Relevant ARIN Employee Handbook Policies

The following are excerpts from the ARIN Employee Handbook Policies relevant to Standards of Conduct.

Business Ethics and Conduct/Whistleblower Policy

The successful business operation and reputation of ARIN is built upon the principles of fair dealing and ethical conduct of our employees. Our reputation for integrity and excellence requires careful observance of the spirit and letter of all applicable laws and regulations, as well as a scrupulous regard for the highest standards of conduct and personal integrity.

The continued success of ARIN is dependent upon our customers’ and members’ trust and we are dedicated to preserving that trust. Employees owe a duty to ARIN, its customers, and members to act in a way that will merit the continued trust and confidence of the public.

ARIN will comply with all applicable laws and regulations and expects its directors, officers, and employees to conduct business in accordance with the letter, spirit, and intent of all relevant laws and company policies, and to refrain from any illegal, fraudulent, wasteful, dishonest, or unethical conduct.

In general, the use of good judgment, based on high ethical principles, will guide you with respect to lines of acceptable conduct. If a situation arises where it is difficult to determine the proper course of action, the matter should be discussed openly with your Department Director for advice and consultation.

Compliance with this policy of business ethics and conduct is the responsibility of every ARIN employee. Appropriate disciplinary action may be taken against any employee willfully violating this policy.

To the extent any employee believes that the standards and requirements of this policy are being violated, that employee should notify any of the following: Chairman of the Board of Trustees, President/Chief Executive Officer, Chief Human Resources Officer, or General Counsel.

If an employee wishes to anonymously report any misconduct and/or violation of company policies observed at ARIN, ARIN also offers an anonymous toll-free whistleblower hotline service administered by a third-party vendor, NAVEX Global EthicsPoint.

There will be no retaliation against any employee for making a complaint or report of perceived violation of ARIN business policies or conduct contrary to this policy, and there will be no retaliation against any employee for cooperating in an investigation into any report made under this policy.

Conflicts of Interest

Employees have an obligation to conduct business within guidelines that prohibit actual or potential conflicts of interest. The purpose of these guidelines is to provide general direction so that employees can seek further clarification on issues related to the subject of acceptable standards of operation. Contact the HR and Administration Department for more information or questions about conflicts of interest.

An actual or potential conflict of interest occurs when an employee is in a position to influence a decision that may result in a personal gain for that employee or for a relative as a result of ARIN’s business dealings. For the purposes of this policy, a relative is any person who is related by blood or marriage, or whose relationship with the employee is similar to that of persons who are related by blood or marriage.

No “presumption of guilt” is created by the mere existence of a relationship with outside firms. However, if employees have any influence on transactions involving purchases, contracts, or leases, it is imperative that they disclose to an officer of ARIN as soon as possible the existence of any actual or potential conflict of interest so that safeguards can be established to protect all parties.

No ARIN employee, or relative of an ARIN employee, may substantially or materially benefit or personally gain, directly or indirectly, by virtue of any service provided by ARIN including but not limited to Internet Number resource requests or transfers. Personal gain may result not only in cases where an employee or relative has a significant ownership in a firm with which ARIN does business, but also when an employee or relative receives any kickback, bribe, substantial gift, or special consideration as a result of any transaction or business dealings involving ARIN. If a situation arises where it is difficult to determine a potential conflict, the matter should be discussed openly with your Department Director for advice and consultation.

To demonstrate to our membership that ARIN employees are fully committed to serving our membership without any conflict of interest, ARIN employees are not permitted to be independent members of ARIN or of the other four regional Internet registries.

Gift Policy

Due to the nature of our work, it is imperative that ARIN employees perform their jobs in a manner that elicits and sustains ARIN’s current trust and respect from everyone in the Internet Community. Accordingly, ARIN generally prohibits employees from accepting any gifts, favors, or gratuities from individuals, consultants, or companies that do business with us. No employee shall solicit, accept, or agree to accept, anything of value under circumstances that could reasonably be expected to influence the manner in which the employee performs work or makes decisions.

Token gifts or giveaways/raffle prizes of a promotional advertisement nature (value of less than $25) such as coffee mugs, t-shirts, pens, calendars, and other small items may be accepted. Any items with a value more than or in excess of $25 should be declined. On occasion, it is permissible for employees to give or receive a meal or entertainment of modest value (definition of modest means that the cost of the meal or entertainment does not exceed per diem for the location), so long as a definite business purpose is being served. For example, it is permitted to give or receive such entertainment while traveling overseas in circumstances where it would be inhospitable to refuse. Employees may accept occasional lunches, dinners, or entertainment events of modest value paid for by our vendors, members or customers, but only if the vendor, member, or customer attends the event, and there is no extended practice of doing so without management permission.

Accepting a gift or entertainment is often a professional decision; and ARIN stresses the importance of making prudent and conservative judgement with regards to this policy. When in doubt, do not accept the gift or entertainment offer. Additionally, employees should exercise thoughtful diligence with the ARIN community and specifically ARIN members. This is intended to avoid the perceptions of employees having a conflict of interest.

Employees who are given or offered a gift, entertainment, or preferred treatment not consistent with these guidelines should refuse to receive the gift, or seek advice concerning the matter from ARIN’s Chief Operating Officer, Chief Human Resources Officer, or General Counsel.

Last Updated: 29 Sep 2023