At the Bill & Melinda Gates Foundation, we act with integrity and abide by the highest ethical standards.

Code of Conduct

This Code of Conduct specifies each employee’s responsibilities to ensure a foundation-wide culture of respectful, ethical behavior and good stewardship.

We are honest, fair and trustworthy in our foundation activities and relationships

The foundation’s commitment to integrity starts with each individual. This means that we go beyond simply obeying the laws governing our work. We act honestly and treat others fairly. If confronted with a questionable situation, we take action to protect the foundation’s reputation--its most valuable asset. When in doubt, apply Warren Buffett’s rule:

  • I want employees to ask themselves whether they are willing to have any contemplated act appear the next day on the front page of their local paper – to be read by their spouses, children and friends – with the reporting done by an informed and critical reporter.

We always treat colleagues and others with respect

Our global work means that we encounter people of every background and experience. We acknowledge these differences, endeavor to create an inclusive environment and treat everyone with fairness, dignity and respect. This principle of fairness extends to every part of our work, including hiring, promotions and working with grantees, partners and others.

We follow foundation policies

Foundation policies provide the basis for this Code and guide our conduct and day-to-day work. We are committed to upholding these policies, including disciplined stewardship of the foundation’s assets. These are serious matters and violation of foundation policy or the law may become the basis for disciplinary action, including termination of employment, criminal penalties and civil liability.

We report integrity concerns

If you believe a colleague, grantee, vendor or other third party has engaged in inappropriate behavior, bring the situation to the attention of a foundation manager, HR business partner, or member of the Legal Team. You may also utilize EthicsPoint, an anonymous ethics reporting service.

The foundation is committed to protecting whistleblowers. Responders will treat a report of unethical or illegal conduct as confidential in a manner consistent with the need to investigate and prevent or correct the action. If you report in good faith what you perceive to be wrongdoing, violations of law, or unethical conduct, the foundation will take steps to protect you from retaliation.

Cooperate with internal investigations

If you are asked to assist the foundation with an internal investigation, your good-faith cooperation is required.

Creating an organization where we are all proud to work will be achieved by upholding the key elements of this Code of Conduct: acting with integrity and honesty, being fair and respectful to colleagues and partners, following the law, being good stewards of the foundation’s assets, and holding one other accountable.


Conflict of Interest

The foundation's Conflict of Interest Policy requires employees to disclose relationships with a potential grantee or vendor and provides guidance on managing conflicts. 

Purpose/General Rule

The purpose of this policy is to provide guidance in identifying and handling potential and actual conflicts of interest involving the foundation. In most instances, conflicts of interest can be avoided simply by continuing to exercise good judgment and, indeed, the foundation relies on the sound judgment of its employees to prevent many such conflict situations. 

The foundation is committed to the highest levels of integrity. Employees of the foundation are expected to conduct their relationships with each other, the foundation, and outside organizations with objectivity and honesty. The general rule is that: foundation employees are obligated to avoid and disclose ethical, legal, financial, or other conflicts of interest involving the foundation, and remove themselves from a position of decision-making authority with respect to any conflict situation involving the foundation.

Read the full policy (6 pages, 628KB, PDF)