Code of Conduct

PORT OF SEATTLECODE OF ETHICS& WORKPLACE CONDUCT

CONTENTS 04 05MESSAGE FROM THE CEO 06ONE PORT 07 Serving the Public 08 Pursuing a Common Mission Honoring Shared Values 10 OUR CORE VALUES 12MAKE GOOD DECISIONS 13 Taking Time to Stop, Think & Ask 14FOLLOW THIS CODE 15 Understanding Employees’ Obligation to Comply Application to Represented Employees Expectations of Managers and SupervisorsBE ACCOUNTABLE Speaking Up Reporting Code Violations Commitment to Non-RetaliationBE HONEST Being Open and Truthful Keeping Accurate and Complete Records Duty to Report FraudREPORT LOST OR STOLEN PORT PROPERTY Duty to Report Theft Duty to Report LossesAN EQUAL OPPORTUNITY WORKPLACE Commitment to Non-Discrimination Accommodating Individuals with DisabilitiesWORKPLACE FREE OF ALCOHOL,ILLEGAL DRUGS & VIOLENCE

APPENDIX 16 What to Expect When Reporting a Code of Conduct Violation Intake 18 Review 19 Investigation Post-Investigation Confidentiality INVESTIGATION PROCESS PORT OF SEATTLE CODE OF ETHICS & WORKPLACE CONDUCT POLICIES 05WORKPLACE CODE OF CONDUCT

MESSAGE FROM THE CEO TED J. FICK December 1, 2015 I hope you feel as I do, that it is an honor and a privilege to serve the public as an employee at the Port of Seattle. Our Code of Ethics & Workplace Conduct expresses our organization’s core values, and contains policies that guide how we carry out the Port’s mission on behalf of King County residents. The mission, established in 1911, is to generate economic development, facilitate trade, and develop transportation infrastructure in the Puget Sound region. As employees of a public agency, we are expected to accomplish the Port’s mission with transparency and openness. In this, we are guided by our core values that call us to: • Conduct business with the highest ethical standards • Honor our commitments within the organization and to our customers • Embrace the richness of a diverse workplace and support employee development • Protect community resources and the environment We can continue to earn and maintain the public’s trust by carrying out Port busi- ness on the solid foundation of ethical, open, and respectful behavior that is expressed in the Code. To make sure we all follow the spirit and letter of the Code, we first need to read it and become familiar with the contents. If you have a question, feel free to ask the Workplace Responsibility Office staff for details on Code requirements. There also will be training, guidance, and coaching avail- able to help us learn how to incorporate the Code’s provisions into our daily responsibilities. Please be aware that each of us is required to report any Code violation that could result in fraud, loss of public funds, or electronic systems violations. Managers have even more responsibility in this regard, and are expected to contact the Workplace Responsibility Office about any Code violation reports. I am confident that by living the values in our Code, we can help assure the Port of Seattle continues to be a successful agency with a motivated workforce, and a source of pride for all of us and the communities we serve. 0504 THEODORE J. FICK Chief Executive OfficerWCOODREKOPFLAETCHEICCSO&DWEOORKFPCLAOCNEDCUONCDTUCT ETHICS & COMPLIANCE HOTLINE: 1.877.571.5237

Port of Seattle WE ARE ONE PORTStatement of Values SERVING THE PUBLICThe Port’s ethical values were devel-oped by Port employees to guide Port employees are public servants entrusted to act on behalf of and for theand shape the Port’s philosophy and benefit of the community. As public servants, Port employees work every day toculture. These values should be maintain this trust. The Port’s reputation as a trustworthy public agency startsreflected in all business transac- and ends with each employee.tions, community interactions, andin the workplace. HONORING OUR SHARED VALUESEmployees conduct business with Port employees achieve their common mission through decisions and actionsthe highest ethical standards. that honor the Port’s values. As employees make choices in their everydayThe Port’s business practices reflect work, they are especially attentive to upholding the Port’s ethical values.integrity, accountability, honesty, Employees should always think about what it means to act with integrity,fairness, and respect at all levels. be fair, be honest, and treat others with respect.Employees honor their commitmentsto one another, the community, andthe Port’s customers. Employeesprovide outstanding service andvalue to each other, Port customers,the citizens of King County, and theregion they serve.Employees are capable, highperforming people who appreciatethe privilege of public service.Employees practice opencommunication, innovation,collaboration, and transparencyin all interactions.Employees embace the richnessof a diverse workplace andsupport employee development.Employees encourage a healthy anddiverse organization that enhancesthe Port’s contributions locally. 0505 ETHICS & COMPLIANCE HOTLINE: 1.877.571.5237WCOODREKOPFLAETCHEICCSO&DWEOORKFPCLAOCNEDCUONCDTUCT

OUR ETHICAL VALUES Integrity Employees act in the public interest and live up to Port values. Respect Honesty Employees treat Employees are open others with and truthful. dignity. Ethical Values Fairness Accountability Employees Employees demonstrate objectivity & avoid readily account personal bias for and take & favoritism. responsibility for their actions. 0506 ETHICS & COMPLIANCE HOTLINE: 1.877.571.5237WCOODREKOPFLAETCHEICCSO&DWEOORKFPCLAOCNEDCUONCDTUCT

Ask! EMPLOYEES MAKE GOOD DECISIONSTo discuss a situation or to askfor guidance in thinking through Maintaining the public trust requires a daily commitment to makingwhat to do, reach out to a good decisions. This sounds simple, but it’s not always easy. Employeessupervisor or manager, or to: should always choose right over wrong, but sometimes understanding which issues to consider is less clear.You also can connect with theWorkplace Responsibility TAKING TIME TO STOP, THINK & ASKOffice through the followingstaff members: Whenever an employee feels uncertain about whether an action is the right thing to do, the employee should consider whether they would be comfortable seeingHUMAN RESOURCES a description of their conduct, or that of somebody else representing the Port, on& DEVELOPMENT the front page of the newspaper.Assistant DirectorMarjorie Hillson Questions to [email protected] Is this action legal?Employee Relations ManagerCynthia Alvarez Is this action consistent206.787.4508 with Port [email protected] Does this action complyLEGAL DEPARTMENT with the Port ofCode Compliance OfficerGeneral Counsel Seattle Code of Conduct?Craig Watson206.787.3218 If an employee feels unsure about taking a particular action, the [email protected] should stop and discuss the situation with a supervisor, or with the WorkplaceSenior Port Counsel Responsibility staff.Anne Purcell206.787.3773 ETHICS & COMPLIANCE HOTLINE: [email protected] AdvisorSenior Port CounselTraci [email protected] are urged to payattention to their intuition.Intuition often can deter-mine what’s right evenbefore there is time to think.A physical reaction, suchas a gut feeling, signalsa need for more thoughtbefore taking action. 0507WCOODREKOPFLAETCHEICCSO&DWEOORKFPCLAOCNEDCUONCDTUCT

WE FOLLOW THIS CODEEmployees should not This Code of Conduct is the Port’s guide to applying the correctviolate the Code ethical values to work and workplace behavior. The conduct standardseven if doing so would outlined in this Code express the commitment employees make tolower costs, improve Port business partners and customers, the public, and to each other.performance, or provide Employees commit to following the Code because they are legallyany other beneficial obligated to do so, and because it’s the right thing to do.effect. UNDERSTANDING EMPLOYEES’ OBLIGATION TO COMPLYQ&A This Code applies to all Port employees. Employees are responsible for followingWhere can employees find the standards outlined in this Code. Compliance with Code standards is athe Workplace Responsibility condition of employment at the Port. Because employees are responsible forCompass page? following the Code, violations of it, or violations of the laws that underlie it, will subject employees to disciplinary action. Disciplinary action can includeGo to the Port’s Compass page termination.and look under the “Quick Links”tab for Workplace Responsibility. Although this Code can’t provide specific guidance for every situation employees may face, most issues can be addressed by referring to this Code and the resources posted on the Workplace Responsibility Compass page. When in doubt, employees should ask for help. Conflict of interest and ethics issues in particular are not always obvious or clear. It’s better to: “Stop. Think. Ask.” 0508 ETHICS & COMPLIANCE HOTLINE: 1.877.571.5237WCOODREKOPFLAETCHEICCSO&DWEOORKFPCLAOCNEDCUONCDTUCT

APPLICATION TO REPRESENTED EMPLOYEES This Code applies to represented employees. If a particular Code standard constitutes a change in working conditions under an applicable collective bargaining agreement or other negotiated agreement between the Port and a union, or is contrary to a bonafide past practice, an opportunity to bargain the change will be provided before employees of that bargaining unit are held responsible for complying with that standard. EXPECTATIONS OF MANAGERS AND SUPERVISORS Supervisors and managers have additional responsibilities. They are expected to: • Understand this Code and set an example for others by referring to it, making good decisions, and seeking guidance when in doubt • Review parts of this Code with their team members and encourage identification of issues and questions • Create an environment in which employees can raise concerns without fear of retaliation • Ensure that all Port teams complete all required Code certifications and compliance training 09 ETHICS & COMPLIANCE HOTLINE: 1.877.571.5237CODE OF ETHICS & WORKPLACE CONDUCT

“I like knowing there are places EMPLOYEES HOLD to turn to when I have a question THEMSELVES ACCOUNTABLE or concern.” Accountability is one of the Port’s ethical values. Employees take responsibilityEmployees should trust by speaking up when they have concerns, and holding each other accountabletheir instincts. They should by calling out conduct that violates this Code.ask questions or raiseconcerns, rather than SPEAKING UPignore behavior that couldbecome a serious problem. Employees hold themselves and each other accountable for following this Code. This means employees speak up whenever they have a question about a situationIf any employee is that concerns them. By speaking up, employees provide an opportunity forconcerned that a situation others to stop, think, and ask before a decision is made or any action is taken.poses an immediate threat,they should call 911. If employees have questions or concerns about anyone’s conduct, or are unsure how to handle a situation, they should: • Talk to a supervisor or manager or • Reach out to any of the Workplace Responsibility resources REPORTING CODE VIOLATIONS If employees believe any employee is not living up to this Code, or the law, they should promptly report it. Port employees are encouraged to report all potential violations, but they must report the following misconduct: • Violations of the Employee and Consultant Ethics and Conflict of Interest policies (see pages 19–15) • Fraud Awareness & Prevention (see pages 29–31) • Violations of the Information Systems and Services Acceptable Use and Corporate Use of Social Media policies (see pages 32–35) MANAGERS AND SUPERVISORS Supervisors and managers are held to a higher level of responsibility. They must promptly report all potential Code violations if they have reason to believe that violations may have occurred, or if someone reports a potential violation to them. 10 ETHICS & COMPLIANCE HOTLINE: 1.877.571.5237CODE OF ETHICS & WORKPLACE CONDUCT

Designated REPRESENTED EMPLOYEESReporting Resources The Code’s reporting obligations apply equally to represented and non-represented employees.Ethics & Compliance Hotline1.877.571.5237 WHERE TO REPORTEmail Employees should report a potential Code violation to a supervisor or manager,workplaceresponsibility or to a designated Reporting Resource, listed at left. Supervisors and [email protected] must report any potential violation of the Code to one of the Port’s designatedHUMAN RESOURCES & Reporting Resources.DEVELOPMENT DEPARTMENTEmployee Relations Manager The Port’s designated Reporting Resources includes the Ethics & ComplianceCynthia Alvarez Hotline. Operated by a third party to facilitate confidential reporting, this206.787.4508 hotline is available 24 hours a day, 7 days a week. Reports can be [email protected] anonymously. Any information reported to the designated Reporting ResourcesConsultant is referred to the Workplace Responsibility Office for review and follow up.Matthew Bullock206.787.5860 REVIEW & [email protected] Workplace Responsibility staff reviews each report to determine how to bestLEGAL DEPARTMENT follow up. Some reports are referred to appropriate agencies. Other times,Code Compliance Officer it can be appropriate to conduct a full investigation.General CounselCraig Watson If an investigation is deemed to be appropriate, employees who are contacted206.787.3218 as part of the investigation are expected to cooperate and provide [email protected] information. For more information on Workplace Responsibility’s process forEthics Advisor reviewing and following up on reports, go to “What to Expect When ReportingSenior Port Counsel a Violation” on page 16.Traci Goodwin206.787.3702 THE PORT IS COMMITTED TO [email protected] The Port promotes and supports a workplace where it is safe to speak up withoutNo matter what reporting fear of retaliation. Employees shall never engage in or tolerate retaliationresource employees use, against anyone who in good faith raises a concern, reports a possible violation,their concerns are promptly or participates in the investigation of a report.reviewed for follow up. Retaliation is a negative action taken against an employee because the employee 11 reported or participated in an investigation of a potential Code violation. A negative action is one that would dissuade a reasonable person from making CODE OF ETHICS & WORKPLACE CONDUCT a report or participating in an investigation. Retaliation can take the form of threats of or actual suspension, termination, harassment, demotion or intimidation. Anyone found to have retaliated against a Port employee who raised a concern, reported a potential violation, or participated in an investigation will be subject to disciplinary action, up to and including termination. Anyone who reports a concern or potential violation in bad faith also will be subject to disciplinary action, up to and including termination. ETHICS & COMPLIANCE HOTLINE: 1.877.571.5237

Recording Time EMPLOYEES ARE HONESTEmployees must accurately record Honesty is one of our ethical values. We maintain the public’s trust, and ourtime worked. They should let their trust in each other, through transparency, truthfulness and accurate recordsupervisor or manager know if keeping.they have problems recording theirtime properly. BEING OPEN AND TRUTHFULSalaried employees shall:• Always ensure that the total Employees are forthright and truthful because it’s the right thing to do. Telling the truth can feel uncomfortable, or can mean that one will be the bearer of bad number of hours they record news. Because Port employees are committed to openness and truthfulness, they in their bi-weekly time must never engage in acts of dishonesty. Dishonest acts include intentional report accurately reflects the misrepresentation, concealment, omission or other deceptive or misleading minimum number of hours behavior for the purpose of improperly advancing a personal or outside interest that they actually worked or improperly benefitting the Port.• Never record hours for a day when they were A particularly serious form of deception is fraud. Fraud at the Port includes not performing their work any act of deception that could result in personal gain. Fraud includes divertingHourly employees shall never: Port resources to an outside entity or to an individual without authorization.• Work without pay, including Fraud may exist whether or not there is actual harm to the Port. Forgery or not recording hours for work any unauthorized alteration of Port records or documents also is prohibited. done at home• Move hours from one day Cheating is another form of dishonesty that the Port does not tolerate. Cheating to another on a time refers to a knowing and intentional violation of the rules. Cheating can include record to avoid overtime taking or administering a test in an unfair way.• Record time for each other• Inaccurately record KEEP ACCURATE AND COMPLETE RECORDS time worked• Remove correctly recorded Employees strive to ensure that the information they put in their records is hours from a time record accurate and complete. This obligation extends to time records, expense reports, budget, accounting and financial documents, decision memos, contracts and 12 service agreements, payments and other transactions. CODE OF ETHICS & WORKPLACE CONDUCT DUTY TO REPORT FRAUD As responsible stewards of public resources, Port employees have an affirmative duty to immediately report information that they know or have reason to believe indicates potential fraud, forgery or cheating. Our duty to report fraud includes reporting activity that occurred in the past, but has only recently become apparent. Employees must report their concerns to a designated Reporting Resource, even if they have already made a report to law enforcement. ETHICS & COMPLIANCE HOTLINE: 1.877.571.5237

Reporting Theft REPORT STOLEN ORof Port Property LOST PORT PROPERTYFirst, immediately contact: As responsible public servants, employees are committed to preventingPort of Seattle and minimizing the theft and loss of Port resources.Police Department206.787.5401 DUTY TO REPORT THEFT(Or local police agency iftheft occurs off Port property) All employees are responsible for immediately reporting any known or suspected theft of Port resources. Even if the value of the loss is small, the Code does notand relieve employees of the obligation of reporting the theft. Theft occurring on Port property must be reported immediately to the Port of Seattle Police Department.ICT Service Desk If the theft involves a Port computer, laptop, tablet, smartphone or other elec-206.787.3333 tronic data device, you should also immediately contact Information & Communi-(If stolen item is an cations Technology (ICT) so the device can be blocked from unauthorized useelectronic data device) and any sensitive or confidential information can be deleted. If an employee has reason to believe that another Port employee committed the theft, the employeeand must also report the theft to Workplace Responsibility.Ethics & Compliance Hotline DUTY TO REPORT LOSSES1.877.571.5237 Employees must promptly report known or potential losses of Port resourcesSecond, complete exceeding $50 in value (individually, or recurring smaller losses that total $50 oran Incident Report: more). This responsibility to report losses extends to those losses that occurred• Go to Compass Quick Links in the past, but which have only recently become apparent. The following activities need not be reported, but should be recorded in the• U nder Forms & Templates accounting system and monitored for any unusual trends: open Risk & Liability Online • Normal “over and short” situations from cash receipting operations Incident Report • Reasonable inventory shortages identified during a physical count• C omplete and submit ETHICS & COMPLIANCE HOTLINE: 1.877.571.5237 Port Property Loss FormReporting Lossesof Port PropertyFirst, complete anIncident Report• Go to Compass Quick Links• U nder Forms & Templates open Risk & Liability Online Incident Report• Complete and submit Port Property Loss FormSecond, immediatelycontact ICT Service Desk206.787.3333(If the loss involvesan electronic data device) 13 CODE OF ETHICS & WORKPLACE CONDUCT

THE PORT OF SEATTLE IS AN EQUAL OPPORTUNITY WORKPLACE We are committed to non-discrimination and reasonable accommodation The Port of Seattle is an equal opportunity employer and is committed to fostering a diverse workforce. The Port does not tolerate any discrimination in the workplace that is prohibited by local, state, or federal law such as discrimination based on age, race or sex. In addition to making a commitment to inclusion, the Port expects its employees to be tolerant, accept individual differences, and avoid stereotyping others. The Port also recognizes that employees with physical or mental disabilities may need reasonable accommodations in order to perform the essential functions of their jobs. The Port and the employee work together to identify possible accommodations. The Port also offers reasonable accommodation for an employee’s sincerely held religious belief that conflicts with a workplace rule. Employees who wish to request an accommodation of a disability or religious belief should contact the Director of Human Resources and Development (HRD). 14 ETHICS & COMPLIANCE HOTLINE: 1.877.571.5237CODE OF ETHICS & WORKPLACE CONDUCT

THE PORT OF SEATTLE IS A WORKPLACE FREE OF ALCOHOL, ILLEGAL DRUGS & VIOLENCE The Port is committed to proactively preventing workplace violence and maintain- ing a safe and efficient working environment. It’s important that both employees and the public are free from threats of violence at Port facilities. Threatening behaviors include threats of physical injury, aggressive or hostile behavior, threats to property, or possession of a firearm that is not associated with Port duties. In addition, it is possible that domestic violence could intrude into the workplace. Employees should raise any concerns they may have about any domestic violence situation, including their own, with HRD. Employees are responsible for reporting any violation of this policy to a manager or the Director of HRD. Supervisors and managers are held to a higher degree of responsibility and must promptly report any violations of this policy to the Director of HRD. The Port is committed to promptly investigating any reports of threats or violence. The Port also is committed to maintaining a drug-free workplace and does not tolerate employees being impaired due to the influence of alcohol or illegal drugs during work hours. Employees impaired by illegal drugs or alcohol are a serious threat to workplace safety and job performance. Employees are encouraged to report any concerns regarding a coworker’s suspected intoxication/impairment to managers or the Director of HRD. Supervisors and managers are held to a higher standard of responsibility and must report any instance of an employee being impaired to the Director of HRD. The Port will promptly and thoroughly investigate any policy violation reports. 0515 ETHICS & COMPLIANCE HOTLINE: 1.877.571.5237WCOODREKOPFLAETCHEICCSO&DWEOORKFPCLAOCNEDCUONCDTUCT

APPENDIX I 16 WHAT TO EXPECT WHEN MAKING A REPORTWCOODREKOPFLAETCHEICCSO&DWEOORKFPCLAOCNEDCUONCDTUCT The Port follows a well-defined process in receiving, reviewing and, where appropriate, investigating reports of potential violations. This procedure promotes responsiveness, fairness and consistency in how reports are handled and resolved. Intake The Intake Phase is intended to achieve a full understanding of a reported concern. After making a report, the reporter will be asked to provide details to a trained interviewer. The interviewer also may review pertinent records or documents and other background information to confirm reported details. Q: Are the subject of a report and/or potential witnesses contacted during the intake phase? A: No. During intake, as many factual details as possible are collected about the report to assess its credibility and determine appropriate next steps. Only if a full investigation is deemed to be appropriate will the subject and potential witnesses be contacted. Review The response to a report is determined during the Review Phase. This determination is made by a cross-department Review Team, which includes representatives from HRD, Labor Relations, the Legal Department, and Workplace Responsibility. In determining whether an investigation is appropriate, the Workplace Respon- sibility Review Team uses the following standard: If true, would the reported facts constitute a potential violation of this Code or potential improper government action? If the answer is “yes,” an investigation will be initiated. If the answer is “no,” the reporter is notified and, if appropriate, referred to another resource who can help resolve the concern. Q: What if an employee reports conduct that involves a member of the Review Team, or a leader in that person’s department? Will that member be involved in reviewing or discussing the report? A: No. He or she would not be allowed to participate in any review or discussion of the report, or given any information about the report. ETHICS & COMPLIANCE HOTLINE: 1.877.571.5237

Investigation The investigation’s purpose is to independently gather and objectively assess facts to determine whether a Code violation or improper governmental action occurred. Workplace Responsibility and HRD staff generally conduct investiga- tions under the supervision of or in coordination with Legal staff. Investigations of represented employees are conducted in accordance with requirements con- tained in their collective bargaining agreement. Employees are expected to cooperate with workplace investigations and to provide truthful information. The investigator may ask the reporter and witnesses to avoid discussing the investigation with others. Post-Investigation Following an investigation, the reporter, subject, and subject’s supervisor or manager are notified of the findings. If the investigation substantiates a violation, the Review Team members will recommend corrective action or discipline that they deem is fair and consistent with that imposed for similar violations. The subject’s manager or supervisor ultimately is responsible for determining and imposing corrective action or discipline. Confidentiality Every attempt is made to protect the identity of reporters and witnesses, as well as protect the confidentiality of the information they provide. However, the reporter’s confidentiality cannot be guaranteed. Public records disclosure requirements or an applicable collective bargaining agreement may require the Port to disclose reports and investigation records. 17 ETHICS & COMPLIANCE HOTLINE: 1.877.571.5237WCOODREKOPFLAETCHEICCSO&DWEOORKFPCLAOCNEDCUONCDTUCT

INVESTIGATION PROCESS Report of Potential Code of Conduct/ Whistleblower Violation Manager/ Supervisor HRD Employee Legal Ethics and Compliance Hotline WORKPLACE RESPONSIBILITY (WR) Report & Report documented Assessment Phase Intake interview with reporter Review Team (HRD, Labor Relations, Legal & WR) reviews report Yes No If true, do facts constitute potential Follow-up Refer for Code/ Whistleblower follow-up? violation? Process No Yes Intake & ends Review Phase Investigation Review by Review Team No Violation Investigation violation found Phase found Follow-up Yes Review Team recommends on corrective action/discipline Refer for follow-up? Process No Manager/Supervisor determines ends corrective action/discipline 18 Process Outcome ends PhaseWCOODREKOPFLAETCHEICCSO&DWEOORKFPCLAOCNEDCUONCDTUCT

APPENDIX II PORT OF SEATTLE CODE OF CONDUCT CC- 01 • Help employees identify potential ethical concerns and conflicts of interest EMPLOYEE ETHICS AND CONFLICT OF INTEREST • Require employees to disclose potential conflicts of interest; and Serving the Port Loyally CC-1 as of 1.1.10 • Require employees to report potential policy violations I. THE PORT’S INTERESTS COME FIRST No policy can adequately substitute for per- Port of Seattle employees are expected to sonal honesty, common sense and good judg- serve the Port with the highest standards of ment. At a minimum, Port employees are ethical conduct and to avoid situations that expected to apply these attributes to their create a real or perceived “conflict of inter- daily job-related activities. Port employees are est.” A “conflict of interest” exists when an expected to conserve and responsibly use employee’s duty to give undivided loyalty to the resources the public has entrusted to the the Port is influenced, or could be influenced, Port, to act in accordance with applicable by personal interest. The fact of a conflict laws, and to conduct all Port business in a of interest is not in itself a violation of the manner that will reflect positively on the Port, policy. Instead, it is something that should its employees and the community. be reported (see Section IV) so the Port may ensure that decisions are not made that II. REAL OR PERCEIVED CONFLICTS could be influenced by the conflict of interest, OF INTEREST or perceived to have been influenced by it. Port employees must avoid real, or perceived, Port employees must ensure that any outside conflicts of interest between their private activity or personal interest is kept separ- activities and their duties and responsibilities ate from their position at the Port and does as employees. At a minimum, potential con- not influence their business judgment on flicts should be reported so that the Port may the Port’s behalf. Port employees need to use consider what, if any, actions should be taken common sense and keep the interests of to ensure that decisions are not influenced the Port paramount at all times. In addition (or perceived to be influenced) by personal to avoiding actual conflicts of interests, interests. Port employees should avoid situations that could appear to be a conflict of interest. The following are examples of situations in which an employee may feel conflicting loyal- Ethical issues and conflicts of interest are ties between what is in the best interest of not always obvious or clear. It is far better to the Port and what may be in the best interest raise issues in advance and get guidance of the employee. For purposes of this policy, than to make the wrong judgment call. Thus, “Relative” is defined to include an employee’s when in doubt, please review the situation spouse, domestic partner, parents, children, with the Workplace Responsibility Office. cousins, nieces, nephews, grandparents, grandchildren, in-laws, and any person with This policy is intended to: whom the employee has a relationship that is substantially equivalent to any of the above. • Guide employees so that they consistently 19 conduct Port business without being influenced by considerations of personalWCOODREKOPFLAETCHEICCSO&DWEOORKFPCLAOCNEDCUONCDTUCT advantage or gain ETHICS & COMPLIANCE HOTLINE: 1.877.571.5237

A. Conflicts from Business Relationships B. Conflicts from Outside Employment A conflict of interest may exist when an Working with any organization that has a employee, an employee’s Relative, or some- business relationship with the Port, or seeks one with whom an employee has a significant to have one, results in a conflict of interest personal relationship, directly or indirectly, if that business receives, or may receive, more has a Financial or Beneficial Interest in, or favorable treatment as a result of the employ- operates, an organization that competes with ee’s relationship with the business. As a the Port, is doing business with the Port, or result, working for those with whom the Port plans to do business with the Port. Employees has a business relationship is prohibited should, therefore, avoid owning interests in unless expressly approved in writing by the or operating companies that compete with Workplace Responsibility Office. the Port, or that sell (or plan to sell) products or services to the Port, other than minimal Even if outside employment is with an organ- amounts of stock in publicly-traded companies. ization that does not have a business relation- ship with the Port, conflicts of time and en- The Port’s policy is to award business solely ergy may arise. Accordingly, salaried, exempt on merit, without favoritism, by securing employees must obtain prior written approval the best product or service available at the from his or her Department Head before hold- best price. Therefore, an employee must ing a job with another organization. If such disclose to the Workplace Responsibility Office approval is granted, the employee acknowl- the existence of any Financial or Beneficial edges that satisfactory job performance Interest which, because of its existing or with the Port must be maintained and that no potential relationship to the Port, could cre- conflict of interest can exist. ate a present or future conflict of interest. An employee shall be presumed to have All employees with other jobs will continue to knowledge of any Financial or Beneficial be judged by the same performance standards Interest held by a Relative. and will be subject to the Port’s scheduling demands, regardless of any existing outside For purposes of this policy, “Financial or work requirements. If the Port determines Beneficial Interest” is defined to include: (a) that an employee’s outside work interferes a creditor, debtor or ownership interest in an with performance or the ability to meet the amount or value in excess of $1,500; (b) any Port’s changing requirements, employees may employee, consultant or partnership arrange- be asked to terminate outside employment ment; or (c) any option to purchase real or in order to continue employment with the Port. personal property. C. Improper Compensation No employee shall have a Financial or Benefi- No employee may, directly or indirectly, ask cial Interest, direct or indirect, in any contract for or give or receive or agree to receive any that may be made by, through or under the compensation, gift, reward or gratuity from supervision of the employee, or for the benefit a source for performing or omitting or defer- of the Port. No employee shall accept, di- ring the performance of any official duty, rectly or indirectly, any compensation, gratu- unless otherwise authorized by law. See also ity or reward in connection with such contract Gifts and Hospitality Policy. from any other person beneficially interested therein. III. USE OF POSITION FOR PERSONAL BENEFIT An employee shall not participate in any One particular type of conflict of interest arises decision-making, review, approval, selection, when an employee is in a position to exploit authorization or supervisory activity concern- his or her role with the Port to advance his or ing any contract or Port transaction in which her personal interest. A conflict of interest he/she or his/her Relative has a Financial also arises when an employee may have com- or Beneficial Interest. peting loyalties between his or her personal interests and the Port’s business. Employees 20 must avoid circumstances in which it appears, or to a reasonable person might appear,WCOODREKOPFLAETCHEICCSO&DWEOORKFPCLAOCNEDCUONCDTUCT that the employee is requesting or otherwise ETHICS & COMPLIANCE HOTLINE: 1.877.571.5237

21 seeking special consideration, treatment or client privileged communications and attor- advantage because of the employee’s position ney work product; research and development;WCOODREKOPFLAETCHEICCSO&DWEOORKFPCLAOCNEDCUONCDTUCT with the Port. product, content and technology develop- ment plans; marketing; databases; inventions; A. Obtaining Special Privileges research data and mechanisms; procedures; Port employees shall not use their employ- engineering; purchasing; accounting; sales; ment position to secure special privileges or customers; advertisers; investors; suppliers; exemptions for themselves or a Relative. financial status; contracts or employees. This includes obtaining any information, item or service from Port customers, suppliers, The Port’s definition of Confidential Informa- contractors, consultants, or lessees (or poten- tion for purposes of an employee’s require- tial customers, suppliers, contractors, con- ments under this policy covers more informa- sultants, or lessees) or other Port employees. tion than may fall within the public records It also includes an employee using his posi- disclosure rules. While the Port is committed tion at the Port to help a Relative get a job to transparency as a public agency, it also is offer from the Port or to obtain a job offer from respectful of employees and wants to foster a Port vendor. an environment in which opinions may be aired without fear of publicity. It also needs B. Use of Port Equipment to be able to formulate business strategy in- Employees are expected to use Port-owned ternally and make decisions about when such property and equipment for official Port discussion is ready for more public debate. business. An employee shall not take or use Thus, if you have a question about whether Port-owned property and equipment for information is confidential, please consult personal purposes, convenience or profit. This with the Workplace Responsibility Office be- includes taking or using fleet vehicles, shop fore communicating it externally. tools, fax machines, copiers, postage, office supplies, cameras, cell phones and laptops. An employee shall not use Confidential Infor- mation in any manner that is detrimental It is not a violation of this policy for an em- to the Port. This restriction applies regardless ployee to (i) engage in the incidental personal of whether the use or disclosure of Confiden- use of such property or equipment (such as tial Information results in any benefit to the sending/receiving personal e-mails while employee or the employee’s Relative. using a Port-owned laptop) while at the work- place, or (ii) engage in other incidental uses An employee shall not use Confidential Infor- of such property or equipment that may mation for the benefit of the employee or be specifically permitted by a CEO’s adopted employee’s Relative. An employee shall not policy (such as an employee’s use of a Port accept secondary employment or engage assigned cell phone to make a long distance in business or professional activities that the call to a family member while traveling on employee might reasonably expect would Port business, in accordance with Procedure require or induce him/her to disclose Confi- AC-2) or CEO written authorization. See also dential Information. Information systems and Services Acceptable Use Policy CC-7. IV. DUTY TO REPORT CONFLICTS OF INTEREST C. Safeguarding Confidential Information An employee shall not disclose “Confidential Employees must report to the Workplace Information” to third parties. “Confidential Responsibility Office all potential situations Information” includes, without limitation, any that could present a real or perceived conflict information in whatever form that the Port of interest, including Financial or Beneficial considers to be confidential, proprietary in- interests held by the employee in entities formation and that is not publicly or generally doing business with the Port. The fact of available relating to: trade secrets (as defined a conflict of interest is not, in and of itself, a by the Uniform Trade Secrets Act); matters policy violation. Rather, it is the failure to dis- discussed during Executive Sessions; requests close a real or potential conflict of interest, for proposals; proposed or pending real estate and/or taking action on behalf of the Port transactions; personnel matters; all matters when there is a real or perceived conflict of not subject to public disclosure; attorney- interest that is of concern to the Port. ETHICS & COMPLIANCE HOTLINE: 1.877.571.5237

After an employee discloses a real or potential ations that create a real or perceived “conflict conflict of interest, the Workplace Responsi- of interest.” Consultants are also expected bility Office will document the disclosure and to conserve and responsibly use the resources determine any steps that should be taken to that the public has entrusted to the Port, avoid the employee’s participation in any deci- to act in accordance with applicable laws and sion. Employees also should report all po- professional standards and to conduct busi- tential conflicts of interest, financial or other- ness with the Port in a manner that will reflect wise, of another employee who is in a position positively on the Port, its employees, its con- to influence the selection, non-selection, or sultants, and the community. conduct of business between the Port and any entity. For purposes of this policy: In an effort to assist employees in identifying “Consultant” or “Consultants” refers to any and disclosing potential conflicts of interest, organization or individual that responds to a the Port will periodically ask employees to Port solicitation or receives compensation complete a “Statement of Financial or Benefi- directly or indirectly from a Contract with the cial Interests” and disclose information that Port. The term “Consultant” or “Consultants” may relate to an actual or perceived conflict of includes individuals working for or on behalf interest. of the consulting organization. V. REPORTING CONCERNS OR VIOLATIONS “Contract” refers to an agreement for the provision of personal or professional services. All employees have a responsibility for ensur- ing that this policy is followed. Concerns “Financial or Beneficial Interest” is defined and potential violations should be reported to to include (a) a creditor, debtor or ownership the Workplace Responsibility Office, or any- interest in an amount or value in excess of one identified in the “Reporting Concerns or $1,500; (b) any employee, consultant or part- Violations” policy. Supervisors and managers nership arrangement; or (c) any option to will be held to a higher level of responsibility purchase real or personal property. A Consul- with respect to reporting potential violations. tant shall be presumed to have knowledge Supervisors and managers who know of or of any Financial or Beneficial Interest held by receive reports of potential violations must a Relative. promptly report them to the Workplace Responsibility Office. Employees will not be “Representing Consultant” is a Consultant retaliated against for reporting in good who is retained to represent, or who gives the faith concerns or potential violations of this appearance of representing, the Port. policy. See “Reporting Concerns or Violations” policy for more detail. “Relative” is defined to include a Consultant’s spouse, domestic partner, parent, child, For further information, please contact sibling, aunt, uncle, cousin, niece, nephew, the Workplace Responsibility Office. grandparent, grandchild, in-law, and any person with whom the Consultant has a rela- CC- 02 tionship that is substantially equivalent to any of the above. 22 CONSULTANT ETHICS AND A “conflict of interest” exists when a Consul- CONFLICT OF INTEREST tant’s obligations and commitments to theWCOODREKOPFLAETCHEICCSO&DWEOORKFPCLAOCNEDCUONCDTUCT Port are, or may be, in conflict with the Con- Serving the Port With Integrity sultant’s financial or other personal interest, CC-2 as of 8.16.2011 or with the Consultant’s obligations or com- Original – 1.1.2010 Revisions: 8.16.2011 mitments to others. A conflict of interest may exist in a specific Contract , or when the I. THE PORT’S INTERESTS COME FIRST nature of the services to be performed in a specific Contract creates an actual or poten- Port of Seattle consultants (“Consultants”) are tial conflict of interest in future work for the expected to serve the Port with the highest Port. Consultants must ensure that any finan- standards of ethical conduct and to avoid situ- ETHICS & COMPLIANCE HOTLINE: 1.877.571.5237

23 cial or personal interest, or other business owning interests in or operating companies activity, is kept separate from their consulting that compete with the Port, other than minimalWCOODREKOPFLAETCHEICCSO&DWEOORKFPCLAOCNEDCUONCDTUCT role at the Port and does not influence their amounts of stock in publicly traded companies. services to the Port. Consultants need to use common sense and keep the interests of the A conflict may also arise when a Representing Port in mind at all times. In addition to avoid- Consultant or a Relative is employed by or ing actual conflicts of interests, Consultants represents a regulatory agency with authority must avoid situations that could appear to be over Port functions. a conflict of interest. Duty to Disclose: Consultants must disclose Conflicts of interest are not always obvious to the CPO Representative or Project Manager or clear. When in doubt, review the situation all potential situations that could present a with the Port Central Procurement Office real or perceived conflict of interest. The representative identified in the solicitation disclosure should be made as soon as prac- (“CPO Representative”) or the Port project ticable, but not later than seven days after manager identified in the Contract. (“Project the potential conflict was known or should Manager”). You may also contact the Port reasonably have been known to the Consul- Workplace Responsibility Office with any tant. The Port will document the disclosure. questions about this policy or to review a po- The Central Procurement Office, with the tential conflict of interest situation or other concurrence of the Workplace Responsibility ethics issue. Office, will determine whether the Port will waive the conflict of interest and/or identify II. REAL OR PERCEIVED CONFLICTS appropriate steps to be taken to avoid or OF INTEREST mitigate the conflict of interest. The Consul- tant shall not execute any contracts or per- The following are examples of situations in form any services for the Port of Seattle that which a Consultant may feel conflicting loyal- are related to the actual or perceived conflict ties between the Consultant’s private inter- of interest unless and until a waiver is granted. ests or other business activities and the Con- sultant’s responsibilities and commitments B. Prohibited Conflicts to the Port. Prohibited conflicts are a violation of this policy and must be disclosed to the Port. A. Disclosable Conflicts from Business Relationships No Consultant shall accept, directly or indi- The fact of a disclosable conflict of interest is rectly, any compensation, gratuity or re- not in itself a violation of this policy. Instead, ward in connection with a contract from any it is something that must be disclosed and other person beneficially interested therein. waived by the Port. The fact of a disclosable conflict of interest is not in itself a violation of A Consultant shall not participate in any deci- this policy. Instead, it is something that must sion-making, review, approval, selection, be disclosed and waived by the Port. authorization or supervisory activity concern- ing any contract or Port transaction in which A conflict of interest may exist when a Consul- the Consultant or a Relative has a Financial or tant performs services for another entity if Beneficial Interest. those services (i) potentially adversely impact the Port of Seattle or (ii) require or result in A Consultant shall not, directly or indirectly, disclosure of confidential information. ask for or give or receive or agree to receive any compensation, gift, reward, or gratuity A conflict of interest may exist when a Repre- from a source outside the Port for performing, senting Consultant, a Relative, or someone omitting, or deferring the performance of any with whom a Representing Consultant has contractual, legal or professional obligation a significant personal relationship, directly relating to the Consultant’s consulting role, or indirectly, owns any significant interest in unless otherwise authorized by law. or operates an organization that competes with the Port, is doing business with the Port, A conflict of interest arises when a Consult- or plans to do business with the Port. Repre- ant is in a position to exploit the Consultant’s senting Consultants should, therefore, avoid role or use of Port resources to advance ETHICS & COMPLIANCE HOTLINE: 1.877.571.5237

24 the Consultant’s financial or other business IV. SAFEGUARDING CONFIDENTIAL or personal interests. Consultants must avoid INFORMATIONWCOODREKOPFLAETCHEICCSO&DWEOORKFPCLAOCNEDCUONCDTUCT circumstances in which it appears, or to a reasonable person might appear, that the A Consultant shall not use or disclose con- Consultant is requesting or otherwise seeking fidential information to third parties, unless special consideration, treatment or advantage authorized by the Port in writing. “Confiden- because of the Consultant’s engagement with tial Information” includes, without limitation, the Port. any information in any form that the Port considers to be confidential and proprietary, Consultants shall not use their consulting role and is not publicly available. A Consultant to secure special privileges or exemptions shall not use Confidential Information for the for themselves or a Relative. This includes ob- benefit of the Consultant or a Relative. A Con- taining any items or services at below market sultant shall not use or disclose Confidential rates or confidential information from Port Information in any manner that is detrimental customers, suppliers, contractors, consul- to the Port, regardless of whether the use tants, or lessees (or potential customers, sup- or disclosure results in any benefit to the Con- pliers, contractors, consultants, or lessees) sultant or Relative. or other Consultants. It also includes a Con- sultant using his or her engagement with the A. Employment Port to help a Relative get a job offer from A Consultant shall disclose an offer of em- the Port or obtain a job offer from a Port busi- ployment or receipt of compensation from an ness partner. Employer if the Consultant knows, has reason to believe, or the circumstances would lead Duty to Disclose: Consultants must disclose a reasonable person to believe, that the offer to the CPO Representative or Project Manager of employment or compensation was intend- all situations that potentially or actually con- ed, in whole or in part, directly or indirectly, to stitute a prohibited conflict of interest. The influence the Consultant or as compensation disclosure should be made as soon as practica- or reward for the performance or nonper- ble, but not later than seven days after the formance of a duty by the Consultant during prohibited conflict was known or should rea- his/her Port engagement. For purposes of this sonably have been known to the Consultant. policy, “Employer” means any person, partner- ship, association, corporation, firm, institu- III. Use of Port Equipment tion, or other entity, whether or not operated Consultants are expected to use Port-owned for profit. property and equipment for official Port busi- ness related to an existing Contract. Con- V. EXPECTATIONS OF FORMER CONSULTANTS sultants may not use Port owned property or equipment for any other business purpose. For purposes of this policy, “Termination” of Port engagement is defined as the latest date A Consultant shall not take or use Port-owned on which the Consultant provided services property and equipment for personal purpos- on a Contract or, in the case of a retainer, was es, convenience, or profit. This includes, but paid for services. is not limited to, taking or using Port vehicles, shop tools, fax machines, copiers, postage, A. Disclosure Requirements office supplies, cameras, smartphones and For one (1) year after Termination of a Port laptops. It is not a violation of this policy for a engagement, a Former Consultant must Consultant to engage in de minimis or inci- disclose the Former Consultant’s past Port dental personal use of such property or equip- engagement to the Port before participating ment while at the Port workplace. in any Port business or activity and must also disclose the Former Consultant’s past When using Port electronic systems and social Port engagement before participating in any media, Consultants must comply with the proceeding before the Commission. The dis- Port’s Electronic Systems and Social Media closure shall be made in writing to the CPO policies, which are posted on the Port’s public Representative or Project Manager and/or the web site. Commission President. ETHICS & COMPLIANCE HOTLINE: 1.877.571.5237

B. Special Consideration Prohibited The waiver shall be in writing and identify A Former Consultant shall not request or oth- all facts and the rationale for the waiver. The erwise seek special consideration, treatment waiver shall be granted prior to a Former Con- or advantage from other Port staff or Port sultant participating in a competitive selec- Commissioners. A Former Consultant shall tion process or obtaining a Financial or Bene- avoid circumstances in which it might appear ficial Interest. to a reasonable person that the Former Con- sultant requesting or otherwise seeking or VI. REPORTING OTHER POTENTIAL receiving special consideration, treatment or VIOLATIONS advantage from other Port staff or Port Com- missioners. Consultants should report potential conflicts of interest, financial or otherwise, of any C. Appearances Before Commission Port employee or other Consultant who is in a For one (1) year after Termination of Port position to influence the selection, non- engagement, a Former Consultant may not selection, or conduct of business between the appear before the Port Commission on behalf Port and any entity. Reports should be made of another individual or entity, whether or to the Port Workplace Responsibility Helpline not for compensation of any kind, in relation (206.787.4357) or the Ethics & Compliance to any matter, issue, contract, case, pro- Hotline (1.877.571.5237). Consultants will ceeding, application or matter in which such not be retaliated against for reporting good Former Consultant participated in a deci- faith concerns or potential violations of this sion-making, negotiation, review, selection, policy. supervisory or other significant activity. For further information about this policy, By way of limited exception, the Commission please contact the Port Workplace Responsi- may waive this provision if so requested by a bility Helpline. Former Consultant and after public discussion and a finding by the Commission that the CC- 03 public or the Port’s interests would be better served. The Former Consultant must seek FORMER EMPLOYEE ETHICS application to participate in the proceeding at AND CONFLICT OF INTEREST least 14 days in advance of the Commission meeting. Such application shall be submitted Serving the Port Loyally in writing to the Central Procurement Office CC-3 as of 1.1.10 identifying all facts and the rationale for the appearance. I. THE PORT’S INTERESTS COME FIRST D. Participation in Contracts with the Port Former Employees of the Port of Seattle who A Former Consultant may not participate as are engaging in transactions with the Port a competitor in any competitive selection shall do so in an ethical manner and in accor- process, or have a direct or indirect Financial dance with this policy. The purpose of this or Beneficial Interest in any agreement, con- policy is to ensure that Port employees are not tract, concession, or lease that was made by, influenced in their decision-making and authorized or funded by Port action in which actions by the possibility of obtaining employ- the Former Consultant participated in a ment or other advantages with third parties decision-making, negotiation, review, prepa- after leaving the Port. It is also designed ration, selection, supervisory or other signifi- to ensure that Former Employees do not use cant activity. their prior position at the Port for special con- sideration or advantage. After one (1) year following Termination of 25 a Former Consultant’s Port engagement, the Port may waive this provision at its sole dis-WCOODREKOPFLAETCHEICCSO&DWEOORKFPCLAOCNEDCUONCDTUCT cretion. The Central Procurement Office, with the concurrence of the Workplace Responsi- bility Office, will make this determination. ETHICS & COMPLIANCE HOTLINE: 1.877.571.5237

26 II. EXPECTATIONS OF FORMER D. Participation in Competitive Selection EMPLOYEES Process For one (1) year after Termination ofWCOODREKOPFLAETCHEICCSO&DWEOORKFPCLAOCNEDCUONCDTUCT Port employment, a Former Employee may A. Special Consideration Prohibited not participate as a competitor in any compet- A Former Employee shall not request or other- itive selection process for a Port contract in wise seek special consideration, treatment or which the Former Employee participated in a advantage from other Port staff or Port Com- decision-making, negotiation, review, selec- missioners. A Former Employee shall avoid tion, supervisory or other significant activity circumstances which to a reasonable person in any way during his/her Port employment. might appear that the Former Employee is requesting or otherwise seeking or receiving E. Disclosure Requirements special consideration, treatment or advantage For one (1) year after Termination of Port em- from other Port staff or Port Commissioners. ployment, a Former Employee must disclose his or her past Port employment before B. Appearances Before Commission engaging or participating in any Port business For one (1) year after “Termination” of Port or activity. The disclosure shall be made in employment, a Former Employee may not ap- writing to the Port’s Workplace Responsibility pear before the Port Commission on behalf Office. of another individual or entity, whether or not for compensation of any kind, in relation to F. Use of Confidential Information any case, proceeding, application or matter in A Former Employee shall not disclose or use which such Former Employee participated in any Confidential Information gained by a decision-making, negotiation, review, selec- reason of his/her Port employment unless the tion, supervisory or other significant activity information is a matter of public knowledge during his/her period of Port employment. or is available to the public on request. See By way of limited exception, the Commission Employee Ethics & Conflict of Interest policy may waive this provision if so requested by for definition of “Confidential Information.” a Former Employee and after public discus- sion and a finding by the Commission that the G. Employment public or the Port’s interests would be better No Former Employee may accept an offer of served. For purposes of this policy, “Termina- employment or receive compensation from an tion” of employment is defined as the latest Employer if the Former Employee knows, has date for which the employee is receiving reason to believe, or the circumstances would any pay or benefits from the Port, even if the lead a reasonable person to believe, that the employee ceased to provide services to the offer of employment or compensation was Port earlier in time. Termination includes all intended, in whole or in part, directly or indi- voluntary and involuntary separations from rectly, to influence the Former Employee or as employment, regardless of the reason for the compensation or reward for the performance separation. or nonperformance of a duty by the Former Employee during his/her Port employment. C. Participation in Contracts For purposes of this policy, “Employer” means with Port of Seattle any person, partnership, association, corpora- For one (1) year after Termination of Port tion, firm, institution, or other entity, whether employment, a Former Employee may not or not operated for profit. have a direct or indirect Financial or Benefi- cial Interest in any contract that was made III. REPORTING CONCERNS OR VIOLATIONS by, authorized or funded by Port action in which the Former Employee participated in a All employees and Former Employees have a decision-making, negotiation, review, selec- responsibility for ensuring that this policy tion, supervisory or other significant activity is followed. Concerns or potential violations during his/her period of Port employment. should be reported to the Workplace Respon- “Financial or Beneficial Interest” is defined sibility Office, or anyone identified in the to include (a) a creditor, debtor or ownership “Reporting Concerns or Violations” policy. interest in an amount or value in excess Supervisors and managers will be held to a of $1,500; (b) any employee, consultant or higher level of responsibility with respect to partnership arrangement; or (c) any option reporting potential violations. Supervisors to purchase real or personal property. and managers who know of or receive reports ETHICS & COMPLIANCE HOTLINE: 1.877.571.5237

of potential violations must promptly report • Is this Gift a “reward” for a them to the Workplace Responsibility Office. business decision? Employees will not be retaliated against for reporting in good faith concerns or potential • Is this Gift excessive in value? violations of this policy. See “Reporting Concerns or Violations” policy for more detail. • W ould the public likely be concerned to find out I had received this Gift? For further information, please contact the If the answer to any of these questions is Workplace Responsibility Office. “yes,” or even unclear, then the Gift should not be accepted, regardless of its value. CC- 04 Gifts related to promotional hosting activ- CONDUCTING ALL PORT BUSINESS ities are covered under the Port’s Promotional WITH INTEGRITY AND RESPECT Hosting; Trade/Business and Community Development Expenses policy AC-4. If you Gifts and Hospitality have questions about how this policy applies CC-4 as of 1.1.10 in a given circumstance, please contact the Workplace Responsibility Office. ENSURING SOUND BUSINESS DECISIONS, AVOIDING UNDUE INFLUENCE II. SPECIFIC GUIDELINES REGARDING GIFTS 27 I. Statement of the Policy A. Solicitation of Gifts Prohibited The Port of Seattle’s policy is that gifts and An employee may not receive, accept, take,WCOODREKOPFLAETCHEICCSO&DWEOORKFPCLAOCNEDCUONCDTUCT hospitality should never influence imminent seek, or solicit, directly or indirectly, any Gift business decision-making processes or cause if it could be reasonably expected (or appear others to perceive that there is an influence. to a third party) that the Gift would influ- Employees may not solicit Gifts. The Port also ence the action or judgment of the employee, discourages employees from accepting Gifts or be considered as part of a reward for action from an actual or potential business partner. or inaction. If you have any question about The Port requires employees to follow this whether accepting a Gift would be improper, policy not only to protect the Port’s business please ask the Workplace Responsibility Office. reputation but also to protect employees from unfounded allegations of improper behavior. B. Gifts Accepted on Behalf of the Port A Port employee may accept a gift of any value A Gift is defined as anything of value that is as long as it is for, and on behalf of, the Port. received without any consideration provided Any Gift so accepted shall become the property in return. Hospitality is defined as services, of the Port and not of the employee. An Em- meals, entertainment, beverages, lodging, ployee shall report the acceptance of any Gift transportation, experiences, and other similar under this Section to the Workplace Respon- activities that are received without any con- sibility Office within thirty (30) days of receipt. sideration, or for consideration that is below the fair market value. For purposes of this pol- C. $50 Limit on Gifts icy, both gifts and hospitality will be referred Even if the acceptance of the Gift is not solicit- to collectively as “Gifts.” Any Gift given to ed and even if accepting the Gift would not an employee’s relative or guest shall be at- influence the employee’s action or inaction, tributed to the employee for purposes of this the Port believes it is appropriate to limit Gifts policy unless an independent business, to a $50 value. Thus, an employee may not family, or social relationship exists between accept a Gift for the employee’s benefit with the donor and the relative or guest. an aggregate value exceeding $50 from a sin- gle source in a calendar year. “Single source” Employees are encouraged to ask themselves means any person, vendor or business partner, the following questions when evaluating whether acting directly or through any agent Gifts: or other intermediary. In other words, one vendor may not provide an employee with more • If I accept this Gift, will I feel obligated than $50 worth of Gifts in a year, as it could to respond in some manner? appear to be an effort to influence decisions. ETHICS & COMPLIANCE HOTLINE: 1.877.571.5237

28 An employee also may not accept a single Gift • Occasional Gifts in the form of food and that may have been purchased by multiple beverage in the ordinary course of mealsWCOODREKOPFLAETCHEICCSO&DWEOORKFPCLAOCNEDCUONCDTUCT sources that has a value in excess of $50. where attendance by the employee is The term “single gift” includes any event, item related to the performance of official du- or group of items used in conjunction with ties. If you have a question about whether each other or any trip including transporta- attendance is related to official duties, tion, lodging, and attendant costs. For exam- please consult with the Workplace ple, an employee may not accept a Gift of a Responsibility Office. Gifts in the form of sports outing that has been paid for by several food and beverage that exceed $50 per vendors if the value exceeds $50, even if person on a single occasion shall be each contributing vendor spent less than $50 reported to the Workplace Responsibility toward the Gift. Office. “Occasional” means not more than four to six times per year with the same D. Exceptions to $50 Limit on Gifts business partner. The following Gifts are presumed not to influ- ence an employee’s action or non-action III. ITEMS NOT CONSIDERED GIFTS on any matter and may be accepted without regard to the $50 limit. However, in the event The following items are excluded from the that facts suggest that a Gift could influence definition of Gift and may be accepted by an a business decision, or create the appear- employee or Relative without constituting ance of influencing a business decision, then a violation of this policy. the Port may request that the Gift not be offered or accepted. • Items from family or friends where it is clear beyond a reasonable doubt that the • U nsolicited flowers, plants, and item was not given as part of any design floral arrangements to gain or maintain influence in the Port • U nsolicited advertising or promotional • Items related to the outside business of items of nominal value, such as pens a Port employee that are customary and note pads and not related to the employee’s perfor- mance of his/her official duties • U nsolicited items received by an employee for the purpose of evaluation or review, • Items exchanged among employees or if the employee has no Financial or between employees and Port Commis- Beneficial Interest (See Conflict of Inter- sioners, or a social event hosted or spon- est Policy for definition) in the eventual sored by an employee or Port Commis- use or acquisition of the item by the Port sioner for co-workers • Informational material, publications, • Payments by a governmental or nongov- or subscriptions related to the employee’s ernmental entity of reasonable expenses performance of official duties incurred in connection with a speech, pre- sentation, appearance, or trade mission • F ood and beverages consumed at hosted made in the employee’s official capacity. receptions where attendance is related “Reasonable expenses” are limited to to the employee’s official duties, including travel, lodging, and subsistence expenses admission to, and the costs of food and incurred the day before through the day beverages consumed at, events sponsored after the event. by or in conjunction with a civic, charita- ble, governmental, or community • Items an employee is authorized by law organization, provided that where the to accept, including, but not limited Gift exceeds $50 on a single occasion, to, items accepted in accordance with the it shall be reported to the Workplace Re- Port’s Promotional Hosting; Trade/Busi- sponsibility Office ness and Community Development Expenses policy AC–4Payment of enroll- • U nsolicited Gifts from dignitaries from ment and course fees and reasonable another state or a foreign country travel expenses attributable to attending and intended to be personal in nature seminars and educational programs spon- sored by a bona fide governmental or ETHICS & COMPLIANCE HOTLINE: 1.877.571.5237

nonprofit professional, educational, trade CC- 05 or charitable association or institution. “Reasonable expenses” are limited to FRAUD AWARENESS & PREVENTION travel, lodging, and subsistence expenses incurred the day before through the day Promoting Trust and Vigilance after the event. 30Gifts and Hospitality CC-5 as of 1.1.10 • Items returned by the employee to the I. STATEMENT OF THE POLICY donor within thirty (30) days of receipt or donated to a charitable organiz- The Port of Seattle serves the public. Every ation within thirty (30) days of receipt Port employee has a responsibility to earn and maintain the public’s trust by using taxpayer • C ampaign contributions reported resources wisely and preventing loss and under chapter 42.17 RCW fraud. The Port is committed to having a work atmosphere of fraud awareness, where its • D iscounts available to an employee as employees, interns and volunteers, are skilled a member of an employee group, occu- to identify potential fraudulent activity and pation, or similar broad-based group are supported when carrying out their respon- sibility to immediately report such activity. • A wards, prizes, scholarships, or other Every employee is expected to follow this poli- items provided in recognition of academic cy and to immediately report known or sus- or scientific achievement. Unsolicited pected loss of public funds or assets or “Fraud.” tokens or awards of appreciation in the form of a plaque, trophy, desk item, wall Fraud is a unique and particularly insidious memento or similar item. form of dishonesty that is being called out separately from the Port’s related Loss IV. REPORTING CONCERNS OR VIOLATIONS Prevention Policy (EX 18), to emphasize the seriousness of such acts. For purposes of this All employees have a responsibility for ensur- policy, the Port defines “Fraud” broadly. It ing that this policy is followed. Concerns or includes any act of deception that is, or could potential violations should be reported to the reasonably be expected to, result in personal Workplace Responsibility Office, or anyone gain. It includes any situation in which Port identified in the “Reporting Concerns or Vio- resources are diverted to an employee, or the lations” policy. Supervisors and managers employee’s Relative, friends, or associates, will be held to a higher level of responsibility without authorization, which may also include with respect to reporting potential violations. misappropriation. Fraud may exist whether Supervisors and managers who know of or there is actual harm to the Port or not. receive reports of potential violations must promptly report them to the Workplace The Port of Seattle has zero tolerance for Responsibility Office. Employees will not be Fraud. “Zero tolerance” means that complaints retaliated against for reporting in good faith of violations of this policy will be reviewed concerns or potential violations of this policy. and any violations will be addressed. The See “Reporting Concerns or Violations” proce- manner in which violations are addressed will dure. depend on the circumstances. Employees could be subject to progressive discipline up For further information, please contact the to and including immediate termination. Workplace Responsibility Office. Employees must report suspected violations of this policy. See “Reporting Complaints” policy for more detail. 29 “Relative” is defined to include an employee or a consultant’s spouse, domestic partner,WCOODREKOPFLAETCHEICCSO&DWEOORKFPCLAOCNEDCUONCDTUCT parents, children, cousins, nieces, nephews, grandparents, grandchildren, in-laws, and any person with whom the employee or con- sultant has a relationship that is substantially equivalent to any of these. ETHICS & COMPLIANCE HOTLINE: 1.877.571.5237

II. SPECIFIC PURPOSES OF THIS POLICY B. Fraud Response Committee The following is additional information about To ensure proper stewardship over public the investigation process and the Port’s Fraud funds and assets, and provide timely and Response Committee. The Port will gener- proper handling of any known or suspected ally follow the process outlined below. How- fraudulent activity ever, the Port reserves the right to take an approach that best suits the particular situa- T o comply with RCW 43.09.185, that requires tion and may not follow every step outlined State agencies and local governments to below in all cases. immediately report any known or suspected loss of public funds or assets to the State The Port’s Fraud Response Committee is com- Auditor’s Office (SAO) prised of the Deputy CEO, General Counsel, Chief Financial Officer and the Accounting To establish clear expectations and ensure and Financial Reporting Director. If any mem- consistent and timely action by the Port ber of the Committee has or reasonably be- lieves they may have a conflict with any mat- T o ensure that losses are minimized; ter, they shall immediately recuse themselves investigations and audits are not hampered; from any further participation in that matter. and bond claims are not jeopardized T he General Counsel or Workplace Responsi- III. WHAT AND HOW TO REPORT bility Office will respond to reports of sus- pected fraud received through the Ethics and Employees must report any irregularity that Compliance Hotline, and will forward such reasonably leads a Port employee to suspect reports to the Port Police. The Port Police will Fraud — regardless of amount or type. Early forward all reports of suspected fraud brought and vigilant reporting will allow the Port to to their direct attention to the General minimize losses by addressing matters be- Counsel and Senior Internal Audit Manager. fore they become larger issues. The reporting requirement also includes issues that have Following receipt of a report of Fraud, the occurred in the past but have only recently General Counsel shall advise the Commission become apparent. When in doubt, report. President and Chief Executive Officer. In Employees also should report suspicions of concert with the Port Police and the Senior Fraud even if the matter has been referred Internal Audit Manager, the General Counsel to law enforcement. Any Port employee who shall make preliminary inquiries and review becomes aware of or suspects Fraud shall im- relevant documents for the purpose of deter- mediately report this to the Ethics and Com- mining whether cause exists to pursue the pliance Hotline, the Port’s General Counsel, or matter further, either as an employment mat- the Workplace Responsibility Office — even if ter or as a civil matter to recover funds or it is also separately referred to the Port Police. assets. The General Counsel also may submit Employees will not be retaliated against for requests for additional information through reporting concerns or complaints of suspected the Ethics and Compliance Hotline process Fraud. See “Reporting Concerns or Violations” as necessary. The General Counsel then will policy. draft a written recommendation that the matter be pursued further or that the matter IV. INVESTIGATION PROCESS should be closed for lack of substantiation. The General Counsel may not interfere with A. Commitment to Review and Investigate any police investigation or any decision by the The Port will review and investigate concerns Port Police to refer a matter for prosecution. or complaints of Fraud, as outlined in the Port’s Reporting Concerns or Violations policy. Employees are expected to fully cooperate with, and avoid any actions that may impede an audit or investigation. 30 ETHICS & COMPLIANCE HOTLINE: 1.877.571.5237WCOODREKOPFLAETCHEICCSO&DWEOORKFPCLAOCNEDCUONCDTUCT

The General Counsel shall forward his or her Any Port employee in possession of or respon- recommendation to the Commission President, sible for relevant financial, operational and all the Chief Executive Officer and members of other records shall protect them from loss or the Fraud Response Committee. If the General destruction, and all original records related to Counsel recommends closing the matter, the the loss shall be secured in a safe place until Commission President, the Chief Executive a full audit/investigation has been completed. Officer, or any member of the Fraud Response Committee may request further review and For further information, please contact the the matter will be forwarded to the Fraud Workplace Responsibility Office. Response Committee. IIf the Fraud Response Committee determines CC- 06 that further action is necessary, the Committee will determine the appropriate next steps LOSS PREVENTION including establishing the scope of the inquiry and determining whether in-house resources Preventing Loss of Public Funds and Assets or outside consultants should be used to con- CC-6 as of 1.1.10 duct the review. I. STATEMENT OF THE POLICY T he Senior Internal Audit Manager, or retained The Port of Seattle serves the public. Every consultant as determined by the General Port employee has a responsibility to earn and Counsel or by the Fraud Response Committee, maintain the public’s trust by using taxpayer shall conduct an investigation to gather the resources wisely and preventing loss, whether facts, determine the nature of the irregularity, accidental or intentional. Every employee is and inform the General Counsel and/or Fraud expected to follow this policy and to immedi- Response Committee. ately report known or suspected loss of public funds or assets. See “Reporting Concerns A t the point it is suspected or known that a or Violations” policy for more detail. For con- Fraud has occurred, the Senior Internal Audit cerns about potential fraudulent activity, Manager shall immediately notify the SAO please refer also to the “Fraud Awareness and in accordance with RCW 43.09.185. Prevention” policy. T he General Counsel or the Fraud Response II. SPECIFIC PURPOSES OF THIS POLICY Committee shall recommend the appropriate next steps for disciplinary action and recovery • T o ensure proper stewardship over pub- of funds or assets, based on the Senior Inter- lic funds and assets, and provide timely nal Audit Manager’s or retained consultant’s and proper handling of any known or assessment and recommendations. Any suspected loss of such funds or assets recommended actions shall be implemented pursuant to applicable Port policies and pro- • To comply with RCW 43.09.185, that cedures. Any such recommendations shall requires State agencies and local govern- be coordinated with any ongoing criminal in- ments to immediately report any known vestigation. or suspected loss of public funds or assets to the State Auditor’s Office (SAO) T he Senior Internal Audit Manager shall notify the Risk Manager of all known and suspected • T o establish clear expectations and instances of fraudulent activity. The Risk ensure consistent and timely action by Manager, in coordination with General Coun- the Port sel, shall determine whether to file a claim against the Port’s employee dishonesty insur- • To ensure that losses are minimized, in- ance policy, considering the circumstances. vestigations and audits are not hampered, and bond claims are not jeopardized 31 ETHICS & COMPLIANCE HOTLINE: 1.877.571.5237CODE OF ETHICS & WORKPLACE CONDUCT

32 III. WHAT TO REPORT • R easonable inventory shortages identified during a physical count. These inventoryWCOODREKOPFLAETCHEICCSO&DWEOORKFPCLAOCNEDCUONCDTUCT The Port encourages reporting of losses. Early adjustments are to be recorded in the and vigilant reporting will allow the Port to accounting system and monitored accord- minimize losses by addressing matters before ingly. they become larger issues. Thus, employees must report any irregularity that reasonably For further information, please contact the leads a Port employee to suspect a loss of Port Workplace Responsibility Office. funds or assets, in accordance with this policy. This includes all suspected losses including CC- 07 losses resulting from unlawful activity such as theft and fraud—regardless of amount or type. INFORMATION SYSTEMS AND It also includes those that have occurred in SERVICES ACCEPTABLE USE POLICY the past but have only recently become appar- ent. When in doubt, report. See “Reporting Using Port Information Systems Concerns or Violations” policy. and Services Responsibly CC-7 as of September 2014 A. Required Reporting Original 1.1.2010 Port employees must report all suspected or known losses of Port funds and assets in I. STATEMENT OF THE POLICY accordance with this policy, subject to the ex- ceptions set out in Sections B and C below. The Port of Seattle is committed to providing This includes all suspected losses that have a work environment that encourages the use occurred in the past, but only recently become of information systems and services to sup- apparent. Reports should be made in the port our business objectives. The Port expects manner described in the “Reporting Concerns all authorized system users to use the Port’s or Violations” policy. information systems and services in a respon- sible and respectful manner. This policy is B. Materiality of Reportable Losses designed to help system users understand the A loss of a “de minimus” amount, defined as Port’s expectations and system user respon- under $50 (fifty dollars), may but need not be sibilities related to the use of the Port’s infor- reported. However, a pattern of suspected mation systems and services. recurring losses that may in aggregate exceed $50 must be reported. The full exposure to II. DEFINITIONS the Port can only be determined by a thorough investigation. However, any loss resulting a) “ System user” refers to anyone who has from suspected unlawful activity such as theft been authorized to use or access the and fraud must be reported regardless of the Port’s information systems and services. amount of the loss. System Users specifically include Port employees as well as none­ mployees, C. Losses That Generally such as Commissioners, interns, contrac- Need Not Be Reported tors, and vendors, who are authorized The following activities generally need not be to use or access information systems and reported, which is consistent with State Audi- services. System User does not, however, tor’s Office guidelines. However, those in include members of the public that leadership positions for the related operations use or access publicly available resourc- are responsible to monitor such activities for es (e.g., public wireless networks). unreasonable irregularities and take action in accordance with this policy as necessary b) “ Information systems and services” refer to Port-managed or Port-provided work- • N ormal and reasonable “over and short” stations, laptops, servers, network infra- situations from cash receipting operations. structure, peripherals (e.g., copiers These transactions are to be recorded and printers), mobile information devices in the accounting system as miscellane- (e.g.,mobile phones, smartphones, ous income and expense, respectively, portable digital assistants, tablets/pads, and monitored by cashier for any unusual etc.), telephones, faxes, Port-provided trends. software and applications, Port-provided ETHICS & COMPLIANCE HOTLINE: 1.877.571.5237

33 internet access and intranet services, IV. ACCEPTABLE USE as well as surveillance and monitoringWCOODREKOPFLAETCHEICCSO&DWEOORKFPCLAOCNEDCUONCDTUCT systems. Authorized uses of Port information systems and services include the following : c) “ Electronic communications” is defined under this policy as the electronic trans- a) Uses permitted under the Use of Port mission (internally or externally) of Equipment. Section 111. B of CC-1. data that has been encoded digitally, Employee Ethics and Conflict of Interest including, but not limited to, e-mail, policy and EX-20. Corporate Use of instant messaging/ chat, text messaging, Social Media policy; voice mail, file transfers [i.e., FTP or similar], internet browsing/searching, b) P ersonal use, provided that such person- download/installation of files or soft- al use does not interfere with or disrupt ware/applications. the Port’s business processes, the system user’s job productivity, or the normal III. NO RIGHT OR EXPECTATION OF PRIVACY operation of the Port and that such per- sonal use does not impose cost or fees a) T he Port makes information systems and on the Port or otherwise violate this policy; services available to system users to facilitate Port business. Although each c) U ses software/ applications in accor- system user may be provided a unique dance with license agreements. The user name and password to access the Port licenses the use of system software/ Port’s information systems and services, applications from a variety of vendors. these information systems and serv- Compatibility, vulnerabilities, mainte- ices are owned or managed by the Port. nance and licensing concerns should be considered prior to installing software/ b) S ystem users have no expectation or applications. The Port does not own most right of privacy regarding their use of the software/ applications or its related doc- Port’s information systems and services, umentation and, unless authorized by including any electronic communications the software/ application developer, does made with them. not have the right to reproduce it except for backup purposes. c) T he Port, at its discretion and without system user notification or permission, V. PROHIBITED USE may monitor, log, analyze or review a system user’s information systems and The following uses of the Port’s information services usage and activity, as well systems and services are prohibited: as electronic communications, whenever the Port deems such action necessary. a) A ny use that violates the law or Port poli- cies, including but not limited to CC-1, d) E lectronic communications and data Employee Ethics and Conflict of Interest related to Port activities are generally policy, CC-8, Anti-Harassment policy, subject to public disclosure under Wash- and EX-20, Corporate Use of Social Media ington’s Public Records Act. They may policy; also be subject to discovery in civil litigation in which the Port is involved. b) Creating, downloading, viewing, stor- ing, copying, or transmitting content that e) The Port is not responsible for any loss, is sexually explicit, sexually-oriented, modification, destruction, or mainte- criminal, or disparaging of others based nance of personal content saved or on their race, national origin, sex, sex- stored on Port information systems and ual orientation, age, disability, religion or services. The Port will not provide sup- political beliefs; port services of any kind related to personal content. If personal content is c) S oliciting, proselytizing, or advancing stored on Port information systems or personal political or religious inter- services, this content is specifically ests, commercial ventures, personal or subject to Public Disclosure, monitoring, outside causes, or engaging in other logging, analyzing, and review. similar, non-job-related solicitations; ETHICS & COMPLIANCE HOTLINE: 1.877.571.5237

d) Soliciting funds or services for charitable n) U se of surveillance systems for non- causes without prior written approval authorized or voyeuristic purposes, and/ from the Director of Human Resources or creating, posting or disseminating and Development; unauthorized surveillance video clips; e) Visiting or establishing websites/URLs o) U se of any Port information systems and that promote gambling, illegal weapons, services as a staging ground or platform violence or hate; to gain unauthorized access to the Port or other systems. Such uses include, but f) C opying, disseminating, or reproducing are not limited to, circumventing user information that has been authored authentication or security of any host, by others in violation of the applicable client, network, or account, effecting terms of use or without the express security breaches or disruptions, intro- permission of the author(s) or copyright duction of a malicious program into the holder(s); system, or executing any form of network monitoring which will intercept data not g) D ownloading or storing of Port sensitive intended for the user; information (e.g., Social Security Num- bers, HIPAA, CJIS, credit card numbers, VI. ADDITIONAL RESPONSIBILITIES etc.) on personal computers, removable OF SYSTEM USERS media, or portable devices; a) T he system user must review and con- h) S toring credit card numbers on any sent to this policy PRIOR to access being Port information systems or services granted to Port information systems except as specifically approved by ICT and services. System users that do not Senior Manager, Information Security; consent are not authorized users; i) T ransmitting or extracting Port infor- b) System users must apply software up- mation without authorization or business dates, patches and versions as required justification; by ICT; j) Gaining access to Port information sys- c) System users must use caution to avoid tems and services by using any ac- the introduction of computer viruses cess-control mechanism not assigned to or other destructive and malicious files the particular user (“impersonating”), or or programs; permitting another person to have access by sharing one’s Port credentials and d) S ystem users that are authorized to use passwords; their personal computers to gain access to Port information systems and services k) A ttempting to bypass, defeat, strain via a form of authorized remote-access or test any security mechanisms of any (e.g., Outlook Web Access/OWA}, must information system or service. If sec- maintain and apply current antivirus urity mechanisms must be bypassed for software and security-related software/ any reason, they must be approved in application updates on their computer; advance by contacting the ICT Service Desk; e) S ystem users may require user creden- tials (user id and password) or other I) Introducing destructive software/applica- access-control tools to gain access to in- tions or programs such as computer formation systems and services. These viruses, Trojan horses, or worms , adware, tools and credentials (e.g., passwords) spyware, keystroke-loggers, root kits, are not to be shared with anyone, includ- hacking tools, or other malware, etc. ing the Service Desk, co-workers, admin- into the Port’s information systems and istrative staff or managers; services; 34 m) U sing systems or technology that dis-WCOODREKOPFLAETCHEICCSO&DWEOORKFPCLAOCNEDCUONCDTUCT guises or alters the identifying informa- tion of the computer or system user, such as external proxies or anonymizer sites, for any purpose; ETHICS & COMPLIANCE HOTLINE: 1.877.571.5237

f) S ystem users must use secure transmis- VIII. EXCEPTIONS sion methods (e.g., encryption, secure FTP, etc.) when sending sensitive infor- Any exceptions to this policy must be mation (e.g., Personally Identifiable requested through the ICT Service Desk Information, ePHI, system information, (206.787.3333) and explicitly approved vulnerability/risk information, etc.). in writing by the ICT Senior Manager, For transmission options, please contact Information Security. the ICT Service Desk (206.787.3333). The ICT website also has an extensive list For further information, please contact the of sensitive information examples; ICT Senior Manager, Information Security or the Workplace Responsibility Helpline g) S ystem users who believe their pass- (206.787.HELP). words or any access-control tools have been compromised must immediately CC- 08 change their passwords and notify the ICT Service Desk (206.787.3333); ANTI-HARASSMENT h) S ystem users who believe an information Fostering a Respectful Workplace system has been lost or stolen must CC-8 as of 1.1.10 immediately notify the ICT Service Desk (206.787.3333) and file a report with the I. UNLAWFUL HARASSMENT WILL local police department (which may be NOT BE TOLERATED the Port Police Department) . The system user must provide the Police report The Port of Seattle is committed to providing number to the ICT Service Desk once re- a respectful, supportive and productive work- ceived. place for all employees that is free of verbal, physical and visual forms of unlawful harass- i) S ystem users must immediately report ment. One of the Port of Seattle’s core values any recovery of a lost or stolen system is treating co-workers, customers, contrac- to the ICT Service Desk (206.787.3333); tors, vendors and community members with respect. Consistent with that value, the Port j) S ystem users may not introduce wireless of Seattle does not tolerate unlawful harass- access points/ networks or modems, elec- ment in the workplace. tronic equipment or devices anywhere on the Port network. Any such needs must Unlawful harassment refers to behavior that be requested and approved in advance by is not welcome, that is personally offensive, contacting the ICT Service Desk. that debilitates morale, and interferes with work effectiveness. It includes, but is not VII. REPORTING CONCERNS OR VIOLATIONS necessarily limited to, unwelcome verbal or physical conduct that is derogatory of an System users are required to report all suspect- employee because of their age, race, color, ed security and/or policy violations as outlined national origin/ancestry, religion, disability, in CC-14, Reporting Concerns or Violations Family Medical Leave Act (FMLA) use, policy. System users will not be retaliated pregnancy, sex/gender, sexual orientation, against for the good-faith reporting of con- whistleblower status, marital status, military cerns about, or potential violations of, this status, use of workers’ compensation, policy. transgender status, political beliefs, or any other category protected by law (“Protected Violation of this policy may result in disci- Status”). Not all disrespectful activity rises plinary action, including reduction or termina- to a level of severity and pervasiveness that tion of access, termination of employment, would be considered unlawful harassment. and/or referral of the system user to law However, the Port strives to eliminate all enforcement authorities for local, state and disrespectful conduct from the workplace. federal offenses. 35 ETHICS & COMPLIANCE HOTLINE: 1.877.571.5237WCOODREKOPFLAETCHEICCSO&DWEOORKFPCLAOCNEDCUONCDTUCT

The Port does not tolerate unlawful harass- • S ubmission to such conduct is made ment or disrespectful conduct in the work- either explicitly or implicitly a term or place. This policy also applies to business- condition of employment (such as related activities that take place outside promotion, training, overtime assignment, of the workplace, such as business-related leave of absence) trips, meetings and social events. The Port also will not tolerate unlawful harassment or • Submission to, or rejection of, such con- disrespectful conduct of any of its employ- duct affects employment opportunities ees by non-employees (including customers, visitors, and independent contractors). • The conduct interferes with an employee’s work or creates an intimidating, hostile or The Port has a “zero tolerance” policy concern- offensive work environment ing harassment. “Zero tolerance” means complaints will be reviewed and violations of Sexual harassment includes harassment this policy will be addressed. Offending be- based on another person’s gender, gender havior will not be permitted to continue or be identity, sexual orientation or harassment repeated. The manner in which violations are based upon pregnancy, childbirth, or related addressed will depend on the circumstances. medical conditions. It also can include Employees could be subject to progressive harassment of another employee who is the discipline up to and including immediate ter- same gender as the harasser. mination. Examples of sexual harassment include, II. HARASSMENT DEFINED but are not limited to: Prohibited harassment may take many forms, • O ffering or conditioning an employment from passing along cartoons to actual physi- benefit, like a raise, a promotion or a cal violence. We provide the following exam- special job assignment, in exchange for ples of what may be considered harassment. sexual favors Nonsexual harassment based on race, nat- • T hreatening or taking a negative employ- ional origin, religion, marital status, sexual ment action (such as termination, demo- orientation, gender identity, age, disability tion, denial of a leave of absence), or (or other protected status) can include the fol- changing performance expectations, after lowing: an employee has turned down a sexual advance • D isplaying or circulating in any manner pictures, objects, or written materials • U nwelcome sexual advances, like requests (including graffiti, cartoons, photographs, for dates or propositions for sexual favors posters, pinups, calendars, magazines, figurines, novelty items) that demean or • Excessive, one-sided, romantic attention show hostility to a person because of the in the form of requests for dates, love person’s Protected Status letters, telephone calls, e-mails or gifts • V erbal conduct, including making or using • V isual or physical conduct, like unwelcome derogatory comments, bullying, epithets, staring, leering, making sexual gestures, slurs and jokes towards such groups whistling or individuals based on Protected Status • D isplaying or circulating in any manner • A sking unwelcome questions or making and/or through e-mail, voice mail or unwelcome comments about another other electronic means pictures, objects, person’s Protected Status or written materials (including graffiti, cartoons, photographs, poster, pinups, Sexual harassment is generally defined as calendars, magazines, figurines, novelty unwelcome sexual advances, requests for sex- items) that are sexually suggestive ual favors, or other visual, verbal or physical conduct of a sexual nature when: • Verbal conduct, like making or using derogatory comments, epithets, slurs, teasing and jokes of a sexual nature 36 ETHICS & COMPLIANCE HOTLINE: 1.877.571.5237WCOODREKOPFLAETCHEICCSO&DWEOORKFPCLAOCNEDCUONCDTUCT

• Graphic verbal or written comments Supervisors and managers will be held to a (including e-mails or other electronic higher level of responsibility with respect documents) about an individual’s to reporting potential violations. Supervisors sex life or body and managers who know of, or receive, reports or complaints of offending behavior • S exually degrading words used to must promptly report them to the Director describe an individual of Human Resources and Development. See “Reporting Concerns or Violations” policy • S uggestive or obscene letters, e-mails, for more detail. notes or invitations V. THE PORT’S COMMITMENT • A sking unwelcome questions or making TO INVESTIGATE AND ACT unwelcome comments about another person’s sexual activities, dating, person- The Port will promptly and thoroughly investi- al or intimate relationships gate all claims of harassment. Complaints will be handled with sensitivity, discretion and • U nwelcome intentional touching of confidentiality to the extent allowed by the cir- another person or other unwanted inten- cumstances and the law. Please see “Reporting tional physical contact (including patting, Concerns or Violations” policy for more detail. pinching, shoulder rubs, brushing up against another person’s body, or imped- If the Port concludes that unlawful harass- ing or blocking movements) ment occurred, prompt and effective remedial action will be taken. This may include disci- III. YOUR RESPONSIBILITIES pline of the harasser and other actions to remedy the effects of the harassment and pre- The Port is committed to taking reasonable vent further harassment. No action will be steps to prevent harassment from occurring taken against any employee who in good faith and will take immediate and appropriate action files a complaint of harassment or assists in when it knows that unlawful harassment has the investigation of such a complaint. occurred. To do this, however, the Port needs the cooperation of all employees at all levels. VI. NO RETALIATION All Port employees are responsible for keeping our work environment free of harassment. IV. WHAT TO DO IF YOU SUSPECT This policy is also violated if an employee is HARASSMENT fired, denied a job, subjected to negative performance feedback or denied some other Harassment, particularly sexual harassment, employment benefit because the employee is often difficult to define. Misconceptions in good faith complained about harassment, abound and people tend to have different or assisted in an investigation of harassment. notions of what is appropriate conduct and what is not. Employees should never tolerate Employees who believe they have been retali- inappropriate behavior. The Port encourages ated against for having reported harassment employees who are uncomfortable with an or participated in an investigation should interaction to make their feelings known to promptly report it to the Director of Human the offending employee, if they are comfort- Resources and Development or anyone identi- able doing so. If the behavior does not stop, fied in the “Reporting Concerns or Violations” or if the employee is not comfortable with policy so that such concerns can be investi- this approach, then the employee should im- gated. Supervisors and managers will be held mediately report the concern to the Director to a higher level of responsibility with respect of Human Resources and Development or to reporting potential retaliation. Supervisors anyone identified in the “Reporting Concerns and managers who know of or receive reports or Violations” policy. of potential retaliation must promptly report them to the Director of Human Resources and Development. See “Reporting Concerns or Violations” policy for more detail. 37 ETHICS & COMPLIANCE HOTLINE: 1.877.571.5237WCOODREKOPFLAETCHEICCSO&DWEOORKFPCLAOCNEDCUONCDTUCT

Employees who are found to have engaged ers concerning the employee’s condition, in retaliation could be subject to progressive its impact on the employee’s ability to perform discipline up to and including immediate job functions, and possible reasonable ac- termination. commodations. Please see the Port’s Disability Management policy for more information. For further information, please contact the Di- rector of Human Resources and Development. The Port also generally will offer reasonable accommodation for an employee’s sincerely CC- 09 held religious belief that conflicts with a workplace rule, unless doing so would create EQUAL OPPORTUNITY an undue hardship. Ensuring Non-Discrimination and Employees who want to request accommoda- Reasonable Accommodation tion of a disability or religious belief should CC-9 as of 1.1.10 contact the Director of Human Resources and Development. The Port will evaluate requests I. THE PORT’S COMMITMENT TO EQUAL consistent with current legal requirements. EMPLOYMENT OPPORTUNITY III. COMMITMENT TO INCLUSION The Port of Seattle is an equal employment opportunity employer. The Port embraces, and The Port expects its employees to embrace a in fact relies on, having a diverse workforce. higher standard of nondiscrimination and Every employee has the right to work in inclusion than simply not discriminating and surroundings that are free from all forms of harassing others based on Protected Status. unlawful employment discrimination. The It expects all employees to be tolerant and Port will not engage in, or tolerate, any accepting of our individual differences, to discrimination in the workplace prohibited avoid stereotyping others with whom we inter- by local, state or federal law. Specifically, no act both at the Port and in the broader com- employee will be discriminated against on the munity based on protected characteristics and basis of his or her age, race, color, national to treat others with respect. Disrespectful origin/ancestry, religion, disability, Family treatment by Port employees of our custom- Medical Leave Act (FMLA) use, pregnancy, ers or members of the public is not consistent sex, gender identity, sexual orientation, with the Port’s values and will not be condoned. whistleblower status, marital status, military status, use of workers’ compensation, IV. REPORTING CONCERNS OR VIOLATIONS transgender status, political beliefs, or any other category protected by applicable federal, All employees have a responsibility for ensur- state or local law (“Protected Status”). ing that this policy is followed. Concerns or potential violations should be reported to the II. REASONABLE ACCOMMODATION Director of Human Resources and Develop- OF DISABILITIES AND RELIGION ment, or anyone identified in the “Reporting Concerns or Violations” policy, even if the The Port recognizes that employees with alleged improper conduct happened to some- physical or mental disabilities may need rea- one else. Supervisors and managers will be sonable accommodations to enable them held to a higher level of responsibility with re- to perform their essential job functions. spect to reporting potential violations. Super- The need for accommodations is determined visors and managers who know of or receive on a case by case basis. Generally the Port reports of potential violations must promptly and the employee will work together in an in- report them to the Director of Human Re- teractive process to identify possible accom- sources and Development. Employees will modations. The employee has an obligation to not be retaliated against for reporting in good cooperate with the Port in this process, which faith potential violations of this policy. See may include authorizing the Port to commun- “Reporting Concerns or Violations” policy for icate with the employee’s health care provid- more detail. 38 ETHICS & COMPLIANCE HOTLINE: 1.877.571.5237WCOODREKOPFLAETCHEICCSO&DWEOORKFPCLAOCNEDCUONCDTUCT

For further information, please contact the Di- II. DUTY TO REPORT DANGEROUS SITUATIONS rector of Human Resources and Development. Port employees should report any potentially CC- 10 dangerous situation immediately to a super- visor or the Director of Human Resources and WORKPLACE VIOLENCE Development. While the Port does not expect employees to be skilled at identifying poten- Promoting a Safe Work Environment tially dangerous persons, employees are CC-10 as of 1.1.10 expected to exercise good judgment and to inform his or her supervisor or the Director of I. WORKPLACE THREATS AND VIOLENCE Human Resources and Development of co- WILL NOT BE TOLERATED worker behavior which could cause concerns. Examples include: The Port of Seattle is committed to maintain- ing a safe and efficient working environment • Discussing ammunition, weapons, or vio- where employees and the public are free from lent activity in such a manner that causes the threat of violence. one to reasonably believe that the em- ployee could pose a risk to the workplace The Port also supports a proactive approach in identifying potential threats and preventing • Bringing weapons or ammunition into the workplace violence. workplace, unless specifically authorized in connection with the performance of The Port does not tolerate any type of work- Port duties (i.e., law enforcement, wildlife place violence committed by or against management, and other like positions) employees. Employees are prohibited from making threats or engaging in violent activi- • Displaying overt signs of extreme ties. The following behavior, while not an stress, resentment, hostility or anger exhaustive list, provides examples of conduct that is prohibited. • Making threatening remarks • Causing physical injury to another person • S udden or significant deterioration of performance • Making threatening remarks • D isplaying irrational or inappropriate • A ggressive or hostile behavior that cre- behavior ates a reasonable fear of injury to another person or subjects another individual to Employees who have concerns about domes- emotional distress tic violence (either their own situation or a co-worker’s situation) are urged to contact the • Intentionally damaging Port property Director of Human or property of another employee Resources and Development so that HRD • Possession of ammunition, a firearm, professionals can work with such employees weapon or other item intended to be used to evaluate risks and minimize risk to the as a weapon on Port property or while on workplace. Port business, unless specifically autho- rized in connection with the perform- Employees who encounter a threatening per- ance of Port duties (i.e. law enforcement, son should not attempt to challenge or dis- wildlife management, and other like posi- arm that individual. Employees should remain tions) calm, keep constant eye contact and talk to the individual. If a supervisor can be safely • C ommitting acts motivated by, or related notified of the need for assistance without en- to, unlawful harassment or domestic dangering the safety of the employee or oth- violence ers, such notice should be given. Alternatively, if possible, call 911. 39 ETHICS & COMPLIANCE HOTLINE: 1.877.571.5237WCOODREKOPFLAETCHEICCSO&DWEOORKFPCLAOCNEDCUONCDTUCT

III. THE PORT’S COMMITMENT Port of Seattle employees are strictly prohib- TO INVESTIGATE AND ACT ited from possessing, selling, or being under the influence of illegal drugs and misused The Port will promptly and thoroughly investi- prescription medications or other controlled gate all reports of workplace violence. Reports substances while on the job, during work will be handled with sensitivity, discretion hours, in company vehicles or in any other and confidentiality to the extent allowed by manner that may affect the employee’s work the circumstances and the law. Please see performance or the Port’s interests. Any “Reporting Concerns or Violations” policy for employee who is taking a prescription medi- more detail. Any employee determined to have cation should determine from his or her physi- engaged in workplace violence will be sub- cian or pharmacist whether the prescription ject to disciplinary action, up to and including drug could impair his or her ability to perform termination. the job safely and effectively. If the employ- ee’s performance may be so impaired, he or IV. REPORTING VIOLATIONS OF THIS POLICY she should advise his or her supervisor so that reasonable accommodations can be consid- All employees have a responsibility for ensur- ered. ing that this policy is followed. Concerns or potential violations should be reported to the The Port may permit the moderate consump- Director of Human Resources and Develop- tion of alcohol at Port-sponsored events. ment, or anyone identified in the “Reporting Even when alcohol is available at such events, Concerns or Violations” policy. Supervisors employees are expected to conduct them- and managers will be held to a higher level of selves in a professional manner and only con- responsibility with respect to reporting poten- sume moderate amounts so that their be- tial violations. Supervisors and managers who havior is appropriate and does not create a know of or receive reports of potential viola- possible risk to the health or safety of the tions must promptly report them to the Direc- employee or others nor a risk of harm to the tor of Human Resources and Development. Port’s interests. Employees will not be retaliated against for reporting in good faith concerns or potential Employees are strictly prohibited from being violations of this policy. See “Reporting impaired by the use of alcohol while on the Concerns or Violations” policy for more detail. job, during work hours, in company vehicles or in any other manner that may affect the For further information, please contact the Di- employee’s work performance or the Port’s rector of Human Resources and Development. interests. CC- 11 Any employee experiencing difficulties with drugs or alcohol is encouraged to contact the SUBSTANCE ABUSE Port’s Employee Assistance Program or Human Resources before the drug or alcohol issue Promoting Personal Health and Safety affects his/her work performance. Human CC-11 as of 1.1.10 Resources and Development can provide refer- rals to helpful resources. I. STATEMENT OF THE POLICY To ensure compliance with this policy, the Use of alcohol or drugs is a serious threat to Company may require drug and alcohol test- personal health, workplace safety and job ing at its discretion. This includes testing performance. Moreover, maintaining a drug- based upon reasonable suspicion, where man- free workplace is essential to the Port’s ability agement personnel reasonably suspect that to deliver quality work and service, to the an employee may be under any influence of Port’s image with customers and the public, drugs or alcohol, or is otherwise violating this and to the Port’s ability to maintain federal policy. funding for Port projects. 40 ETHICS & COMPLIANCE HOTLINE: 1.877.571.5237WCOODREKOPFLAETCHEICCSO&DWEOORKFPCLAOCNEDCUONCDTUCT

II. REPORTING CONCERNS OR VIOLATIONS Test results are handled as confidential re- cords, and provided only to those with a need All employees have a responsibility for en- to know the information. suring that this policy is followed. Employees should report to the Director of Human Re- For further information, please contact the Di- sources and Development, or anyone identi- rector of Human Resources and Development. fied in the “Reporting Concerns or Violations” policy, potential violations of this policy or CC- 12 any other situation in which you reasonably believe that an employee’s use of alcohol EMPLOYMENT OF RELATIVES or drugs could be impacting the employee’s ability to safely do the job. See “Reporting Avoiding the Appearance of Favoritism Concerns or Violations” policy. CC-12 as of 1.1.10 Supervisors and managers will be held to I. STATEMENT OF THE POLICY a higher level of responsibility with respect to reporting potential violations and also with The Port of Seattle believes it is in the Port’s respect to identifying and reporting situa- best interests to keep business and profession- tions in which an employee’s use of alcohol al relationships separate from personal and or drugs could be impacting the employee’s family relationships, wherever possible. To ability to safely do the job. Supervisors and prevent real or perceived conflicts of interest managers who know of, or receive, reports or favoritism, the Port provides the following of offending behavior must promptly report guidelines. them to the Director of Human Resources and Development. Employees will not be retaliat- “Relative” is defined to include an employee ed against for reporting suspected violations or a consultant’s spouse, domestic partner, of this policy. See “Reporting Concerns or parents, children, cousins, nieces, nephews, Violations” policy. grandparents, grandchildren, in-laws, and any person with whom the employee or con- III. THE PORT’S COMMITMENT sultant has a relationship that is substantially TO INVESTIGATE AND ACT equivalent to any of the above. The Port will promptly and thoroughly investi- When there will be employment of an employ- gate all reports of violation of this policy. ee or consultant’s Relative such employment Complaints will be handled with sensitivity, will only occur where: discretion and confidentiality to the extent allowed by the circumstances and the law. • Neither will supervise, appoint, Please see “Reporting Concerns or Violations” remove or discipline the other policy for more detail. The Port will impose disciplinary action, up to an including termi- • N either will evaluate or audit the nation of employment, in the event of any of work of the other the following: • The employment relationship will 1. Violation of this policy not create a conflict of interest or the appearance of favoritism 2. A positive test result When there will be an engagement of an 3. R efusal or failure to submit to employee or consultant’s Relative as a consul- testing when requested to do so tant, such engagement will only occur where: 4. Refusal to cooperate in the • Neither the employee nor consultant testing process shall evaluate or audit the work of the Relative and vice versa 5. A dulteration of any sample or tampering with any part of the testing process • N either the employee nor the consultant shall approve of payment for the Relative 41 ETHICS & COMPLIANCE HOTLINE: 1.877.571.5237WCOODREKOPFLAETCHEICCSO&DWEOORKFPCLAOCNEDCUONCDTUCT

• T he business relationship will not create concludes that it is the best approach under a conflict of interest or the appearance of the circumstances to avoid real or perceived favoritism conflicts of interest. II. CANDIDATES FOR POSITIONS IV. REPORTING CONCERNS OR VIOLATIONS Port employees and consultants should not be All employees have a responsibility for involved in any way with a Relative’s candida- ensuring that this policy is followed. cy for employment. Even recommending a Relative for employment could be perceived, Concerns or potential violations should or experienced, as undue pressure by the hir- be reported to the Director of Human ing team. To make such a recommendation carries an inherent conflict of interest. The Resources and Development, or anyone iden- higher level the position of the employee who tified in the “Reporting Concerns or Viola- recommends a Relative for employment, the tions” policy. Supervisors and managers will greater the risk of real or perceived pressure be held to a higher level of responsibility to hire the Relative. Thus, an employee’s with respect to reporting potential violations. failure to follow this policy could subject an Supervisors and managers who know of or employee to discipline up to and including receive reports of potential violations must termination. A consultant’s failure to follow promptly report them to the Director of Hu- this policy could lead to termination of the man Resources and Development. Employees consultant’s business engagement with the will not be retaliated against for reporting Port. in good faith concerns or potential violations of this policy. See “Reporting Concerns or When a Relative of a Port employee is a candi- Violations” policy for more detail. date for a Port position, the candidate shall be judged the same as other applicants, based For further information, please contact the Di- on his/her individual qualifications, without rector of Human Resources and Development. influence from Relatives who are already em- ployed. Any interference or influence exerted CC- 13 by a Port employee regarding employment, compensation, or working conditions of his or POLITICAL ACTIVITIES her Relative could disqualify the candidate from employment and could be considered a Responsible Personal Participation violation of this policy. CC-13 as of 1.1.10 The Port also reserves the right not to employ I. STATEMENT OF THE POLICY Relatives of high-level employees of its com- petitors or major vendors where such a re- Employees are encouraged to take an active striction is a reasonable step towards avoiding individual interest in political activities pro- the actuality or appearance of a conflict of vided that participation does not give the im- interest or to protect confidential information. pression employees are representing the Port. 42 III. EMPLOYEES WHO BECOME RELATED Employees are encouraged to participate in the affairs of government. In doing so, theWCOODREKOPFLAETCHEICCSO&DWEOORKFPCLAOCNEDCUONCDTUCT If two employees become related (typically by following guidelines should be considered: marriage or a relationship substantially sim- ilar), and their continued employment might • Employees should not use Port equipment create a conflict of interest or the appearance or facilities for the benefit of a political of favoritism, one of the employees may be campaign. transferred to another open position consistent with the employee’s skills, change supervisory • Intelligent participation requires knowl- authority, or provided alternate assignments edge and understanding of government, that remove the potential for a conflict of in- candidates, and issues. Employees are terest. The Port reserves the right to terminate urged to become informed through indi- the employment of an employee if the Port vidual and group study. ETHICS & COMPLIANCE HOTLINE: 1.877.571.5237

• P articipation must be of the employee’s Port employees should report, without fear own volition and on their own time. of retaliation, any matter which they believe could constitute a violation of the Port’s Work- • P ersonal beliefs should not be communi- place Responsibility policies or other improper cated in any manner that could cause governmental activity. This policy outlines another to construe such beliefs as offi- the steps that the Port generally will take to cial Port endorsement of any particular review and investigate concerns and com- candidate or issue. plaints. This policy also sets forth the Port’s commitment to ensuring that employees Port employees are not obligated to endorse who make reports in good faith, or who parti- or contribute funds or time to any Port Com- cipate in investigations, do not experience mission candidate. Port employees choosing retaliation. This protection extends to employ- to support a Port Commission candidate ees who report concerns of alleged improper must do so on their own time, using non-Port governmental activity, commonly referred to facilities and equipment. as “whistleblowers.” II. REPORTING CONCERNS OR VIOLATIONS Workplace Responsibility/ Code of Conduct Policies: All employees have a responsibility for ensuring that this policy is followed. • E mployee Ethics and Conflicts of Interest Concerns or potential violations should be reported to the Workplace • Consultant Ethics and Conflicts of Interest Responsibility Office, or anyone identified in the “Reporting Concerns or Violations” policy. • F ormer Employee Ethics Supervisors and managers will be held to a and Conflicts of Interest higher level of responsibility with respect to reporting potential violations. Supervisors • Gifts and Hospitality and managers who know of or receive reports or complaints of potential violations must • Fraud Awareness and Prevention promptly report them to the Workplace Responsibility Office. Employees will not be • Loss Prevention retaliated against for reporting in good faith concerns or potential violations of this • Information Systems and Services policy. See “Reporting Concerns or Violations” policy for more detail. • Anti-Harassment For further information, please contact the • Equal Opportunity Workplace Responsibility Office. • Violence in the Workplace CC- 14 • Substance Abuse REPORTING CONCERNS OR VIOLATIONS • Employment of Relatives Ensuring Compliance with • Political Activities Workplace Responsibility Policies CC-14 as of 1.1.10 II. EXPECTATIONS OF SUPERVISORS AND MANAGERS I. EACH EMPLOYEE’S ROLE IN COMPLIANCE All employees have a responsibility for ensur- The Port of Seattle is committed to reviewing ing that each of the Workplace Responsibility/ concerns and investigating potential viola- Code of Conduct policies is followed. Super- tions of its Workplace Responsibility policies, visors and managers will be held to a higher as well as concerns that the Port has engaged level of responsibility with respect to reporting in improper governmental activity. potential violations of the policies described above. Supervisors and managers who know of or receive reports or complaints of offending behavior must promptly report. 43 ETHICS & COMPLIANCE HOTLINE: 1.877.571.5237WCOODREKOPFLAETCHEICCSO&DWEOORKFPCLAOCNEDCUONCDTUCT

III. HOW TO REPORT Employees who believe they have been retali- ated against for having made a complaint or To report a concern or potential violation participated in an investigation must promptly employees should contact any one of the notify any one of the resources listed in following: Section III of this policy so that such concerns can be investigated. Appropriate corrective • Workplace Responsibility Office measures will be taken if allegations o retalia- tion are substantiated. • General Counsel VI. THE INVESTIGATION PROCESS • D irector of Human Resources and Development The Port will promptly and thoroughly review all reported concerns and alleged viola- • E thics & Compliance Hotline: tions of its Workplace Responsibility policies. 1.877.571.5237, 24 hours a day, Reports will be handled with sensitivity, 7 days a week discretion and confidentiality to the extent allowed by the circumstances and the law. An employee who reports his/her own im- Generally this means that details are shared proper action does not automatically receive only with those who have a need to know so immunity from disciplinary action. However, that the Port can conduct an effective investi- the fact that an employee voluntarily reports gation. his or her own possible policy violations may be favorably considered when evaluating There may be a preliminary investigation to disciplinary action. determine whether the concern or allegation constitutes a potential policy violation, as a IV. CONFIDENTIALITY rational and legitimate explanation may exist for the reported activity. If a full investiga- Except as necessary to facilitate a thorough tion is deemed appropriate, decisions will be investigation, any person within the Port re- made about whether to conduct internally or ceiving information about a concern or poten- by retaining an outside investigator. The tial violation of a Workplace Responsibility Port will conduct the investigation as swiftly policy shall keep all information received as as feasible. confidential as possible. This includes the names of the persons involved and the nature The reporting employee typically will be of the concerns or violations. requested to provide relevant details, such as the dates(s), location(s), names(s) of witness- V. NO RETALIATION es, or information about the alleged improper actor(s)/action(s). Other persons with rele- No retaliatory action will be taken against any vant information may be interviewed as need- employee who in good faith reports a concern ed. During the investigation, steps may be or potential violation of a Workplace Respon- taken, when appropriate, to minimize con- sibility policy, or Reporting Concerns or tact between the reporting employee and the Violations who assists in the investigation of alleged improper actor. In the case of har- one. The Port’s commitment to non-retaliation assment allegations, changes may include includes protection of those employees who schedule changes, temporary transfers or report complaints of alleged improper govern- investigatory leave, usually for the alleged ha- mental activity, commonly referred to as rasser. “whistleblowers.” After the investigation is completed, the Port Employees are prohibited from using their generally will discuss its findings with the official authority or position to prevent or in- reporting employee, the alleged improper terfere with an employee reporting violations actor, and possibly others directly concerned of Workplace Responsibility policies. with the matter. 44 ETHICS & COMPLIANCE HOTLINE: 1.877.571.5237WCOODREKOPFLAETCHEICCSO&DWEOORKFPCLAOCNEDCUONCDTUCT

If the Port concludes that a policy violation occurred, prompt and effective remedial action will be taken. This may include discipline of the improper actor(s) and other actions to remedy the effects of the violation and to pre- vent further violations. The Port also will be responsible for fulfilling other statutory reporting requirements that may be necessary, including those required by the Washington State Auditor’s Office. For further information, please contact the Workplace Responsibility Office. 45 ETHICS & COMPLIANCE HOTLINE: 1.877.571.5237WCOODREKOPFLAETCHEICCSO&DWEOORKFPCLAOCNEDCUONCDTUCT

Where a sustainable world is headed™.PORT OF SEATTLECOMMISSIONERSTom AlbroStephanie BowmanJohn CreightonFred FellemanCourtney GregoireCHIEF EXECUTIVE OFFICERTed J. FickGENERAL COUNSEL/CHIEF COMPLIANCEOFFICER Craig WatsonPort of SeattleP.O. Box 12009Seattle, WA 98111 U.S.A.206.787.3000www.portseattle.orgPhotographyDon WilsonThe Port of Seattle operates underthe State of Washington’s PublicDisclosure Act.To obtain public records visithttp://bit.ly/pr-requestsor call 206.787.4141. Printed on recycled paper with vegetable-based inksPrint date: 12/29/2016