Code of Conduct CONTENTS

Contents GLOSSARY

NAVIGATING THIS DOCUMENT Click on a title in the Contents to go directly to that topic.

Click on a burgundy hyperlink within the document to either go to the Glossary/Definitions, or to the policy hosted on an AARP website (you will need to be connected to AARP's secure network).

WHO WE ARE HOW WE DO IT HOW WE TREAT EACH OTHER Message From Our CEO ...... 4 Protecting Our Data, Systems, Respect & Diversity ...... 27 How to Use the Code ...... 5 & Assets ...... 16 Discrimination & Harassment ...... 28 Our Purpose, Vision & Values ...... 6 Data ...... 16 Workplace Violence & Acting Ethically ...... 7 Systems ...... 17 Threatening Behavior ...... 29 Introduction to the Code ...... 7 Assets ...... 18 Alcohol Use & Drug- Manager Responsibilities ...... 7 Representing AARP ...... 19 Free Workplace ...... 30 The R.I.G.H.T. Decision- Media Inquiries ...... 19 Revolving Door & Other Requirements Making Model ...... 8 Use of Social Media ...... 19 of Previous Employers ...... 31 How to Raise YRVoice ...... 9 Vendor Testimonials ...... 20 You Can Raise YRVoice in Following Professional BOARD OF DIRECTORS’ Many Ways ...... 9 Standards ...... 20 CODE OF ETHICS Zero Tolerance of Retaliation ...... 10 Government & Other Grants .... 20 Setting the Tone ...... 33 Avoiding Conflicts of Interest ...... 21 Duty of Care ...... 34 WHAT WE DO Significant Relationships ...... 21 Duty of Loyalty ...... 34 Vendors, Consultants Preserve Our Tax-Exempt Status ...12 Duty of Diligence ...... 37 & Independent Third- AARP’s Advocacy ...... 13 Duty to Raise YRVoice ...... 37 Party Providers ...... 22 Lobbyists ...... 13 Hiring Friends & Family ...... 22 Government Officials Benefitting 39 Outside Employment/ GLOSSARY/DEFINITIONS from AARP Resources ...... 13 Volunteer Work ...... 22 Personal Political Activity ...... 14 Give & Get ...... 23

1 Raise YRVoice at 1-855-YRVoice (978-6423) or www.aarp.org/YRVoice CONTENTS

GLOSSARY

“To serve, not to be served.”

– DR. ETHEL PERCY ANDRUS, FOUNDER OF AARP

2 Raise YRVoice at 1-855-YRVoice (978-6423) or www.aarp.org/YRVoice CONTENTS We are all GLOSSARY responsible for acting ethically in everything that we do.

WHO WE ARE

• Message From Our CEO • How to Use the Code • Our Purpose, Vision & Values • Acting Ethically • How to Raise YRVoice • Zero Tolerance of Retaliation 3 Raise YRVoice at 1-855-YRVoice (978-6423) or www.aarp.org/YRVoice WHO WE ARE CONTENTS

“We cannot fulfill our purpose and be successful GLOSSARY Message From without exhibiting integrity in everything we do. The Code of Conduct is our guide.”

Our CEO – JO ANN JENKINS, CHIEF EXECUTIVE OFFICER

Dear Colleague:

At AARP1, we work hard every day to steps in their daily life, pushing government truthful, to comply with all applicable laws empower people to choose how they live as and business to address healthcare and and regulations, to follow the Code, to raise they age. Just as Dr. Andrus did sixty years prescription drugs, protecting pensions and your voice if you think something is not right, ago, we envision a society in which all people efforts to erode financial security, helping and to not retaliate against those that raise live with dignity and purpose. We want to people recognize and guard against fraud, concerns. If you need help, there are many empower them to attain their real possibilities and advocating for individual data control and resources available to you. over the course of an ever-longer lifetime privacy in the 21st century. while living healthier, more financially secure, AARP is a successful organization today— and more fulfilling lives. We believe that no one’s possibilities should and has been for more than 60 years— be limited by their age and that experience because we are built on a solid foundation We envision a future where AARP is viewed has value. In all that we do, we strive to of trust. As we strive to help people 50-plus by its members and people 50-plus as both a be innovative while addressing the wants and their families confront their challenges wise friend and fierce defender. To be a wise and needs of people 50-plus including and embrace their opportunities, we must friend, we must earn our members’ trust. Our multicultural communities and people with continue to build that trust by acting members don’t trust us simply because they low incomes—to help them turn their goals ethically and with integrity—and following trusted us in the past. We must earn their trust and dreams into real possibilities. our Code of Conduct. by demonstrating shared values, experiences, and interests in every interaction with them. We cannot fulfill our purpose and be successful without exhibiting integrity in As a fierce defender, we must continue to everything we do. The Code of Conduct is champion societal change. That means: our guide. It is our commitment to ethical fighting ageism—both in society and in the conduct and sets forth the expectations for Chief Executive Officer workplace—pressing for sustainable caregiver our employees, volunteers, Board members, JO ANN JENKINS supports, inspiring millions to take healthier and those with whom we do business. At a minimum, it requires us to be honest and

1 AARP and its affiliated entities are each organized as a separate and distinct entity with its own governing body, standards and records. The term “AARP” is used collectively to describe AARP and its affiliated entities for ease of reference and not to disregard the separate missions organizational status of each entity.

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How to Use the Code GLOSSARY

The Code cannot cover every situation.

In addition to the Code, there are other policies and guidance that you must follow. This Code does not create any rights to continued employment and is not an employment contract. The Code is designed to provide you with a broad overview of our ethical standards and incorporates all organizational policies. Internal links to key terms and policies can be found throughout the Code.

Here is your guide to accessing additional informa- tion. Additional resources can be found by looking for these icons.

What about those that we do business with? We expect them to comply with the Code of Conduct This icon indicates This icon lets you know that as applicable. examples and additional there are policies or other information. guidance. See our Key Information for Vendors brochure that highlights sections of the Code of Conduct most likely to apply to those that we do business with.

5 Raise YRVoice at 1-855-YRVoice (978-6423) or www.aarp.org/YRVoice WHO WE ARE CONTENTS

Our Purpose,Vision & Values GLOSSARY

This Code of Conduct is designed to help us do Our Purpose Our Vision business in line with our organizational character. Empower people to choose how A society in which all people live they live as they age. with dignity and purpose, and fulfill their goals and dreams.

Our Values Our values—Impact, Innovation, Humanity, Empowerment, Honesty— compass guiding how we show up, what we deliver, how we make express what we stand for and what we believe. They reflect how we decisions, and how we communicate. treat each other as well as those we serve. They are also our internal

AARP creates real value for AARP evolves and invents AARP cares about people AARP uses its influence and AARP acts and speaks with people in their life and in the to meet the new realities and serves them with resources to remove barriers integrity in every action wider world of aging compassion and open possibilities

6 Raise YRVoice at 1-855-YRVoice (978-6423) or www.aarp.org/YRVoice WHO WE ARE CONTENTS

Violations of the law, the Code, policies, procedures, or guidelines GLOSSARY will result in disciplinary action up to Acting Ethically and including termination of em- ployment. Managers and executives will be subject to disciplinary action if they condone, permit, fail to take action to prevent or detect, or fail SIX SIMPLE RULES TO REMEMBER Introduction to the Code to report unethical conduct. The We are all responsible for acting 1 Act in accordance with our Values following are examples of unethical ethically in everything that we do. This conduct: Code of Conduct (Code) sets forth our 2 Obey applicable laws, rules, and regulations expectations for Ethical Conduct for • Theft of Assets, including, but our employees, volunteers, Board 3 Know and comply with our Code of Conduct, policies, not limited to, the falsifying of members, and those we do procedures, and guidelines expense reports. We reserve the business with. right to pursue all legal remedies 4 Raise YRVoice if you think something is not right to recover Assets including, but Claims of ignorance, good intentions, not limited to, restitution, civil or using poor judgment will not be Don’t retaliate against those who raise concerns in Good Faith 5 recovery, and criminal prosecution; accepted as excuses for non-compli- Fully cooperate with any investigation, inquiry, audit, or ance. Violations of the law, the Code, 6 • Improper disclosure of Data or legal proceeding policies or procedures, or failure to access to Systems; report such violations, will result in disciplinary action pursuant to the • Actual or threatened Workplace Employee Disciplinary and Corrective Violence or intimidation, including Complete Mandatory Training & Raise YRVoice. You may not Action Policy up to and including harassment or bullying on social Ethics Statements on Time. remain silent about concerns termination of employment. Each media; year, you will be asked to acknowl- Ensure that your staff has the “know that you discover or that others edge that you have read and complied how” to perform their jobs by mak- share with you. You must report • Falsifying any record; or with the Code. ing sure that they and you timely concerns immediately. complete all mandatory training and • Conflicts of Interest, e.g., soliciting Managers and executives who Manager Responsibilities ethics statements; or implying that you will accept condone, permit, fail to take gifts or favors from anyone AARP Managers are held to a higher Open Door. Encourage “open door” action to prevent or detect, or fail does business with; and failure to standard and are expected to: communication so your employees to report unethical conduct will be disclose conflicts of interest. and others can ask you questions or subject to disciplinary action up Lead by Example. Your staff follows raise concerns even when they may to and including termination. Ethical behavior is also taken into your lead so you are expected to pro- be about you or uncomfortable; and consideration in performance evalua- mote our organizational character by tions and compensation. acting in accordance with our Values. This includes taking steps to prevent unethical conduct before it happens; 7 Raise YRVoice at 1-855-YRVoice (978-6423) or www.aarp.org/YRVoice WHO WE ARE CONTENTS

Acting Ethically GLOSSARY

The R.I.G.H.T. Review the facts, the Code, and applicable

Most people know right from wrong Decision-Making Model policies to make sure that what you want to do but still make unethical decisions We live in a complex and ever-changing is aligned with our Organizational Character. because they feel pressured to do so, world which makes it hard sometimes to R have an incentive that rewards them know what the right decision is. for the unethical behavior, or have Inquire if you are not sure if it is legal or ethical. rationalized their decision. Here are In all decisions you should consider how some of the warning signs: your actions might reflect on our orga- I nizational character, impact others, and • The only reason for taking action is what the ethical implications might be. Get input from others on how your actions because management says so; When faced with a difficult decision, you might impact them. • The decision accomplishes a can use the R. I. G. H. T decision-making G goal that impacts bonuses or model to help you. compensation; Hold the decision up to the mirror. Does it If working through this model does not feel right? Do you like what you see? Will • There are other rewards like hotel lead you to the right answer, there are you be proud of the decision? points or frequent flyer miles; H many resources available to help you. • Everyone does it; The most important thing is that you • No one will know; Raise YRVoice. Think about how the decision could impact your reputation, and ours. • No one will be hurt; T • I earned it.

If any one of these is the reason for the decision, please contact the Ethics & Compliance Office to discuss your options.

8 Raise YRVoice at 1-855-YRVoice (978-6423) or www.aarp.org/YRVoice WHO WE ARE CONTENTS

How to Raise YRVoice GLOSSARY

Concerns about violations of the law, the Code, policies, procedures, or guidelines should be reported immediately through any of these channels so that appropriate action can be taken. Raise Q: What information should Q: Is my report confidential? Q. Can I report anonymously? I provide? A: Except as may be required by A. You can choose to be anonymous A: Please help us help you by pro- law and necessary to conduct an through Raise YRVoice web or YRVoice viding as much information as adequate investigation, every phone line. possible. Please be as specific as effort will be made to keep the If you remain anonymous, you are possible. The following is informa- identity of the person who made provided a tracking number that tion that will aid us in getting to a the report confidential. lets us communicate with each resolution of the concern: Concerns must be raised in other. You may use this number You Can Raise YRVoice • Tell us what happened in as Good Faith. to check on the status of your in Many Ways much detail as possible concern and provide us with • Let us know if you have first- additional information. Talk with your manager. hand knowledge or learned He or she may know more facts and about the concern from others be in the best position to help you. • Describe why you think the Consult with other resources. conduct is unethical, e.g., what Human Resources, the Office of section of the Code do you General Counsel, and the Ethics & believe applies, what policies, Compliance Office may be able to procedures, or guidelines assist you. might be applicable • Who else may have facts or Contact 1-855- YRVoice (978-6423) knowledge • Policy on Protection from Retaliation and or www.aarp.org/YRVoice Reporting Possible Unethical Conduct YRVoice is available 24/7. It is man- • What might be the impact aged by a third-party vendor and • Identify and/or provide any • How We Handle Misconduct information supplied, whether by documents or records phone or online, cannot be traced. • Your responsibilities in investigations

9 Raise YRVoice at 1-855-YRVoice (978-6423) or www.aarp.org/YRVoice WHO WE ARE CONTENTS

Zero Tolerance of Retaliation GLOSSARY

We prohibit intimidation, harassment, discrimination, or retaliation against those who come forward with concerns about unethical conduct or participate in investigations. Examples of retaliation can include This applies even if the concern is not found to be true. If you engage in these prohib- direct or indirect actions that may ited activities, you have violated the Code and appropriate disciplinary action may be dissuade a reasonable employee taken, up to and including termination of employment. from raising a concern, such as: • Substantive changes in the type and quality of work • Changes to schedule, location, and reporting assignments • Exclusion from meetings, events, and social activities

Retaliation can take many differ- ent forms and can be subtle. If you believe that you are being retaliated against, please Raise YRVoice.

• Employee Disciplinary and Corrective Action Policy

• Policy on Protection from Retaliation and Reporting Possible Unethical Conduct

10 Raise YRVoice at 1-855-YRVoice (978-6423) or www.aarp.org/YRVoice CONTENTS We take GLOSSARY care to be nonpartisan and to preserve our tax exempt status.

WHAT WE DO

• Preserve Our Tax Exempt Status • AARP’s Advocacy

11 Raise YRVoice at 1-855-YRVoice (978-6423) or www.aarp.org/YRVoice WHAT WE DO CONTENTS

Preserve Our Tax-Exempt Status GLOSSARY

Most AARP entities are tax exempt, a privilege that allows us to use funds that would otherwise be paid in taxes to fulfill our nonprofit missions. AARP is tax exempt as a “social welfare AARP Foundation is AARP’s affiliated charity, and is tax exempt under To preserve this privilege, we must organization” under section 501(c)(4) section 501(c)(3) of the tax laws, meaning that donations to it are tax dedicate our work to fulfilling those of the tax laws. We strive to help the deductible. It serves vulnerable people 50+. missions. Additionally, we must entire community of those age 50+. Our membership helps us work toward that AARP Foundation donations and grant awards must be used solely for respect the separate and distinct na- goal, but we do not exist just to help the charitable purposes of the AARP Foundation. Any grants the AARP members. As Ethel Percy Andrus said, ture of each entity by each remain- Foundation makes to AARP must be under the Foundation’s control and “What we do, we do for all.” ing independent from the others used to further the AARP Foundation’s tax-exempt, charitable mission. and each entity must comply with Advocacy is integral to achieving AARP’s the laws and regulations that grant mission and, as permitted by law, the AARP Foundation receives federal and state grants as well as govern- each its tax status. When in doubt as Association can engage in legislative ment contracts with the Federal Government. All terms of these grants advocacy and lobbying activities. Other and contacts must be complied with. Since the Foundation receives fed- to whether an activity is appropriate entities in the AARP family are subject to eral grants and holds government contracts, there are restrictions on the for any particular entity, contact the limits and restrictions on their lobbying lobbying activities that the AARP Foundation can engage in, in addition Office of General Counsel before activities. to lobbying restrictions for charities under the tax laws. proceeding. Consistent with our fundamental value of nonpartisanship, AARP does not di- rectly or indirectly participate in political Here are some important campaigns or other electoral or partisan things to know: activity, except for our issues-focused Review the chart to see which voter education efforts. organization does what. If you have We can identify and communicate infor- questions about whether an activity is mation about AARP member benefits appropriate for any particular entity, but we must refrain from marketing AARP Services, Inc. (ASI) is a wholly-owned taxable subsidiary of the or promoting commercial products or Association, and provides for member benefits through contracts with contact the Office of General Counsel services that carry the AARP name. Staff independent third-party providers, as well as managing advertising sales before proceeding. responsible for member communications for our publications and website. ASI is an independent entity, and as should refer to the Office of General such, the Association must not exercise day to day supervision and con- Counsel for more guidance. trol over ASI. Through its work, ASI supports the Association’s mission.

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AARP's Advocacy GLOSSARY

AARP engages in a substantial or party in our advocacy efforts. We AARP must comply with the registra- federal executive branch, and state amount of advocacy before govern- do not support or oppose, nor use tion and reporting requirements of governments have all enacted specific mental bodies on behalf of the our organizations’ funds, to make any each jurisdiction. Failure to comply gift laws with civil and criminal penal- 50+ community. financial contributions to any politi- with those requirements can result ties for violations. Because AARP is a cal party or individual candidate for in both criminal and civil charges for lobbyist entity, those laws are particu- As interactions with government public office. AARP and the individual lobbyist. larly strict and deserve special atten- employees and agencies are highly tion from all employees. regulated, our advocacy work cre- ates unique legal issues that must be Lobbyists Government Officials addressed. Being nonpartisan allows Our advocacy work requires us to Benefitting from AARP us to work with all parties and find meet registration and reporting re- Resources support for efforts that best serve the quirements under the federal Lobby- When interacting with government 50+ population, and it’s crucial to our ing Disclosure Act (LDA) and a variety employees, we must be careful not effectiveness. We take special care to of unique state laws. As an organiza- to give anything of value to those avoid supporting a specific candidate tion that employs in-house lobbyists employees, including AARP staff time at both the state and federal level, and resources. The House, Senate,

Can I March or Protest? Can I “Like” on Facebook Yes, you can but please do not or Retweet? involve AARP in that activity in Yes, you can. If you are in a Desig- any way, including: nated Position you cannot: • Wearing AARP apparel • Post original endorsing content or • Making statements to the • Add endorsing commentary press about AARP positions • AARP Advocacy Central or viewpoints • AARP Policy on Personal Political Activity • Protesting on work time or using AARP resources • AARP Foundation Political Activity Policy

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AARP's Advocacy GLOSSARY

Personal Political ARE YOU IN A DESIGNATED POSITION? Activity AARP employees are, of course, en- titled to their own personal, political leanings and to participate in the democratic process. Because certain NO YES employee positions have greater exposure to the public, AARP asks those employees to refrain from You May... You May Not... certain types of political activity.  Express opinions on pending or proposed  Solicit financial contributions These are known as “Designated legislation or other government action Positions.”  Organize a public event or participate  Work for or engage in political activity on on the host committee It is our long-standing policy that behalf of a political party  your personal life, beliefs, and con- Hold public office  Accept an official or unofficial position on duct outside the Workplace are not  Work for or on behalf of a political party subject to review or evaluation by a political or candidate campaign  Endorse via social media, yard signs, AARP unless they have a negative  Solicit or make lawful financial bumper stickers, or dissemination of effect on your performance, AARP’s contributions to a candidate campaign literature performance, or the reputation or  Become a candidate for or hold other legitimate interests of AARP. public office  Perform “back office” activities for a campaign (e.g., answering phones or stuffing envelopes) For full guidance on our Personal Political Activity Policies, including examples and FAQs, please visit Advocacy Central on InfoNet.

14 Raise YRVoice at 1-855-YRVoice (978-6423) or www.aarp.org/YRVoice CONTENTS You must GLOSSARY take appropriate steps to protect and preserve our Assets.

HOW WE DO IT

• Protecting our Data, Systems, & Assets • Representing AARP • Avoiding Conf icts of Interest

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Protecting Our Data, GLOSSARY Systems & Assets

It is your responsibility to protect our • Know and understand how the Data • Comply with all policies regard- Data, Systems, and Assets. that you handle is classified. Refer ing the handling of personal to the Classification and Data Han- Data of members, volunteers, This responsibility continues even dling Standards to know how we donors, current and former em- after you leave AARP. Our Data, define our Data classes and identify ployees, contractors, and others. Systems, and Assets may not be used the requirements for handling the for your personal advantage or the various classes of Data. • Maintain our Data in accordance advantage of others, as would be with the Records and Informa- the case if you were to directly or • Avoid discussing in public places or tion Management Policy and ASI indirectly purchase, hold, or sell any other forums. Document Retention Policy and security. In regard to public or soon Procedure. to be public companies, use of such • Never share or solicit information insider information can result in large about other organizations including fines and imprisonment. former employers and vendors. • Follow the Third Party Security Data Program (TSP) if certain Data will We collect, use, and distribute Data be shared with a third party. in the course of our daily operations • Do not disclose Material Information and in support of our mission. To about recent or impending trans- • How to report suspicious activity protect our Data you must: actions or activities related to any • Only use the Data as authorized. independent third-party provider. • Classification and Data Handling Standards

• Share only with others who are • Third Party Security Program authorized to have the Data. • Records and Information Management Policy

• ASI Document Retention Policy and Procedure 16 Raise YRVoice at 1-855-YRVoice (978-6423) or www.aarp.org/YRVoice HOW WE DO IT CONTENTS

Protecting Our Data, GLOSSARY Systems & Assets

Systems TO PROTECT OUR SYSTEMS We use Systems every day and they must be protected from unauthorized use. DO DON’T Anyone using our Systems has no ex- • Look out for phishing and think before you click • Share passwords. pectation of privacy including anything on a link or respond to an email. Check here for viewed, created, stored, sent, or received. security tips and how to report suspicious activity. • Attempt to install unauthorized software or programs. We reserve the right to access, use, moni- • Be careful when connecting to public internet. tor, and disclose the contents of any com- • Modify, try to alter, or compromise munications, whether made for business • Immediately report any unauthorized access, any System. or personal reasons in accordance with loss of information, or suspicious activity to the • Access inappropriate sites, e.g. sexually applicable laws and regulations. AARP Help Desk. explicit, gambling, or illegal. All information created, stored, sent, or • If you suspect a security breach, contact • Use our Systems to conduct other business. retrieved over these Systems, including the Help Desk immediately and notify email messages and files, is the property your manager. of AARP. AARP will not return or restore • Make sure that access to Systems is only grant- any personal information on our Systems. ed to those that need access and is promptly terminated when it is no longer needed, e.g., change in duties or termination of employment.

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Protecting Our Data, GLOSSARY Systems & Assets

Assets Intellectual Property & Work Product AARP has the right to its Intellectual Property, and Protection and Use of Assets you must not use or allow others to use this Asset You must take appropriate steps to protect and pre- without approval. All work product, and the Intel- serve our Assets. Our responsibility to our members lectual Property rights therein, made, developed, and donors is to use our Assets prudently and effec- perfected, devised, or conceived by you either tively. Assets are to be used for business purposes solely or in collaboration with others while work- only. Never use Assets for personal gain or profit. ing for us, relating to the business is, and shall You are responsible for submitting only true and be, the sole and absolute property of AARP. We valid expense reports in compliance with our Travel expect work product to be original and prohibit and Expense Reimbursement Policy and Corporate the misstatement of facts, falsification of data, Credit Card Program. We reserve the right to seek and plagiarism. You must respect the intellectual restitution, civil recovery, and recoupment for the property rights of others and may not use or incor- misuse of our Assets. porate other content without obtaining permission for use and crediting the source. Physical Property • Travel and Expense Reimbursement Policy As with our Data and Systems, you must protect Our Brand our physical property. You do not have the right to You must protect our brand, using it only as per- • Corporate Credit Card Program privacy when using our Assets. See Appropriate mitted by the AARP Brand Identity & Guidelines • Volunteer Portal for policies and Use of and Access to Company Equipment. If you and not letting others use it unless authorized. See procedures that apply to volunteers lose your laptop, iPhone, or any other equipment Policy on the Use of AARP Brand in Vendor Public that could provide access to our Data or Systems, Statements. • Appropriate Use of and Access to immediately report it to the Help Desk. You must Company Equipment return all Assets upon termination of employment • AARP Brand Identity & Guidelines and AARP has no obligation to store, retrieve, or provide access to any personal information that you • Policy on the Use of AARP Brand in may have placed on any Assets or Systems. Vendor Public Statements

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Representing AARP GLOSSARY

It is our long-standing policy that your personal All Media Inquiries from state-based media must life, beliefs, and conduct outside the Workplace be directed to State Communications Representa- are not subject to review or evaluation by AARP tives or the individual designated to handle media unless they have a negative effect on your perfor- relations in a state office. Further, you are prohibit- mance, AARP's performance, or the reputation or ed from divulging proprietary or confidential infor- other legitimate interests of AARP. mation to any external parties unless compelled to do so by law or authorized to do so by AARP. If you choose to speak or write publicly or in any other way publicly express your personal views or beliefs, it is important that you avoid giving Use of Social Media the impression that you are representing AARP’s Responsible use of social media platforms is an views. Prior to any public activity, including run- effective way for us to engage our targeted audi- ning for office, serving on the board of directors ences and deliver our messages in real time. All of another organization, publishing, or providing a of these platforms, despite privacy settings, are testimonial or endorsement, you should seek guid- essentially public forums with their own etiquette ance from your manager and the Ethics & Com- and policies. When communicating on social pliance Office to ensure that a conflict of interest media platforms you may use publicly available does not exist. information. However, do not share or post any of this type of information without documented Office Media Inquiries of General Counsel approval: To ensure that accurate and consistent information • AARP financial information that is not made public. about AARP is provided to the news media or • AARP member, provider, employee, or other interested parties, all calls from the national donor information. media must be directed to Media Relations before AARP policy on • AARP internal communications. • Social Media any information is released. Only the Chief Com- Communication munications & Marketing Officer, his/her desig- • Personal endorsement of candidates or nee, and/or Media Relations staff may authorize a political parties. • Policy on the Use of AARP disclosure to the national media on our behalf. Brand in Vendor Public Statements • Marketing or promotion of third-party providers or their products and services. • If you are in a fundraising role, you are expected to follow the Association of Professional Fundraisers’ Code of Ethical Principles and the Donor Bill of Rights 19 Raise YRVoice at 1-855-YRVoice (978-6423) or www.aarp.org/YRVoice HOW WE DO IT CONTENTS

Representing AARP GLOSSARY

Vendor Testimonials • Are responsible for ensuring that any subcon- tract necessary to satisfy the award contains all The AARP Brand is our most valuable asset. We required terms. Examples of information that must must protect the AARP Brand and only use it with be kept confidential include: proper authorization. Beyond the products and • Must not offer or pay any form of “pay to play,” • Information provided in the bidding services that carry the AARP name that are made bribe, or kickback to apply for or be awarded process by any bidder available by independent Member Benefit Pro- government funds or a grant, or make any false viders, we do not use the AARP Brand or publicly statements or claims. • All pricing information endorse the products, services, or other offerings • All contractual terms of other companies, unless approved in advance by • May not participate in the application or pro- the Office of General Counsel . gram funded by any grants if there is a real or • Competitive information, such as perceived conflict of interest. A conflict of inter- product development, marketing est exists if you or someone with whom you have strategies, or new or proposed Following Professional Standards a Significant Relationship has a financial or other business ventures If you are a member of a profession that has estab- interest in an entity that may receive grant funds lished its own code of ethics or standards, such as a from us. lawyer, certified public accountant, grant writer, or fundraiser, you are expected to follow and comply • May not offer, solicit, or accept employment, with those professional standards as well as this Code. gratuities, favors, or anything of monetary value from any government official or employee. See GIVE & GET section of the Code. Government & Other Grants If you are involved in the application for or pro- In addition to disciplinary action, violations can grams funded by any government grants, you: result in fines and/or imprisonment, as well as loss of the award and suspension or debarment from • Are responsible for knowing and complying eligibility to receive government grants. with all terms and conditions of the application or award.

• Policy on the Use of AARP Brand in Vendor Public Statements

20 Raise YRVoice at 1-855-YRVoice (978-6423) or www.aarp.org/YRVoice HOW WE DO IT CONTENTS

Avoiding Conflicts of Interest GLOSSARY

Each of us is responsible for avoiding situations that could create a conflict of interest or the appearance of such conflict. Certain professional and personal CONFLICTS OF INTEREST relationships, outside obligations, financial inter- Perceived or Actual ests, or other employment may result in a conflict of interest and could affect the objectivity of your business decisions. You should advise your manager of all conflicts of interest, potential conflicts, and You are responsible for avoiding situa- tions (actual or perceived) that conflict Significant Relationships that may be perceived as a between your interests & AARP's. conflict of interest so the situation can be reviewed DO YOU... and any necessary actions can be taken. Updating your Ethics Statement is how we document that you're doing the right In addition, you are required to formally disclose Work, volunteer, or are a Board member thing and it protects you and AARP. your relationships and/or affiliations with individuals  of another entity? or organizations that have a direct business relation- Own, invest, or have a relationship with ship with us or may have a direct or indirect inter-  a vendor or someone who seeks to do est that conflicts with, or appears to conflict with, business with us? AARP’s best interests.  Accept gifts or favors given for improper The Ethics & Compliance Office manages this formal purposes or that exceed our limits? IF SO, DISCLOSE disclosure process through the eIntegrity system. Have a relationship with anyone at work or  that you have referred to work at AARP? Significant Relationships  Talk to your manager You shall not use your position, or any knowledge Email [email protected] for  an Ethics Statement or opportunity gained there from, in such a way that a conflict of interest, real or perceived, might  Complete Ethics Statement arise between AARP, you, or those with whom you have a Significant Relationship.

21 Raise YRVoice at 1-855-YRVoice (978-6423) or www.aarp.org/YRVoice HOW WE DO IT CONTENTS

Avoiding Conflicts of Interest GLOSSARY

Vendors, Consultants Hiring Friends & Family Outside Employment/ • Receiving an honorarium and/or compensation for time and/or ser- & Independent Employees are an excellent recruit- Volunteer Work vices that are also compensated Third-Party Providers ing source, and we encourage you You should obtain approval from by us (see the GIVE & GET section to refer qualified applicants. Howev- your manager, and the Ethics & under Valuable Privileges). Decisions about with whom we will er, the appearance of favoritism or do business must be objective, fair, Compliance Office or his/her desig- other conflicts of interest may arise if • Becoming involved in outside and in AARP’s best interest. Infor- nee, before entering into relation- those with whom you have a Signifi- activities that compete with our mation or business opportunities ships such as: cant Relationship are working in the interests. that you learn about in the course of same area or department. For these • Volunteering at, working for, or es- your work may not be used by you or reasons, you may not be hired, trans- tablishing an interest (financial or Even where an outside work/volun- those with whom you have a Signifi- ferred, or promoted into a position proprietary) in an entity that does teer relationship does not involve a cant Relationship. where you would report directly or business with us. conflict of interest, you must avoid creating the perception that you A real or perceived conflict of interest indirectly through the line of authori- • Working for pay or as a volunteer represent AARP. can occur if someone with whom you ty to someone with whom you have a Significant Relationship. at another organization whose have a Significant Relationship is hired purpose, objectives, and/or philos- as a vendor, consultant, or indepen- ophy are similar to or are at odds dent third-party provider. As a result, with those of AARP. when such a potential conflict exists (real or perceived), you must disclose the matter to your manager so that appropriate actions can be taken prior to the proposed transaction. If a conflict exists, you may not be involved in any way with approving, managing, or influencing the business relationship. The Ethics & Compliance Office should be consulted for the appropriate action to take. • Relationships, Conflicts of Interest, and Employment of Relatives and Friends Policy 22 Raise YRVoice at 1-855-YRVoice (978-6423) or www.aarp.org/YRVoice HOW WE DO IT CONTENTS

Avoiding Conflicts of Interest GLOSSARY

Give & Get General rule of thumb is that we cannot give more than we can get. “You” includes someone with whom you have a Significant Relationship.

GOVERNMENT OFFICIALS GIFTS  No one should make contributions, Still not sure if you can accept a gift? See Guidance on Acceptance of Gifts financial or otherwise, that could be CAN OFFER & ACCEPT construed as “pay to play,” a bribe, or a kickback.

 No one shall give gifts or make offers You may offer and accept gifts valued at of employment to any government $50.00 or less per gift and $150.00 per personnel or officials without specific source per calendar year, excluding written approval from the Office of items that: CANNOT OFFER OR ACCEPT General Counsel.  You pay market value for or promptly  Many federal, state, and/or local return, laws prohibit or strictly limit gifts or  You cannot accept gifts regardless of value  Are paid for from your personal funds payments to government personnel if being offered for improper purposes, e.g., and offered or given on the basis of and officials. AARP and its registered "pay to play," bribes, or kickbacks. personal friendship, lobbyists cannot provide “gifts” to  You should take great care to avoid accept-  Gifts between employees in celebration Members of Congress or their employ- ing frequent gifts from the same individuals of an event (such as a wedding, birth of ees, such as free AARP memberships, or organizations, and individuals and organi- a child, graduation, retirement), free meals, or free tickets to sporting zations that are seeking to do business with events unless an exception applies, as  Promotional items with logos, or AARP or in the contracting/bidding process identified by the House and Senate  Food items that are meant to be with AARP. Gift Rules. Violations of these rules shared, e.g., food baskets.  You cannot offer or accept cash or gift cards. can result in fines up to $200,000 and criminal prosecution. Contact the Office of General Counsel for details.

23 Raise YRVoice at 1-855-YRVoice (978-6423) or www.aarp.org/YRVoice HOW WE DO IT CONTENTS

Avoiding Conflicts of Interest GLOSSARY

Give & Get General rule of thumb is that we cannot give more than we can get. “You” includes someone with whom you have a Significant Relationship. VALUABLE PRIVILEGES

INFLUENCE CAN ACCEPT WITH  If you deal with vendors, consultants, or inde- CANNOT ACCEPT pendent third-party providers, you must treat CERTAIN LIMITATIONS them fairly to avoid the appearance of favorit- ism or impropriety.  If you accept honoraria for representing  You may not offer or accept valuable AARP, it must be donated to the Foun- privileges under any circumstances.  You must not use information or opportunities dation or Legal Counsel for the Elderly. Examples of what would be considered learned from your dealings, nor solicit or ask them a valuable privilege include. to provide personal services for you or others.  You may accept reimbursement for reasonable out-of-pocket expenses in  Admission to semi-final or final sporting  You must not ask for favors, contributions, or connection with an AARP-authorized events like playoff games, the Super donations to an entity or cause that you support. speech, panel discussion, or presen- Bowl, the World Series, or the Olympics.  When dealing with multiple independent tation provided you have not request-  Admission to rare or unusual perfor- third-party providers, you must comply with the ed or been reimbursed for the same mances by famous people or stars, ASI’s Anti-Trust Policy. expenses. season tickets, or a series subscription  You must comply with our competitive bidding  You may retain honoraria and/or to cultural events. Procurement procedures and not give any spe- expense reimbursements received for  Memberships to sports, country, or cial preferences or advantages. All information participating in an outside activity on other types of clubs. regarding any transactions or business dealings your personal time, when you were not must be kept strictly confidential. representing AARP.  Experiences such as travel by private aircraft, boat, or luxury vehicle.  You shall comply with all Procurement and Contract Management Policies and Procedures.  Payment for travel or lodging.

24 Raise YRVoice at 1-855-YRVoice (978-6423) or www.aarp.org/YRVoice HOW WE DO IT CONTENTS

Avoiding Conflicts of Interest GLOSSARY

Give & Get General rule of thumb is that we cannot give more than we can get. “You” includes someone with whom you have a Significant Relationship.

ENTERTAINMENT TRAVEL

CAN ACCEPT CANNOT ACCEPT OFFER ACCEPT

You can accept items that Entertainment that would be We do not pay for travel, Please see section on Valuable would be considered common considered a valuable privilege lodging or other business Privileges regarding travel ex- courtesies - such as business is not acceptable. expenses of non-employees penses that you can and cannot meals, tickets to local sports unless specifically provided for accept from others. AARP will or cultural events, if there is a in a contractual agreement, only reimburse expenses in legitimate business purpose and then only in accordance accordance with the Travel and to attend, the business person with the agreed upon terms. Expense Reimbursement Policy. providing the entertainment will be present and it is local.

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AARP GLOSSARY welcomes different backgrounds, life experiences, and points of view. HOW WE TREAT EACH OTHER • Respect & Diversity • Discrimination & Harassment • Workplace Violence & Threatening Behavior • Alcohol Use & Drug-Free Workplace • Revolving Door & Other Requirements of Previous Employers 26 Raise YRVoice at 1-855-YRVoice (978-6423) or www.aarp.org/YRVoice HOW WE TREAT EACH OTHER CONTENTS

Respect & Diversity GLOSSARY

We understand that our diversity strengthens our ability to innovate and fulfill our mission.

We treat others with respect and value people’s contributions. We are committed to the safety and security of our employees.

Respect & Diversity • Treat people fairly—with respect and dignity • Act professionally in all interac- tions—including all conversations, meetings, email communications, and online exchanges • Create an inclusive, equal op- portunity work environment that values the opinions of others • Engage others positively, with- out belittling or using bullying or offensive behaviors • Support officers, directors, and managers in their efforts to foster a positive work environment • Avoid language or gestures which may be offensive to others (e.g., profanity, obscene pictures)

27 Raise YRVoice at 1-855-YRVoice (978-6423) or www.aarp.org/YRVoice HOW WE TREAT EACH OTHER CONTENTS

Discrimination & Harassment GLOSSARY

Discrimination & Harassment AARP is firmly committed to equal employment opportunity. AARP prohibits discrimination and harassment on the basis of race, ethnicity, religion, sex, color, national origin, age, sexual orientation, gender identity or expression, mental or physical disability, genetic information, or on any other basis prohibited by applicable law.

• Never discriminate based on any of the protected factors listed above. • Base employment decisions on the individual’s qualifications, skills, and performance—not on personal characteristics or protected status. • Be careful not to harass others, even without intending to—joking, teasing, and commenting about sensitive subjects can offend others and create uncomfortable working conditions regardless of whether done in person or online. • Raise YRVoice if you witness or experience harassing, discriminatory, or unfair behavior.

LifeWorks (www.lifeworks.com), our employee work-life consultation and referral service, has been updated to make it faster and easier to use so that you can find the information and support you’re look- ing for quickly and easily, whenever you need it. Online, by phone, or in person; LifeWorks is fast, confidential, and easy to use—and it’s absolutely free. Best of all, it’s there for you any time of the day • Equal Employment Opportunity and Prohibited Harassment and or night, wherever you are. Retaliation Policy

• Lifeworks 28 Raise YRVoice at 1-855-YRVoice (978-6423) or www.aarp.org/YRVoice HOW WE TREAT EACH OTHER CONTENTS

Workplace Violence & GLOSSARY Threatening Behavior

Workplace Violence & Threatening Behavior AARP is committed to creating a safe and respectful work Employee- Sourced Risk Intelligence environment, free of all forms of violence, including verbal and physical threats, intimidation, abusive or offensive behavior, and harassment. Our Workplace Violence and Threatening Behavior Policy specifically addresses violence We want you to be safe. Before You can also use the in the workplace and provides examples of behaviors that an incident occurs download the LiveSafe app to report are prohibited and you should report. LiveSafe app so you have all of an incident, get help, or the information that you need find out what to do. To to report a workplace safety Reporting Procedures concern. learn more, download the app here. Every employee has an obligation to report conduct in the workplace that is believed to be dangerous, regardless of GET LIVESAFE the alleged offender’s identity or position. Reports made in Using the QR code above, down- Good Faith will be treated with discretion, managed on a load “LiveSafe” from the App need-to-know basis, and investigated. Store or Google Play. Register and fill out your profile.erify V your AARP email. You’re set!

• Workplace Violence and Threatening Behavior Policy 29 Raise YRVoice at 1-855-YRVoice (978-6423) or www.aarp.org/YRVoice HOW WE TREAT EACH OTHER CONTENTS

Alcohol Use & Drug- GLOSSARY Free Workplace

Alcohol Use & Drug-Free Workplace AARP is committed to providing an alcohol- and drug-free work envi- ronment. Employees who are under the influence of alcohol or drugs as defined within the Alcohol Use and Drug-Free Workplace Policy are prohibited from AARP premises, even when the actual use of the controlled or illegal substance occurred off site.

As a condition of employment, you are required to report to your im- mediate manager—in writing within five days—any conviction, plea of guilty or no contest, and/or imposition of sentence in connection with the violation of any federal, state, or local drug statute.

• Alcohol Use and Drug-Free Workplace Policy 30 Raise YRVoice at 1-855-YRVoice (978-6423) or www.aarp.org/YRVoice HOW WE TREAT EACH OTHER CONTENTS

Revolving Door & Other GLOSSARY Requirements of Previous Employers

Revolving Door & Other Requirements of Previous Employers Q. A new hire brings with her a wealth of infor- We honor all revolving door and other requirements of pre- mation and even the “play book” from her vious employers, whether the government, other not-for- previous employer. This information will help us with impact and innovation. Can I get and profit organizations, or public entities. You are responsible use it to further our mission? for notifying Human Resources of and complying with any such requirements. A. No. Just like you, she may have an obligation not to disclose confidential information of a previous employer. You may not ask for or solicit confidential information of others un- less the sharing of such information has been contractually agreed to.

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We have GLOSSARY a strong reputation of being worthy of the public’s trust.

BOARD OF DIRECTORS' CODE OF ETHICS • Setting the Tone • Duty of Care • Duty of Loyalty • Duty of Diligence • Duty to Raise YRVoice 32 Raise YRVoice at 1-855-YRVoice (978-6423) or www.aarp.org/YRVoice BOARD OF DIRECTORS' CODE OF ETHICS CONTENTS

GLOSSARY

Setting the Tone All Directors have a duty to foster ethical conduct as well as a fiduciary You play an integral role in maintain- duty of care, loyalty, and diligence to ing the public's trust by acting with AARP. Fulfillment of these duties re- integrity and accountability. In addi- quires that, at all times, Directors act: tion to compliance with the Code of Conduct, Board members shall com- • In accordance with our Values ply with this Code of Ethics which • With integrity has been approved and adopted by the governing bodies of AARP, Inc. • In the best interest of the organi- (the Association), AARP Foundation zation that they serve (the Foundation), AARP Services, If a Director serves on more than Inc. (ASI), and the Legal Counsel for one AARP Board or other organi- the Elderly, Inc. (LCE) (referred to as zations, these fiduciary duties are “AARP” within this document). owed to each organization. If a con- flict arises, the Director is expected to disclose the conflict and take all necessary steps to mitigate the con- flict which could include abstaining from decision-making or resigning from the Board.

33 Raise YRVoice at 1-855-YRVoice (978-6423) or www.aarp.org/YRVoice BOARD OF DIRECTORS' CODE OF ETHICS CONTENTS

GLOSSARY

Duty of Care Duty of Loyalty In connection with any key indepen- As such, you and your family members dent third-party provider, the follow- may not enter into any transaction Directors shall exercise the same care Directors must be dedicated to the ing outside activities are prohibited: with any tax-exempt AARP entity if that an ordinarily prudent person mission, act in good faith, and give the economic value exceeds the value would in a like position and in similar their undivided loyalty to the orga- • Working directly for or as a of the consideration. In addition to circumstances. This duty includes nization that they serve. Conflicts of third-party consultant you, intermediate sanctions can be adherence to your Professional interest, whether real or perceived, imposed on all disqualified persons • Serving on the governing board Standards, acting in a professional direct or indirect, professional or who approved the transaction, the and courteous manner, and treating personal, must be avoided. • Having a Material Financial or Own- tax-exempt entities, as well as certain everyone with respect and dignity. ership Interest. (Note: A Director’s members of management. Directors are expected to foster and Restrictions of Other Activities investment in a mutual fund that in encourage open communication and This means that Directors must al- turn holds an investment in a provid- Entities with Whom AARP Does to seek a diversity of opinions and ways put the interests of the organi- er shall not be considered to be a Business ideas. As applicable, Board members zation that they serve above self-in- prohibited activity) Directors and those with whom they shall use Assets prudently by align- terest and comply with this Code of If a conflict of interest cannot be appro- have a Significant Relationship shall ing such use with the best interest of Ethics. Directors have an affirmative priately mitigated, the organization’s not be an owner, Board member, Offi- people 50+, members, donors, and duty to immediately disclose any By-laws address the circumstances and cer, employee, consultant, or advisor, program beneficiaries and adhering outside activities that may cause process for removal from the Board. or have a Material Financial or Owner- to all policies regarding the reim- conflicts of interest before engaging ship Interest in any entity that: bursement of expenses. in such activities, so that the appro- No Self-Dealing priate steps can be taken. Such steps • does or seeks to do business with may include recusing themselves by Directors and those with whom they AARP, including “Start-ups” or enti- abstaining from discussing, influenc- have a Significant Relationship shall ties that AARP has provided grants, ing, or making any decisions (taking not enter into any direct or indirect assistance, or invests in, any actions) in which their objectivity financial transactions with any AARP • provides products or services that could be questioned or taking other entity or entity that AARP does carry the AARP name, or steps to mitigate the conflict. business with unless the matter has been discussed with the Ethics & • have entered into a branding rela- In certain cases, outside activities Compliance Office and the appropri- tionship with AARP that could conflict with significant ate approvals have been obtained. unless they have first disclosed such re- AARP public policy positions shall Personal loans, grants, or other lationship to the Ethics & Compliance be prohibited. You may not serve as financial assistance to Directors are Office or ASI General Counsel and a Director if you also serve on the prohibited. As a Director, you are a obtained the appropriate approvals to governing board for a health disqualified person under Section enter or continue the relationship. insurance company. 4958 of the Internal Revenue Code. 34 Raise YRVoice at 1-855-YRVoice (978-6423) or www.aarp.org/YRVoice BOARD OF DIRECTORS' CODE OF ETHICS CONTENTS

GLOSSARY

Entities with Similar or • Taking for themselves or anyone Personal Gifts the Policy on AARP Board Director Opposing Interests with whom they have a Significant Gifts can be given or accepted on Ambassadorial Activities regarding Directors' relationships with entities Relationship any opportunities the basis of personal friendship participation at events, speaking that have similar or competing inter- that are presented in the course unless the Director has reason to be- engagements, and other public ests may also pose a conflict of of the Directors’ service that they lieve that, under the circumstances, appearances. interest. Without approval, Directors have not received permission from the gift was provided because they may not be associated with, advocate AARP to pursue. are a Director of AARP. for, or make public statements for • Using any proprietary or confi- organizations that have opposing dential information for their or for Speaking Engagements public policy positions to AARP. As a anyone with whom they have a & Events Examples of what would be result, before entering or continuing Significant Relationship’s personal Directors may be asked to engage in considered a valuable privilege such relationships, it must first be or professional benefit or gain. events which may include speaking include: disclosed to the Ethics & Compli- engagements, writing books or ance Officer (or to the ASI General Gifts, Entertainment & Travel (GET) articles, being interviewed, and • Admission to semi-final or Counsel) to obtain the appropriate otherwise appearing in public. These final sporting events like the What You Can Accept approvals. activities shall be distinguishable play-off games, the Super Items that would be considered from a Director’s personal activities Bowl, the World Series, or Employment, Business Opportuni- common courtesies such as business in which Directors must avoid the Olympics meals, entertainment, or gifts of a ties & Confidential Information attribution to AARP unless expressly • Admission to rare or unusual Nominal Value may be accepted. Directors shall not use their position authorized to participate as an AARP performances by famous Entertainment is considered a com- to solicit or gain opportunities that representative. As applicable and in people or stars, season tick- mon courtesy if there is a legitimate would not otherwise have been accordance with all policies regard- ets, or a series subscription business purpose to attend, the made available to them or someone ing political, partisan, and lobbying to cultural events business person providing the en- with whom they have a Significant activities, Directors shall protect tertainment will be present, and it is • Memberships to sports, Relationship. As a result, Directors AARP’s reputation for being nonpar- local. Please refer to the GIVE & GET country, or other types of are prohibited from: tisan. Please see the What We Do section of the Code of Conduct for section for more information regard- clubs • Promising, offering, or accepting more details. ing these policies. Any contact from • Experiences such as travel current or future employment with or to the media on behalf of AARP by private aircraft, boat, or anyone in exchange for opportu- must be approved by Media Rela- luxury vehicle nities to do business with AARP. tions. AARP Directors should refer to • Payment for travel or lodging

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GLOSSARY

Honoraria Honoraria offered in connection with In determining if a gift is personal, a Director’s performance of duties the Director shall consider: may be accepted as long as it is reasonable for the service performed • The history of the relationship, and directly donated to the Founda- including any previous ex- tion or Legal Counsel for the Elderly. change of gifts • Whether, to the best of the Prizes Director’s knowledge, the giver: Directors can accept a prize award- • Paid for the gift ed at an event for participation in a • Sought a tax deduction or competitive activity or based on a reimbursement for the gift random drawing. • At the same time, gave What You Cannot Accept the same or similar gifts to other Directors Directors and those with whom they have a Significant Relationship shall not give, solicit, seek, or accept any gifts, loans, or anything of value to or from a Prohibited Source as de- fined below: • Any elected official or government employee • Anyone that does or that seeks to do business with AARP • Any individual or entity that seeks (or appears to seek) to influence AARP

36 Raise YRVoice at 1-855-YRVoice (978-6423) or www.aarp.org/YRVoice BOARD OF DIRECTORS' CODE OF ETHICS CONTENTS

GLOSSARY

Duty of Diligence tion and Foundation Directors, but Fundraising & Lobbying regarding the application and not ASI) shall protect our reputation interpretation of the Code of The duty of diligence requires Direc- Directors shall be truthful in all solic- as a nonpartisan organization. Please itation activities and handle all dona- Conduct should be addressed to tors to be faithful to the mission and see “What We Do” AARP's Advocacy [email protected] or the Ethics & to always act in accordance with the tions with confidentiality. Lobbying section in the code for a description activities on behalf of the Associa- Compliance Office. ASI Board goals of AARP. As applicable, Direc- of activities that you may and may members should contact the tors are expected to honor each do- tion may only be conducted by those not engage in. As a Director you are that are authorized and must comply ASI General Counsel. nor’s intent and the public’s trust in considered to be in a Designated the use of donated funds. Directors with all federal and state laws and Position and there are restrictions on regulations. Duty to Raise YRVoice must comply with applicable state your use of Social Media. and federal laws and regulations, Directors have a duty to promote AARP’s By-Laws, the AARP Board Confidentiality Media ethical behavior and to take steps to Governance Book, and the fiduciary Directors shall uphold the strictest ensure that AARP encourages anyone duties imposed on them by the fed- Any contact from or to the media on standards of confidentiality and who has a concern to Raise YRVoice. eral tax code prohibitions on private behalf of AARP must be approved shall not disclose or provide access Directors should direct employees or inurement and private benefit. by Media Relations. to non-public information obtained others that have concerns to the or developed in the course of their Ethics & Compliance Officer. Con- Public Appearances Endorsements, Testimonials, Board service, to anyone other than cerns involving Directors should be Letters of Recommendation & Board members may be asked to en- as may be required by law or as au- raised with the Chair of the Board. Other References gage in activities that build our repu- thorized by the Chair of the Board. tation by being involved in their com- AARP’s name and logos can only The duty to maintain confidentiality munities. Please refer to the Policy on be used on approved products and exists both during and after the AARP Board Director Ambassadorial services after undergoing a stringent Board member’s term of service. Raise Activities regarding participation at due diligence process. Directors are not authorized to provide any Directors shall annually sign a certi- events, speaking engagements, and fication that they have read and will other public appearances. form of endorsement, testimonial, or reference for or to anyone who comply with the Code of Conduct YRVoice and this Board of Directors’ Code Political Activity does or seeks to do business with us. Directors should disclose and obtain of Ethics. The Board of Directors As applicable and in accordance with approval before proceeding with any shall take appropriate disciplinary AARP Policy on Personal Political form of endorsement or testimonial, and corrective actions, including Activity and AARP Foundation’s Policy as well as any staff or volunteer letter termination of Board service, for an on Political, Partisan, or Lobbying of recommendation. individual Board member’s failure to Activities, Designated Staff and abide by the AARP Code of Conduct Volunteers (which includes Associa- and this Code of Ethics. Questions

37 Raise YRVoice at 1-855-YRVoice (978-6423) or www.aarp.org/YRVoice CONTENTS

GLOSSARY

“What we do, we do for all.”

– DR. ETHEL PERCY ANDRUS, FOUNDER OF AARP

38 Raise YRVoice at 1-855-YRVoice (978-6423) or www.aarp.org/YRVoice GLOSSARY/DEFINITIONS

39 Raise YRVoice at 1-855-YRVoice (978-6423) or www.aarp.org/YRVoice CONTENTS

Glossary/Definitions GLOSSARY

ASSETS — includes the AARP brand, data, financial data, and other propri- MATERIAL INFORMATION — refers to information an investor might find etary or confidential information about us, our members, volunteers, donors, important in their decision to buy, hold, or sell a security. This prohibition employees, Intellectual Property, work product, communication systems, applies to all securities that you or those with whom you have a Significant equipment, furniture, vehicles, office supplies, corporate funds, credit cards, Relationship own. employee time, computer Systems, and Data. MATERIAL FINANCIAL OR OWNERSHIP INTEREST — a Material Financial DATA — is any information received or created by us in any form. or Ownership Interest includes: • An ownership or investment interest representing more than 1% of the DRUGS — are defined as any controlled or illegal substance, whether narcot- outstanding shares of a publicly traded company ic, sedative, or stimulant. • 5% of the outstanding shares or comparable interest of a ETHICAL CONDUCT — means that you behave in a way that complies with privately-owned company this Code and is equitable, fair, and just according to the situation. • An interest that otherwise produces a significant amount of income for or GIFTS OF A NOMINAL VALUE — gifts that are generally valued at $50.00 or constitutes a significant part of your or your family member's net worth less per gift and $150.00 per source per calendar year excluding: MEDIA INQUIRIES — include requests for information through video, • Items that you pay market value for or promptly return printed materials, telephone interviews, personal interviews, news confer- • Promotional items with logos ences, graphics, photography, slides, speeches, and special events.

• Food items that are meant to be shared, e.g., food baskets MISCONDUCT — includes theft or misuse of Assets, fraudulent or negligent financial reporting, conflicts of interest, expense account abuse, vendor-relat- IN GOOD FAITH — when a report is made and there is a reasonable factual ed fraud, check fraud, and harassment. Read our Policy on Protection from basis for the report. Retaliation and Reporting Possible Unethical Conduct. INTELLECTUAL PROPERTY — includes copyrights, patents, trademarks, trade secrets, and business strategies.

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Glossary/Definitions GLOSSARY

PAY TO PLAY — a concept used in some state and federal laws that prohibits government contracts in exchange for having made a political contribution to a covered official.

REVOLVING DOOR — refers to the movement of personnel between em- ployment as legislators, regulators, and lobbyists, and those affected by the legislation and regulations that such individuals worked on.

SIGNIFICANT RELATIONSHIP — a Significant Relationship includes: • Family members who are your and your spouse’s or domestic partner’s par- ents, siblings, and their spouses or domestic partners, and children (natural, adopted, foster) • Individuals with whom there is a professional, economic, dependent, ro- mantic, or close personal relationship

SYSTEMS — are any processes we use to conduct our operations.

WORKPLACE — includes all AARP-owned or leased buildings, work areas, adjoining grounds, and parking facilities. The Workplace also includes busi- ness trips and off-site meetings and conventions as well as when employees work off-site or telecommute.

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