Connor does not tolerate bribery, kickbacks, or corrupt acts of any kind or in any circumstances from Connor staff, or its clients, agents, consultants, licensees, vendors, or representatives of any kind.
Corruption is the misuse of power for private profit or gain. Bribery is broadly defined as offering to make or making a payment, or offering to provide or providing anything of value, to influence a decision or create an improper advantage. This prohibition includes making or offering to make payments through intermediaries or to third parties; and it does not require that payments actually be made.
Staff must abide by all applicable anti-bribery and anti-corruption laws. All Connor staff in all countries are subject to the U.S. Foreign Corrupt Practices Act (“FCPA”). The FCPA prohibits improper payments to government officials and officials of public international organizations. Connor staff living or working in countries other than the US may also be subject to national anti-corruption laws. All staff are required to raise potential issues before they lead to problems and to seek additional guidance when necessary.
Connor considers compliance with anti-corruption laws, and with Connor’s internal policies relating to anti-corruption, to be a serious matter, and will thoroughly investigate any allegations of bribery. Connor employees, and others working on Connor’s behalf or for its benefit, who do not comply with such laws and policies may be subject to disciplinary action up to and including termination of their employment or other relationship. In addition, individuals violating applicable anti-corruption laws may be subject to a range of penalties, which could include fines and imprisonment.
Connor Consulting Corp takes a zero-tolerance approach to fraud, bribery, and corruption and will uphold all applicable laws relevant to countering and investigating such activities across its global operations.
Connor is committed to:
Connor’s Anti-fraud policy applies to all staff members, Connor contractors, experts, consultants and grantees. It is an integral part of Connor’s internal control policy framework and should be read and applied in conjunction with Connor’s Code of Ethics. It forms part of a series of related policies and procedures developed to provide sound internal financial controls and to counter any fraudulent activity. These include: codes of conduct for staff and trustees; anti-corruption and bribery policy; sanctions policy; safeguarding policy; privacy policies; sound internal control systems; effective internal audit; effective recruitment and selection procedures; disciplinary procedure; public interest disclosure (whistleblowing) procedures; and training.
Connor has established an ‘Ethics Hotline’ to ensure that persons can report fraud. Anyone with information regarding fraud or other corrupt practices against Connor or involving Connor staff, non-staff personnel, vendors, implementing partners and responsible parties, is strongly encouraged to report this information through the Hotline and will not be retaliated against for submitting such claim in good faith. The Investigations Hotline is managed by an independent service provider on behalf of Connor to protect confidentiality, and can be directly accessed worldwide in different ways:
Alternatively, complaints can be sent directly to Connor by emailing firstname.lastname@example.org. or by mail to:
Connor Consulting Corp.
300 Brannan St. Suite 207
San Francisco, California 94107
Attn: Privacy Officer
All allegations of fraud and corruption are taken seriously. Upon receipt of an allegation, Connor will assess the case and to determine if there is sufficient ground to warrant an investigation. Investigations will follow the guidelines outlined below.
Depending on the nature, magnitude and the complexity of the fraud, investigations will be carried out by either Connor’s General Counsel or by an external firm with specific expertise to deal with the particular allegation.
Investigations will be conducted without regard to any person’s relationship to the organization, position or length of service. The investigating party will have full access to any files, information or witnesses to conduct the investigation and will keep records of all actions in the investigation, to ensure success in any future criminal, civil or disciplinary action.
The investigating party will issue a report detailing the finding and conclusion of the investigation, including recommendations for future action. The report will be disseminated to and reviewed by Connor’s Senior Leadership and Audit Committee in a timely manner. Unless earlier notice is required by the donor, Connor will inform other parties, including affected employees, external partners and donors of the conclusion of the report as needed.
In cases of substantiated fraud, Connor will pursue disciplinary or criminal sanctions where appropriate and possible and will attempt to recover losses by any lawful means.
Connor Consulting Corp’s (“Connor”) reputation derives from our commitment to our core values: collaboration, integrity, positivity, trust, diversity, accountability and accessibility for our customers and partners. Connor’s Code of Ethics (the “Code”) provides guidance to Connor employees, consultants, independent experts, interns, and volunteers in living Connor’s core values, and outlines minimum standards for ethical conduct which all staff must adhere to.
Connor relies on the personal integrity, good judgement and common sense of individuals acting on behalf of the organization to deal with issues not expressly addressed by the Code. Failure of a staff member to adhere to the Code may result in disciplinary action up to and, including discharge from employment and filing of criminal charges.
Connor employees, consultants, independent experts, interns and volunteers shall:
Any violations of the Code of Ethics should be reported to Connor Consulting Corp via its Ethics Hotline at www.ci.ethicspoint.com.
All staff member shall at all times exercise good faith in all matters relating to their duties and responsibilities to Connor, act in the best interest of Connor when discharging their duties and comply with Connor’s Code of Ethics.
No staff member shall use their position or confidential information obtained in the course of employment to their personal advantage or for any other purpose not specifically approved by Connor or be influenced in the discharge of their duties by any personal, financial, or other interest, involvement or relationship they may have.
Each employee is responsible for recognizing a potential conflict-of-interest and for disclosing it pursuant to the procedures described below.
A conflict of interest exists or may exist whenever an employee or his/her family member has any involvement, interest or relationship, directly or indirectly, in a proposed transaction with Connor from which the employee or his/her family member receives, or may be perceived as receiving, a financial or other personal benefit. Employees are required to report each such transaction with a family member, regardless of whether preceding transactions with the same family member have been reviewed and approved.
A “family member” is defined as a spouse or domestic partner, children and their spouses, parents, siblings and their spouses, grandparents, grandchildren and their spouses, aunt, uncle, first cousin, niece, nephew, corresponding in-law, and respective “step” relations.
Some examples of conflict requiring disclosures are included below. This list is not intended to be exhaustive.
All Connor employees are required to complete and sign annual conflicts of interest disclosure forms. These forms are provided to employees at the start of each fiscal year by the General Counsel’s Office (GCO).
In addition to these annual disclosures, if a proposed transaction arises in which an employee has, or believes s/he may have, a conflict of interest, the employee is required to make an immediate disclosure to the GCO and his/her immediate supervisor, using the conflicts of interest disclosure form available on the Intranet. This disclosure must be done prior to any consideration or execution of the proposed transaction by Connor.
The employee shall not participate in the deliberations on the matter but shall disclose any material facts related to the proposed transaction. Upon a determination by the GCO that a conflict of interest exists, the GCO, working with the supervisor or division head, may request that that appropriate actions be taken to resolve the matter. The GCO shall maintain a record of the existence and resolution of the conflict of interest. In some cases these conflicts may be reported in public filings. If the matter cannot be resolved in a satisfactory manner, but the employee, his/her supervisor and/or the respective division head are of the opinion that the transaction is nonetheless beneficial to the overall interests of Connor, the respective division head and the Connor shall bring the matter to the attention of the Chief Executive Officer who shall make the final determination whether to pursue the transaction; provided, however, that if the employee is also an officer or in a position to exert substantial influence over the affairs of the organization, then the matter is referred to the Compensation Sub-Committee of Connor’s Board of Directors in accordance with its procedures for addressing conflicts of interest.
Employment of Family Members may constitute a conflict of interest. Employees must disclose all such relationships to their supervisor and to the GCO using the conflicts of interest disclosure form available on the Intranet, or the annual disclosure form as appropriate. This disclosure must be done prior to employing any Family Members.
Employees who marry while employed or become part of the same household will be treated in accordance with the policy on personal relationships.
Employees may not engage in any outside consulting or employment that conflicts with the interests of Connor. Employees are required to fulfill the responsibilities of their position, and any external employment activity that results in neglect of the employee’s job responsibilities is inappropriate. Employees should obtain written approval from their supervisor and the division head to engage in any outside consulting activity or employment.
A cookie is a small file placed onto your device that enables certain features and functionalities on our Sites. For example, cookies enable us to identify your device and to help us serve relevant content to you.
Connor drops cookies to improve your experience on our website. For example, we may use these cookies to suppress certain lightboxes or experiences that you have already visited. Our cookies are not associated with Personal Information we collect from you. Deletion of these types of cookies will result in limited functionality of our Site and services.
Most browsers allow you to control cookies through their settings preferences, including a setting to automatically decline cookies or be given the choice of declining or accepting the transfer to your computer of a particular cookie (or cookies) from a particular site. However, if you limit the ability of websites to set cookies, you may negatively impact your overall user experience, since it will no longer be customized to you. For example, because your cookie preferences are stored as a cookie on your browser, if you do not opt in, our cookie opt-in banner will display every time you access a page on Connor’s site.
If you do not want to receive cookies, you can also change your settings via Connor’s cookie banner when accessing our site for the first time. You may also change your cookie settings on Connor’s web site at any time by visiting our Cookie Table page. Find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit wikipedia.org, www.allaboutcookies.org, or www.aboutcookies.org.
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For information related to the processing of personal information about our job applicants, please see our Recruitment Privacy Notice Privacy
Personally-Identifiable Information (“Personal Information”) is information that identifies you, such as your name, phone number, email address, mailing address, credit card number (if you use a credit card to make a donation), or organizational affiliation. Connor and Connor’s service providers only collect Personal Information when you submit such information to sign-up for our personalized services, for example when you sign up for the Connor newsletter or donate.
When you visit our Sites, some information is automatically collected from devices used to visit our Sites, including your computer’s IP address, browser type, browser language, pages you viewed, how long you spent on a page, access times and information about your use of and actions on our Site.. We also get information about in-bound domain names and pages viewed. This data tells us which pages our users visit and what information they volunteer, such as survey information, e-book download registration and/or site registrations.
We may log information using “cookies.” Cookies are small data files stored on your hard drive by a website. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Site. This type of information is collected to make the Site more useful to you and to tailor the experience with us to meet your special interests and needs.
We also collect information about your usage and activity on our Sites using certain technologies, such as cookies, web beacons and other technologies.
(see our Cookies Policy for more details).
We will only collect and process Personal Information about you where we have lawful bases. Lawful bases include consent (where you have given consent) and our legitimate interest in operating, managing and promoting our organization, maintaining our relationship with you and protecting Connor and our Sites provided that such processing shall not outweigh your rights and freedoms. Where we rely on your consent to process personal data, you have the right to withdraw or decline your consent at any time and where we rely on legitimate interests, you have the right to object. If you have any questions about the lawful bases upon which we collect and use your personal data, please contact email@example.com.
We use your personal information as follows:
Examples of uses of Personal Information where you have given consent are:
Examples of use and sharing of Personal Information for legitimate interests are:
We may combine and use data analysis to interpret your information and predict how likely you are to be interested in or responsive to a particular campaign or fundraising communication. If we conclude that you have the potential or interest in supporting Connor’s efforts at a higher level, we may collect additional publicly available information about you and combine and analyze that information into a donor profile, which allows us to engage with you in a customized manner that is responsive to your supporter interest. We commonly look at and combine information from public information resources and other data sources that you chose to make available publicly on your social media channels to give insight into your philanthropic interests and ability to support us. In addition, we may use trusted third party companies that analyze and measure available information to assess affluence. This helps us understand more about your interests and level of potential engagement or donation. Examples of companies that assist us in this process are WealthX and Blackbaud. You can opt out of your data being combined and analyzed for prospect research by contacting us as described in Section 3 (Your Choices).
In some instances, we may combine Personal Information with Device Information or Location Information. If we do, we will treat the combined information as Personal Information as long as it is combined.
We may aggregate non-personally identifiable information collected from you and other users as well as Device Information or Location Information to produce general statistics that cannot be linked to your or any specific user and with which we attempt to provide you with a better experience on our Sites, to improve services, and to analyze and understand how our Sites are used.
We may also share aggregated and/or anonymized data with others for their own uses.
We may share your Personal Information as follows:
Some of the ways we use your Personal information require us to share information with third parties, so we can provide an effective user experience and comply with laws that apply to us:
Law enforcement agencies or government agencies. We only share information if we believe that disclosure is reasonably necessary to comply with a law, regulation or legal request; to protect the safety, rights, or property of the public, any person, or Connor; or to detect, prevent, or otherwise address fraud, security or technical issues.
Affiliates. If we were to engage in a merger, acquisition, bankruptcy, dissolution, reorganization, or similar transaction or proceeding that involves the transfer of the information described in this Policy, we would share your information with a party involved in such a process (for example, the successor organization of Connor).
We keep your Personal Information only so long as we need it fulfill the purposes described in this policy. When we no longer need to use your Personal Information and there is no need for us to keep it to comply with our legal or regulatory obligations, we will either remove it from our systems or depersonalize it so that you cannot be identified.
You can control the type of information collected through our Sites, for example by not accepting cookies from Connor, by erasing all Connor cookies from your browser, or by not providing Personal Information when prompted.
Our marketing emails tell you how to “opt-out.” If you opt out, we may still send you non-marketing emails. Non-marketing emails include emails about your accounts and our business dealings with you.
You may send requests about personal information to our Contact Information below. You can request to change contact choices, opt-out of our sharing with others, and update your personal information.
You can typically remove and reject cookies from our Site with your browser settings. Many browsers are set to accept cookies until you change your settings. If you remove or reject our cookies, it could affect how our Site works for you.
If you wish to update your Personal Information with us or change your communications preferences or if you no longer wish to receive communications from us, please click on the “unsubscribe” link in the email to unsubscribe or tell us so by email, phone, or written letter. Please include your exact name and contact details so that we can correctly remove you from our mailing list. Our mailing address is: Connor Consulting Corp. 300 Brannon Street, Suite 511, San Francisco, California 94107. We can be reached via email at firstname.lastname@example.org or by telephone at (415) 678-5002.
If you are a resident of the United States and would like to opt-out of receiving text messages, that you previously signed up for, text STOP to 21333.
We use appropriate and reasonable administrative, physical, and technical measures to safeguard Personal Information controlled by Connor. Only employees who need the information to perform a specific job are granted access to personally identifiable information.
All online donation transactions are encrypted using the Secure Socket Layers (SSL) protocol. Such transactions are processed through Blackbaud, a VeriSign secured and PCI DSS compliant gateway provider, and are not stored or processed on Connor’s servers. Blackbaud acts as the controller of your credit or debit card information. PCI DSS is the payment card industry security requirement for entities that store, process or transmit cardholder data. PCI DSS Compliance gives consumers the confidence they need to know that organizations accepting donations are doing so in a verified, secure, and consistent fashion. Convio received Level 1 PCI compliance – the highest level validation. The use of VeriSign SSL Certificates provide for the highest level of encryption available. These comprehensive standards are intended to help Connor proactively protect your account data — a responsibility we take very seriously. For more information, visit https://www.blackbaud.com/security/pci-compliance.
Our Sites contains links to other websites. We are not responsible for the privacy practices or the content of such websites.
Connor, with its partnership and commitment to Security and Privacy with Microsoft, also provides a link to their Privacy Statement.
We recognize the importance of protecting the privacy of children on the web and will never collect or maintain information at our website from those we actually know are under 13 years old. No part of our website is directed at children under the age of 13, and we do not knowingly collect Personal Information from children under age 13. If we discover that a person under the age of 13 has provided us with any Personal Information, we will delete that information from our systems. We do not reply to information requests from children under the age of 13, if so identified. A parent or guardian must initiate any requests for information from children under the age of 13 on their behalf. We encourage parents to supervise children when they browse the internet.
It is our policy not to disclose any Personal Information we collect to third parties for direct marketing purposes under any circumstances. However, California Civil Code Section 1798.83 requires that all California residents be afforded the option to exercise their choice of whether Personal Information may be shared with third parties for direct marketing purposes or not, as well as to receive information specified in the statute if Personal Information is disclosed to third parties for direct marketing purposes.
If you are a California resident, effective January 1, 2020 you have the following additional rights:
Only you, or a person you designate to act on your behalf, may make a verifiable consumer request related to your personal information. We may request that your authorized agent have written authorization to make the request on your behalf and may need to verify the authorized agent’s identity.
In some instances, you may be requested to verify your identity prior to access or deletion of your personal information such as a government issued ID. Once identity has been verified, the request will proceed.
Accordingly, you are a California resident and if you wish to inform us whether you permit or refuse the sharing of your personal information with third parties for direct marketing purposes, or if you wish to request certain information if your personal information were to be disclosed to third parties for direct marketing purposes, please contact us as described in the Section 3, Your Choices.
In accordance with applicable law, you are entitled to know what personal information we hold about you and you may ask us to make any necessary corrections to ensure that it is accurate and kept up to date. Under applicable law, you also have the right to request deletion of your personal information or to object to the processing of your personal information. If you wish to exercise your rights, please contact us as detailed in Section 3 (Your Choices). You may also have a right to complain to your data protection authority. Although Connor is a global company, our headquarter is based in the United States. Please be aware that if you submit information to us, it will be stored on servers in the United States.
You can contact us as described in Section 3 (Your Choices) to enforce your privacy rights at any time, including to access your data, ask for your data to be updated, amended or deleted as well as to oppose the way we use your personal data. You may also contact us to request to revoke your previously granted consent to the extent permitted by law. Through the same contact data, we may inform you about:
If you have any questions, comments, or complaints about our collection, use, or disclosure of personal information, or if you believe that we have not complied with this Policy or the Privacy Act 1988 (Cth), please contact us as detailed in Section 3 (Your Choices). When contacting us, please provide as much detail as possible in relation to your question, comment, or complaint. We will take any privacy complaint seriously and any complaint will be assessed by an appropriate person with the aim of resolving any issue in a timely and efficient manner. We request that you cooperate with us during this process and provide us with any relevant information that we may need. If you are not satisfied with the outcome of our assessment of your complaint, you may wish to contact the Office of the Australian Information Commissioner. For more information, please refer to www.oaic.gov.au.
Your Personal Information may be stored and processed in any country where we have facilities or service providers, and by using our Sites and providing Personal Information to us, or by providing consent to us (where required by law), you agree to the transfer of information to countries outside of your country of residence, including to the United States, which may provide for different data protection rules than in your country. Where required, we have implemented appropriate cross-border transfer solutions to provide adequate protection for transfers of certain personal information, including, but not limited to, the European Commission’s Standard Contractual Clauses.
We reserve the right to modify or supplement this policy at any time. If a material change to this policy is made, we will post a notice on the home page, and any changes to the policy will be posted on this page.
If you have any questions about our privacy statement or the practices of this site, please contact us at email@example.com.
Connor Consulting Corp.
300 Brannan St. Suite 511
San Francisco, California 94107
Attn: Privacy Officer
The purpose of this Notice is to explain how Connor Consulting Corp collects, uses and handles (processes) personal information about our job applicants in connection with our online and offline recruitment activities and to explain the rights that they have under data protection law. In this Notice, we refer to this type of information as “Recruitment Data”.
This Notice applies to applications submitted via our website and third parties, such as recruitment agencies and job boards. It also applies to applications submitted via other means, such as by post, recruitment events and email.
Connor Consulting Corp means Connor and any of its subsidiaries and affiliates, as existing from time to time. Conservation International is also referred to in this Notice as “we”, “us” or “our”.
We will generally only collect Recruitment Data in the recruitment process that is necessary to assess you for the position for which you have applied. This may include the following categories of data:
We generally receive Recruitment Data either (a) directly from you (for instance when you provide information as part of your application or during the recruitment process) or (b) from third parties (for instance from recruitment agencies). We will indicate where the information we have requested is mandatory or optional. We will also explain the consequences should you decide not to provide information which we have indicated is mandatory. In some circumstances this may mean we are unable to process your application.
Note: Background check information (such as criminal background, credit check depending on the position you apply for and the region where the position is located) will only be sought where permitted by applicable law and is subject to execution of a separate, specific consent. Connor collects disability related information only to the extent volunteered by you and will process such information only to the extent allowed and in accordance with applicable law.
The main purposes for which we use your Recruitment Data include:
We may verify the Recruitment Data you provide during the recruitment process and/or collect personal data about you from third party sources to assist with our “Pre-Employment Checks”. If this occurs:
We will only process your Recruitment Data where we have a legal basis for doing so. Generally, we will be processing it to help us to decide whether to enter into a contract of employment with you. At other times, we will be processing your Recruitment Data because you have consented to us doing so, in which case you can withdraw such consent at any point.
We may also process your Recruitment Data to comply with our legal obligations or because it is in our legitimate business interests to do so (for example, where it is necessary to understand our applicants in sufficient detail so we can operate an effective recruitment process).
(a) Within Connor
We restrict access to Recruitment Data to people within our group of companies who have a “need to know” such information. For example, certain individuals within Connor will have access to your Recruitment Data in order to process your application and manage the recruitment process (this may include individuals in our Human Resources team and individuals to whom you would report if your application is successful).
(b) Outside Connor
We share Recruitment Data with authorized third-party service providers to conduct and manage the recruitment process. For example, we may share your Recruitment Data with such service providers in order to conduct screening and verification of your application and the information you have provided to us. This may include verifying academic and professional qualifications. Generally, we will only disclose your Recruitment Data to our suppliers and other third parties in the following circumstances:
We keep your Recruitment Data in accordance with our internal retention policies and procedures. Typically, if you are unsuccessful in your application with us (or if you reject the position), we will keep your Recruitment Data for three (3) years following submission by you.
Applicants in the European Economic Area (the “EEA”) and the UK should be aware that their Recruitment Data may be transferred to, and stored at, a destination outside the EEA and the UK in countries, which have less strict, or no data protection laws, when compared to those in Europe. It may also be processed by staff or our vendors in other non-EEA jurisdictions which also have less strict or no, data protection laws.
Whenever we transfer your Recruitment Data outside of the EEA or the UK, we will take legally required steps to ensure that adequate safeguards are in place to protect your Recruitment Data and to make sure it is treated securely and in accordance with this Notice. If you are located in the EEA or the UK, you may contact us for a copy of the safeguards which we have put in place to protect your Recruitment Data and privacy rights in these circumstances.
You may have the right to request access to, rectification or erasure of, the Recruitment Data we hold about you. You may also have the right to object to or restrict certain types of processing of your Recruitment Data and request to receive a machine-readable copy of the Recruitment Data you have provided to us.
If you notice an error in your application that you would like to correct, please contact us using the contact information below.
Any request to exercise one of these rights will be assessed by us on a case-by-case basis. There may be circumstances in which we are not legally required to comply with your request, for example, because of relevant legal exemptions provided for in applicable data protection legislation.
Please contact us at the address below, if you would like to find out more about any matters relating to this Notice or if you have concerns about the way in which we have processed your Recruitment Data:
Connor Consulting Corp.
300 Brannan St. Suite 207
San Francisco, California 94107
Attn: Privacy Officer
We can also be reached via email at firstname.lastname@example.org or by telephone at (703) 341-2400.
If you are still dissatisfied, you have the right to complain to your Data Protection Authority.
We may change this Notice from time to time in order to reflect changes in the law, regulatory guidance or our data privacy practices in compliance with the law. When this happens and where required by law, we will provide you with a new or an updated notice detailing how the use of your Recruitment Data is changing and, if necessary, obtain your consent for further processing.
This Notice was last updated on April 7, 2021
Connor Consulting Corp’s reputation is a reflection of our commitment to the core values of collaboration, integrity, positivity, trust, diversity, accountability and accessibility for our customers and partners. We are committed to lawful and ethical behavior in all of our activities and require our staff and partners to conduct themselves in a manner that complies with all applicable laws and regulations. If at any time a concern regarding the propriety or legality of any action contemplated to be taken or that has been taken by Connor Consulting Corp., an employee, grantee, or partner arises, please report the issue immediately.
Reports should be submitted to Connor’s Ethics Hotline. This resource provides employees, grantees, and other partners and beneficiaries with a globally accessible, multilingual reporting tool the gives the ability to report incidents anonymously. It is available 24 hours a day, seven days a week, by logging on to at www.connor.ethicspoint.com or by dialing a toll-free number from anywhere in the world where Connor works that can be found on the website.
No employee or any other person will be discharged, threatened, or discriminated against in any manner for reporting in good faith what they perceive to be wrongdoing, violations of law, or unethical conduct.
Retaliation against any person who submitted a claim in good faith is subject to disciplinary action up to and including termination for cause and grantees or partners may be disqualified from submitting future funding proposals to Connor Consulting Corp.