policy below.

Trading in the stock of any company or dealing for personal gain on the basis of material, non-public information learned through GPM employment.

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 it, and must comply with this policy. “Gifts and entertainment” means anything of value, including loans, favorable product or service terms, prizes, vehicle use, tickets, gift certificates, vacation facilities, stocks, or other securities. Entertainment is treated as a gift when the giver or their representative will not accompany you to the event.

Acceptable Without Prior Approval

Meals: Modest, occasional meals with business contacts.

Entertainment: Occasional attendance at ordinary sports, theater, and cultural events.

Gifts: Nominal items such as pens, calendars, or small promotional materials.

Never Acceptable

Any gift or entertainment that would be illegal.

Any payment or offer of value to a foreign official, political party, or candidate for foreign political office to induce misuse of their position.

Gifts or entertainment involving parties in a tender or competitive bidding process.

Any gift of cash or cash equivalent (gift certificates, loans, negotiable instruments).

Any gift or entertainment paid for personally to avoid the approval process.

Any entertainment that is indecent, sexually oriented, or likely to adversely affect GPM’s reputation.

Requires Prior Approval

Approval from your manager or a Strategic Leadership Team member is required for:

Entertainment exceeding $150 USD or equivalent per person.

Gifts valued at more than $100 USD or equivalent.

Lavish meals exceeding $150 USD or equivalent per person.

Special events such as major sporting or entertainment events typically valued above $150 USD.

Travel or overnight accommodation.

Entertainment valued above $500 USD or gifts over $250 USD require approval from the GPM President. If a gift exceeding a monetary limit cannot be declined without causing offense, it must be reported to management for a disposition decision. Cash gifts must be returned immediately.

Anti-Corruption

GPM operates under applicable anti-corruption laws including the OECD Convention on Combating Bribery of Foreign Public Officials, 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).

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 to secure an improper business advantage. Soliciting or accepting a bribe is equally prohibited. Colleagues may not knowingly facilitate or assist government officials or private sector clients in violating any law.

Third Party Due Diligence

GPM is legally responsible for corrupt actions by third parties contracted to represent or perform services on its behalf. Due diligence must be conducted before contracting with any third party. GPM’s Due Diligence Questionnaire must be completed and reviewed with the Compliance Director if the third party will join GPM’s Partner Plus Program, serve as a system integrator or contracting partner on a government project or tender, or scores 5 or higher on the Third Party Risk Matrix.

The following characteristics, while not automatically disqualifying, warrant careful scrutiny:

Operating in a high-risk country as defined in the Third Party Risk Matrix.

A reputation for improper, illegal, or unethical conduct.

Refusal to provide requested information during the due diligence process.

Refusal to provide assurances of compliance with anti-corruption laws or to execute a written contract.

Unusually high rates or fees compared to market rates.

Unusual payment requests, including cash payments, advance payments, or deposits to offshore accounts.

Direct family or business ties to a government official or agency.

Large or frequent political contributions.

Suggestions that payments are needed to “get the business.”

Supplier Due Diligence

For direct and indirect suppliers, additional due diligence requirements may apply depending on the type of service or product provided. This may include assessment of information security controls, data privacy protections, and regulatory compliance. An assessment may also be required to determine whether a new third-party service or product is necessary given GPM’s existing business relationships.

Fair Competition

GPM conducts business in compliance with all competition laws. The following are strictly prohibited:

Any agreement or arrangement with a competitor relating to pricing, bids, discounts, terms of sale, costs, or profits. GPM independently determines the prices for its products and services.

Any agreement with a competitor to allocate customers, markets, or control production or availability of products or services.

Any agreement with a competitor to limit business or refrain from doing business with a particular company.

International Trade

Colleagues who arrange, approve, or effect any export or import of products, services, or information must ensure the transaction complies with all applicable legal requirements and that documentation and record-keeping requirements are satisfied. Contact This email address is being protected from spambots. You need JavaScript enabled to view it. for guidance on trade compliance questions.

Antiboycott Laws

GPM complies with laws preventing US companies from being used to implement foreign boycott policies that run counter to US policy. GPM may not refuse to do business with any boycotted country, business, national, or person due to an unsanctioned foreign boycott. US regulations require reporting of any boycott request received, even if GPM does not comply or the request is withdrawn. Any boycott-related request must be reported immediately to This email address is being protected from spambots. You need JavaScript enabled to view it..

Confidential Information and Asset Protection

Colleagues must protect the confidentiality of GPM’s proprietary information and confidential information received from third parties. Confidential information may only be disclosed where there is a clear business need and the recipient has signed an appropriate nondisclosure agreement. All information disclosed under such an agreement must be clearly marked as “confidential.”

GPM confidential information includes any information not intended for public disclosure or that has economic value to GPM, such as:

Business processes, strategies, and product roadmaps.

Financial documents and projections.

Customer lists and personally identifiable information.

Source code and unpublished patent applications.

Project documents and new product or service introduction plans.

Accounting, Reporting, and Auditing Controls

GPM maintains accounting, reporting, and auditing controls to protect its assets and ensure the accuracy of its financial records. All colleagues are responsible for keeping accurate accounts and records, and must:

Not allow the establishment of any undisclosed or unrecorded funds or assets.

Ensure all documentation accurately states the purpose for which funds are disbursed.

Decline to authorize payments with intent or belief that any part will be used for a purpose other than described in supporting documentation.

Follow all generally accepted accounting principles and applicable laws.

Report any accounting or bookkeeping violations immediately upon discovery to This email address is being protected from spambots. You need JavaScript enabled to view it..

Data Privacy

GPM is subject to enhanced requirements for processing personal data under the GDPR and other applicable laws. Personal data is any information that can identify a living individual, directly or indirectly, including names, addresses, identification numbers, location data, online identifiers, and factors specific to an individual’s physical, physiological, genetic, mental, economic, cultural, or social identity.

If you are responsible for developing new GPM products or services, data protection must be considered at the outset of development. Appropriate technical and organizational safeguards must be built in regardless of whether the product is on-premise or cloud-based. Contact This email address is being protected from spambots. You need JavaScript enabled to view it. before engaging any third party that will process personal data on behalf of GPM. A data processing agreement must be in place before any such processing begins.

Full details are set out in the GPM Privacy Policy and GPM Data Protection Policy, both available on gpm.org.

Public Relations and Social Media

GPM has designated spokespeople who may formally represent the Company in the media, with analysts, and on public 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 their employment.

Colleagues are prohibited from posting discriminatory, harassing, or threatening content, or from divulging non-public, sensitive information about GPM that is financial, legal, or operational in nature, or that contains customer or other data governed by GPM’s data protection policies.

Respectful Workplace

GPM is committed to a working environment in which all individuals are treated with respect and dignity. Everyone has the right to a professional atmosphere that promotes equal employment opportunities and prohibits discrimination and harassment. GPM adheres to all applicable labor and employment laws in every country where it operates.

Behaviors that may constitute discrimination include, but are not limited to:

Applying expectations differently among colleagues.

Yielding to internalized stereotypes.

Excluding, interrupting, or providing less support to a colleague, including through non-verbal behaviors.

Engaging in patronizing or paternalistic conduct.

Dismissing the contributions of a colleague.

Workplace Violence

GPM maintains a workplace free from threats and acts of violence. Colleagues, contractors, and vendors are prohibited from making threats or engaging in aggressive or violent activities, including bullying, stalking, intimidation, physical attacks, and property damage. The possession of weapons while conducting Company business or at any Company-sponsored function is strictly prohibited.

Impairment-Free Workplace

GPM prohibits colleagues and contractors from:

The use, possession, solicitation, or sale of illegal drugs, alcohol, or prescription medication without a valid prescription on Company or customer premises or while performing a GPM assignment.

The presence of any detectable amount of prohibited substances while at work, on Company or customer premises, or while on Company business.

Being impaired or under the influence of legal or illegal substances while away from Company premises if it adversely affects work performance, the safety of others, or GPM’s reputation.

Colleagues should report suspected impairment in the workplace. Note that similar signs may result from medical conditions, prescribed medications, psychological factors, or fatigue — report the concern and allow the Company to conduct an independent assessment.

Quality

GPM is committed to high-quality standards for its products and services through a culture of continuous improvement. GPM is audited annually to ISO 9001:2015 standards, and cross-functional teams work continuously to monitor quality indicators and improve operational practices.

Workplace Environmental Health and Safety

Environmental

GPM operates an Environmental Management System (EMS) audited annually to ISO 14001:2015, ensuring adherence to applicable environmental standards and setting goals for continuous environmental improvement.

Health and Safety

All colleagues must be conscious of safety risks and take reasonable steps to mitigate them. Hazards and safety concerns should be reported to managers promptly so GPM can maintain a safe and efficient workplace.

Reporting a Concern

Serious concerns of wrongdoing or danger must be reported. This includes actions that:

Are unlawful.

Are not in line with company policy, including this Code of Ethics.

May lead to incorrect financial reporting.

Otherwise amount to serious improper conduct.

Concerns may be reported directly to management or to GPM at This email address is being protected from spambots. You need JavaScript enabled to view it.. Reports may also be made anonymously through GPM’s confidential reporting channel.

Anti-Retaliation Policy

GPM will not tolerate harassment or victimization of any individual based on knowledge or suspicion that they have reported a concern, whether to GPM directly, to management, or through the confidential reporting channel. If you believe you have been retaliated against for raising a concern in good faith, report it immediately to your manager or to This email address is being protected from spambots. You need JavaScript enabled to view it..

Compliance

Failure to comply with the provisions of this Code of Ethics may result in disciplinary action, up to and including termination of employment or credential revocation, depending on the nature of the violation and the individual’s relationship with GPM.