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. Those who report illegal or improper activity in good faith will be protected 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.


Ethical Conduct and Governance

What follows is the foundation's "whistleblower" policy in its entirety. It is addressed to our employees.

The foundation is committed to lawful and ethical behavior in all of its activities and requires its employees to conduct themselves in a manner that complies with all applicable laws and regulations. If at any time a concern exists regarding the propriety or legality of any action contemplated to be taken or that has been taken by any foundation employee, or grantee, contractor, vendor, as the action relates to foundation activities, or if an action needs to be taken in order for the foundation to be in compliance with law or appropriate ethical standards, you can address the issue directly by going to your manager or to the next level of management as needed until matters are satisfactorily resolved.

Alternatively, if you are not comfortable speaking to a manager or do not feel your issue has been properly addressed, you may contact the Chief Human Resources Officer, General Counsel, or the Chief Executive Officer. If you do not believe that these channels of communication can/should be used to express their concerns, you may utilize the anonymous hotline service the foundation has established with EthicsPoint. If you are not comfortable with these alternatives you may also contact the foundation's outside legal counsel. (An internal Web site provides employees with contact information for the foundation's outside legal counsel.)

Under this policy (sometimes referred to as a "whistleblower policy"), those who report illegal or improper activity will be protected. Efforts will be made to treat a report of unethical or illegal conduct as confidential, consistent with the need to investigate and prevent or correct the action. The individual making the report will not be discharged, threatened, harassed, or discriminated against for reporting in good faith what they perceive to be wrongdoing, violations of law, or unethical conduct.

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)