HouseKeys Global Conflict of Interest and Gift Policy
Purpose: HouseKeys is committed to upholding the highest ethical standards in its administration of affordable housing programs and contracts with local government agencies and homebuilders. This policy provides clear guidance to employees, applicants, contractors, vendors, and other stakeholders to prevent conflicts of interest and maintain transparency, impartiality, and fairness in all operations.
Scope:
This policy applies to:
All HouseKeys employees, officers, and directors.
Program applicants, customers, and participants.
Family members or associates of HouseKeys employees.
Third-party contractors and vendors, including but not limited to Loan Officers, Real Estate Agents, Housing Counselors, Interpreters, and others who work with or on behalf of HouseKeys.
Stakeholders, including government agencies and investors.
Chief Compliance Officer (CCO):
The CCO is responsible for overseeing compliance with this policy. In the event that a CCO has not been appointed or the position is vacant, the CEO will serve as Interim Chief Compliance Officer until the role is filled.
1. Conflicts Related to Employee Participation in Programs and Drawings
Policy:
HouseKeys employees are prohibited from applying for any programs administered by the company or entering any program-related drawings or lotteries. This ensures that employees do not unfairly benefit from the programs meant for the public or external participants.
Disclosure and Enforcement: Employees who violate this policy may face disciplinary action, including termination.
2. Conflicts Related to Family Members or Associates of Employees
Policy:
If an employee has a family member, close associate, or related party who applies for a program, that employee is prohibited from having final underwriting or decision-making authority over the application or any related actions.
Disclosure Requirement: Employees must disclose any relationships with program applicants to their supervisor or the CCO. If the CCO position is vacant, disclosure must be made to the CEO acting as Interim CCO. A neutral party will be assigned to handle the file to ensure impartial decision-making.
3. Conflicts Involving Third-Party Contractors and Vendors
Policy:
Third-party contractors and vendors working with HouseKeys, including but not limited to Loan Officers, Real Estate Agents, Housing Counselors, Interpreters, and others, are prohibited from engaging in activities that could create conflicts of interest. This includes:
Vendors applying for programs: Contractors and vendors working with HouseKeys may not apply for programs or enter drawings related to the company’s administered services.
Impartiality in decision-making: Vendors who work on behalf of HouseKeys, such as Loan Officers or Real Estate Agents, must maintain impartiality when assisting program participants and are prohibited from influencing decisions that benefit themselves or their associates.
Disclosure Requirement: Vendors must disclose any potential conflicts, including personal relationships with program applicants or customers, to HouseKeys.
Enforcement: Contractors and vendors who violate this policy may have their contracts terminated and may be barred from working with HouseKeys in the future.
4. Investment Conflicts Related to Crowdfunding Campaigns
Policy:
HouseKeys employees, applicants, third-party contractors, and vendors may participate in crowdfunding campaigns (e.g., StartEngine) for the company, provided that:
Employees: Employee investments are entirely voluntary and will not affect their employment status or career progression. Employees must invest based on their independent judgment and are prohibited from exerting any undue influence on others to invest.
Applicants and Customers: Applicants, customers, and program participants who choose to invest must do so with the understanding that their investment does not entitle them to preferential treatment in any HouseKeys programs or services.
Contractors and Vendors: Third-party contractors and vendors who invest in HouseKeys must do so without expecting any special treatment in contracts, projects, or program administration.
Disclosure: Any employee, applicant, vendor, or other related party investing in a HouseKeys campaign must acknowledge that their investment is not intended to influence their standing with the company or any programs offered.
5. Insider Information Prohibition
Policy:
Employees, contractors, vendors, officers, and others with access to non-public, material information about HouseKeys are prohibited from using that information to gain an unfair advantage in any investment, business decision, or program participation.
Enforcement: Violations of this policy will result in disciplinary action, including termination for employees or termination of contracts for vendors, and may result in legal consequences as per applicable laws.
6. Restrictions on Gift-Giving by Applicants, Contractors, Vendors, and Employees
Policy:
Gifts from Applicants, Contractors, or Vendors: HouseKeys employees are prohibited from accepting gifts, monetary or otherwise, from applicants, customers, contractors, or vendors if the gift is intended to influence any decision or action related to the applicant’s file, contract, or program participation.
Exception: “Thank You” gifts of nominal value (under $50), given after decisions have been made and without intent to influence future actions, may be accepted at the discretion of the employee’s manager. These must be disclosed to the CCO (or the CEO acting as Interim CCO).
Violation: Any attempt by applicants, contractors, or vendors to influence decisions through gift-giving will result in disqualification from the program, service, or contract.
Gifts to Government Employees: HouseKeys employees are strictly prohibited from providing gifts, meals, or other forms of hospitality to employees of government agencies with whom HouseKeys contracts. This is to comply with legal and ethical standards governing public officials and prevent any appearance of impropriety.
7. Governance and Voting Rights in Crowdfunding
Policy:
Employees, customers, contractors, vendors, or stakeholders who acquire voting rights through investments in HouseKeys’ crowdfunding campaigns are required to recuse themselves from voting on decisions directly related to any programs or services they benefit from, or if they are in a position to influence program administration.
Non-Voting Shares: HouseKeys reserves the right to issue non-voting shares in its crowdfunding rounds to employees, customers, contractors, vendors, and program participants to prevent governance conflicts.
8. Disclosure and Reporting Requirements
For Employees, Contractors, and Vendors: Employees, contractors, and vendors must disclose any conflicts, such as family relationships with applicants, business relationships, or investments in HouseKeys, to the CCO or, if the CCO position is vacant, the CEO acting as Interim CCO.
For Applicants: All program applicants will acknowledge and agree to this policy by checking a box during the application process. This ensures they understand and accept the terms regarding gift-giving, conflict of interest, and impartiality.
9. Enforcement and Non-Compliance
Employees: Failure to comply with this policy may result in disciplinary action, up to and including termination.
Applicants, Contractors, and Vendors: Violation of this policy by applicants, contractors, or vendors, including attempts to influence decisions through gifts or other actions, may result in disqualification from participation in programs or termination of contracts with HouseKeys.
10. Policy Review and Updates
This policy will be reviewed annually to ensure compliance with current laws and regulations. Any necessary updates will be made to address emerging conflicts or changes in operations.