The reputation of Granite Pathways and its parent company, The Fedcap Group, is based on the actions
and behaviors of our employees. Our code of conduct defines our expectations and guiding principles
for appropriate workplace behavior.
Good ethical conduct in the workplace indicates that employees take pride in their company’s ethical
standards and have respect for other employees, customers, suppliers and partners. An employee of
The Fedcap Group (including any Fedcap affiliate) is expected to maintain a working environment that
encourages mutual respect and professionalism, promotes civil and congenial relationships among other
employees, and is free from all forms of harassment and violence. An employee of The Fedcap Group
does not discriminate against other people based on religion, creed, race, color, sex, sexual orientation,
genetic information, national origin, age, gender, gender identity or expression, disability, marital status,
citizenship status, domestic partnership, military status or status as a veteran or any other protected
characteristic in accordance with applicable law. Harassment of any kind is not tolerated, and violations
can lead to termination. Employees reject business gifts that may create the appearance of impropriety
or unfair influence and conflict of interest.
An employee is expected to conduct himself/herself in an appropriate manner as would be judged by a
reasonable person. An employee has the right to perform his/her job without disorderly or undue
interference from other employees.
It is expected that all Fedcap Group employees will maintain the highest ethical standards while
conducting organization business. Each employee is expected to conduct themselves in a manner which
displays integrity and complies with all applicable laws in a manner that excludes considerations of
personal advantage or gain.
Whistleblower Policy
Fedcap Group’s Code of Ethics (“Code”) requires all Fedcap employees, board members and volunteers
to observe high standards of business and personal ethics when performing their respective
responsibilities and acting as agents of Fedcap. It is the responsibility of all employees, board members
and volunteers to comply with the Code and to report violations or suspected violations in accordance
with this policy.
The Whistleblower Policy has been developed to enable Fedcap Group employees, board members and
volunteers to report any concerns they may have with regard to accounting and auditing matters,
conflict of interest issues, disclosure of confidential information, donor stewardship, falsification of
contracts, reports or records, or other serious issues and concerns regarding the operation or
management of Fedcap. These reports may be made anonymously and without fear of retaliation. No
one, who in good faith reports a violation of the Code shall suffer harassment, retaliation or adverse
employment consequence. Any employee who retaliates against someone who has reported a violation
in good faith is subject to discipline up to and including termination of employment.
This policy is intended to encourage and enable employees and others to raise serious concerns within
the organization prior to seeking resolution outside the organization.
To confidentially or anonymously report a complaint or concern about The Fedcap Group, you
can call the EthicsPoint Compliance Hotline 24/7:
USA: 1-833-416-6419
Canada: 1-833-416-6420
Or you can visit www.ethicspoint.com and enter The Fedcap Group to file a new report.