1. Part II: CSO/NGO Codes of Conduct
1 Introduction
A code of conduct is an instrument of self-governance in which an organization or coalition of
organizations “…set down the standards of accountability and transparency which they hold
themselves to, and which they will expect to be held to by their staff, supporters and other
stakeholders”1 based on their core values and guiding principles. NGOs use voluntary codes of
conduct to address accountability issues through public commitment to “principles or standards of
performance to which an organization or a group of organisations voluntary sign up and against which
they are willing to be judged.”2 Generally speaking, NGO codes of conduct address the whole range of
accountability issues including organizational management, project implementation, financial
management, participation, and information disclosure as well as structures and procedures for
enforcement.
1.1 Benefits of Introducing a Code of Conduct
Developing a code of conduct has various benefits at the organizational, coalition and sector levels in
terms of accountability, transparency, and legitimacy. More specifically, the establishment of and
adherence to a code of conduct: increases credibility in the eyes of stakeholders; introduces greater
transparency in management and operation; provides clear standards of accountability; increases
performance and effectiveness; enhances consensus on core values; and, enables efficient use of
resources.
1.2 Forms/Types of NGO Codes of Conduct
NGO codes of conduct may be classified according to various characteristics. The most relevant
among these is their scope in terms of the number and profile of organizations intended to be
covered. A code of conduct may be applicable to a single organization or a group of organizations. In
the latter case, the profile of organizations may be defined in terms of a number of criteria including:
Level of operation, i.e., local, sub-national, national, regional, international
the sector in which they operate, e.g. health, education, food security,
thematic focus, e.g. gender, HIV/AIDS, capacity building
their organizational structure, e.g. membership, non-membership,
their role within the civil society sector, e.g. donors, implementers,
1
INGO Accountability Charter, User Guide
2
http://www.casin.ch/web/pdf/ngoaccountability.pdf

2. Often times, two or more of these criteria define the scope of NGO codes of conduct, the most
common types identified as: sector-specific codes with international application; national codes
applicable across sectors; and; individual NGO codes (drawn up by individual NGOs). For the purpose
of this document, the focus is on national codes applicable across sectors and profiles of
organizations.
2 Areas Covered by a Typical Code of Conduct for NGOs
There are a number of organizational and external factors that influence the approach adopted by an
organization in determining the contents of a code of conduct for an organization. In the context of
a coalition, the profile of members and their shared values are important internal considerations. The
operational environment for civil society in general is an important external factor that would inform
the overall approach to accountability and the specific contents of a code of conduct. The golden
rule in this respect is that codes of conduct should be organization specific as well as custom made
for the environment in which the organization operates. Within these limits, codes of conduct
generally cover three major areas:
a general section indicative of organizational aspirations;
a detailed section setting down specific principles, rules and policies which members of the
organization are expected to adhere to; and,
a third section dealing with the management of the code of conduct including structures,
procedures and standards for the implementation and enforcement of the substantive
provisions.
The level of detail under each of these major sections is determined by the nature and purpose of the
code. Generally, organizational codes are more detailed than coalition or sector level codes with the
most general ones expected in international initiatives covering NGOs operating across broad
sectors and levels of intervention. The rule is that the more common features shared among the
organizations, the more detailed the expected code of conduct.
2.1 General Provisions
The general provisions of the code outline the context and basis for the development and
implementation of the code of conduct including its rationale and objectives (why), scope of
application (who are the subjects), and the underlying value framework (mission, principles, values).
Oftentimes, this section also provides a list of definitions for important or repeatedly used terms as
well as other technical provisions as is common in legislative drafting. The rationale and objectives of
the code of conduct may be presented in the preamble or as separate paragraphs at the beginning
of the document.
2.1.1 Rationale and Objectives
The decision to develop or subscribe to a code of conduct may come from a variety of sources.
Internally, an NGO or coalition may decide to do so as part of a process in operationalizing its values
and principles, to strengthen internal governance structures, address internal accountability
concerns, or build up their reputation in order to increase acceptance of state and other key

3. stakeholders. It may also be the case that external influences arising within the civil society sector,
such as changing practice, may highlight the need for a code of conduct. In many cases, the reason
has to do with a response to accountability concerns raised by donors, governments and other
stakeholders.
The overall goal of developing a code of conduct is to provide an appropriate framework for
organizational accountability by setting standards of performance for effectiveness of NGOs in the
quantity, quality and responsiveness of their activities; independence, transparency and reliability of
their institutional structures; adherence to their mission as well as to a set of core values, guiding
principles, and policies.3 To this end, a generic list of specific objectives for an NGO code of conduct
includes: setting or restating an organization’s vision, values and guiding principles; establishing an
accountability framework that clarifies roles, responsibilities and decision making processes; defining
standards of acceptable professional behavior; and, providing benchmarks for evaluation and
reporting.
2.1.2 Scope
The scope of application is a provision clearly identifying who will be governed by the provisions of
the code of conduct. For organizational codes, this section should clearly state whether the code
applies at the level of governance (board), executive, staff, volunteers, affiliates, etc …4 In the case
of coalitions or groups of NGOs, the application of the code of conduct is normally subject to a
voluntary but formal procedure wherein an organization undertakes to be bound by the provisions
of the code. Thus, even if the code of conduct is intended to be applied to a known profile of
organizations, such as NGOs providing health services in a locality or partners of an organization, the
scope of application provision should indicate how organizations enter such formal commitment.
Another consideration in setting the scope of application for a code of conduct in the context of
coalitions or groups of NGOs is the level of diversity among intended subjects of the code. One
should specially make sure that the intended subjects are too diverse to permit anything but general
rules. As the concept of “civil society” refers to a wide range of different actors, with specific
interests, incentives and challenges, the value of developing a generic all encompassing code of
conduct for organisations as diverse as NGOs, trade unions, cooperatives, social movements, faith-
based organisations, etc… may be minimal.5 If such be unavoidable, as is the case for umbrella
organizations, one may consider separate provisions applicable to the different categories or the
development of subsequent codes. The development of organizational codes of conduct as a
stipulation in the coalition code may also be considered.
2.1.3 Vision, values and guiding principles
Accountability implies that organisations focus on fulfilling their mandate and serving the needs of
their beneficiaries. The code of conduct provides an opportunity to clarify the role of the CSOs/NGOs
3
Marie Chêne, Developing a code of conduct for NGOs, U4 Expert Answers, Transparency International,
27 April 2009
4
Transparency International for example has developed a specific Code of Conduct for both its Board
Members (http://www.transparency.org/about_us/organisation/board/conduct_board), and its
International Secretariat’s staff members
(http://www.transparency.org/content/download/21055/305503).
5
Marie Chêne, Developing a code of conduct for NGOs, U4 Expert Answers, Transparency International,
27 April 2009

4. in a concise manner. While this is more common among organizational codes of conduct, identifying
the vision, mission, and guiding principles of a coalition or group of organizations is also important in
terms of defining their shared profile. This will not only provide prospective members with a clear
idea of the identity of the coalition or group they are about to join but also enable consistency and
uniformity in the development and implementation of the code. This can be done by formulating
explicitly the vision of the coalition, developing the vision into a more detailed mission statement,
and describing its goals and purpose in a concise and accurate manner. Then, the core values are
listed in order of importance to the organization, starting by the most essential ones. The list of core
values should not be too long so that they can be easily remembered.
Codes of conduct should also capture the fundamental values of the organization or group of
organisations, identifying those that are the most essential to accomplish their goals and objectives.
Most codes of conduct commit to adhere to values linked to human and social rights, such as
democracy, nondiscrimination, justice, equity, and transparency. As opposed to detailed behavioral
rules, the guiding principles describe the general principles that the organization or group of
organisations are committed to respect and that inspire its/their daily operations. These guiding
principles provide the basis for detailed standards of conduct in the substantive section of the code.
They are also useful to help external stakeholders identify the general rules and principles that will
govern their interactions with the organisations governed by the code. These guiding principles
often include a commitment to principles of neutrality, objectivity, honesty, transparency, openness,
respect for fundamental rights and freedom, impartiality, participation, and professionalism.
2.2 Specific Rules and Policies
The nature, scope and level of details of the specific rules may greatly depend on whether the code is
meant to govern an individual organization, a group of sectoral organisations or a coalition of
national organisations working in different fields. In the latter cases, specific rules are likely to be
formulated in broader generic terms so that they fit the circumstances of the different member
NGOs.
Codes of conduct should generally establish the overall institutional conditions that are conducive to
ethical behaviours through a set of practical principles and policies as well as internal governance
rules. These policies seek to ensure that a strong oversight board independent from management is
established, that decision making processes are transparent and open to scrutiny, that remuneration
structures and employment conditions are fair and merit based, etc.
2.2.1 Internal governance rules
An accountable organization has a functioning system of internal governance. The English word
“governance” comes from the Latin word meaning “to steer, guide, or direct.” The term generally
refers to the way in which power is assumed, conveyed, and exercised within a society or an
organization. The Working Group on NGO Governance in Central and Eastern Europe defines good
governance as “a transparent decision-making process in which the leadership of a nonprofit
organization, in an effective and accountable way, directs resources and exercises power on the
basis of shared values.”An organization exercises good governance when it has an internal system
of checks and balances that ensures the public interest is served. Good NGO governance is based on
the distinction between organizational entities (management and the governing body) and the
distribution of decision-making power between them. This arrangement helps restrain and moderate

5. the control of any one person or group, ensure the organization’s resources are well managed, and
safeguard the NGO’s public-service orientation.
Internal governance rules may cover issues such as transparent and democratic rules and procedures
governing appointments and elections, terms of office, and balanced regional or gender
representation. At organization level, such rules may explicitly cover the role and composition of the
board, management structures, hiring and firing practices to promote both democratic
representation and accountable institutional structures. Usually, these issues are dealt with in the
basic document of the organization in accordance with legislative requirements.
In codes of conduct developed for a coalition or group of CSOs/NGOs internal governance rules have
dual meaning: rules governing the governance of member organizations, and rules for the
governance of the coalition/group. The concern here is the former with the latter to be dealt with in
the implementation and enforcement section of the code. The code of conduct should set down the
standards for good governance at the organizational level.
2.2.2 Accountability Rules
Accountability rules consist of provisions aimed at ensuring accountability to the organizations’
stakeholders. Codes of conduct stipulate standards for accountability such as regular reporting,
financial independence and transparency, sound financial management and accounting, annual
audited financial statements, and annual general meetings. The concern here is ensuring that all
stakeholders are identified, their respective stakes clarified and appropriate mechanisms put in
place. Ideally, this involves addressing the four key questions of accountability described earlier –
who, to whom, for what, and how, as well as a possible fifth – with what outcome? The following is
one example:
The Humanitarian Accountability Partnership International (HAP-I): organizations
providing emergency relief are accountable to the people affected by the crisis, for the
effectiveness of their relief in helping the people live a life with dignity, by creating a
variety of mechanisms including a self-regulatory watchdog, with the aim of
strengthening the humanitarian sector and thus bettering the lives of the affected
populations.
Since ‘upward accountability’ to donors and governments is governed through contractual and legal
stipulations, codes of conduct should emphasize ‘downward accountability’ to beneficiaries. One
approach in achieving this is “democratic accountability” or “stakeholder democracy” where all
stakeholders in an organization or activity have the same opportunity to govern that organization or
activity. The stakeholders with less power, i.e. beneficiaries, are identified as the primary
stakeholder.6 This is called “proportional accountability”7, meaning that the amount of
accountability should be determined by the amount of affectedness of the group demanding
accountability. The concept of dependent affectedness goes further in addressing the relative power
of different affected groups or persons, suggesting that their dependence on the outcome of an
6
Therefore democratic accountability can be defined as the quality of being accountable to those with
less power who are affected by one’s actions or decisions, when they in turn exhibit the same
accountability, where accountable means both justifying to and being regulated by those to whom
one is accountable.
7
Van Rooy (2004)

6. issue for the fulfillment of their basic rights should be a yardstick for determining the validity of their
opinion on that issue. To clarify, this “democratic accountability” can be described by answering the
four accountability questions as follows:
Who is accountable? The person or group that affects some relatively less powerful person or
group.
To who? To the person or group they are affecting.
For what? For the effect they have on them, particularly if negative.
And how? In a way where the person or group affected can change the behavior of the
person or group affecting them (with the affected also becoming accountable to any third
parties they affect when exerting this influence).
Another more widely applied mechanism effective in ensuring downward accountability to
beneficiaries is found in the promotion of participatory methods of assessing development project
plans and experience.
2.2.3 Rules of Professional Conduct
Rules of professional conduct set out clear standards governing the behavior of CSO/NGO personnel
including prohibited and expected behaviors in a range of situations. These rules typically constitute
guidelines with regard to situations wherein concerns may arise in professional relationships with
stakeholders. The most notable among these relate to the giving or receiving gifts, entertainment
and hospitality, travels, post employment, confidentiality, and non-preferential treatment of families
and friends. In this regard, it is particularly important that codes of conduct layout a framework for
removing or making transparent conflicts of interest and reducing opportunities for misconduct.
These provisions address situations where the private interest of a staff or a member of the
organization interfere with the interests of the organization and can affect the objectivity of
professional behaviors. At the organizational level, these issues are ideally addressed in a conflict-of-
interest policy. Codes of conduct developed within coalitions or groups of NGOs may stipulate brief
rules of professional conduct, stipulate that member organizations undertake to develop an
organizational code of conduct, and provide for the expected form and content.
NGO Governance Handbook: What is conflict of interest?
Conflict of interest is a situation in which outside interests affect or are perceived to affect the
ability of an individual to make fair and impartial decisions on behalf of the NGO. Conflict of
interest can exist when opportunities for direct material gain are involved (also known as
“self-dealing”); when close associates or family members stand to benefit; when personal,
professional, or other affiliations interfere with fair and impartial judgments; or when
personal interests or loyalties conflict and compete with those of the NGO. Conflict of interest
can be both real and perceived: it includes situations in which self-interest seems to play a role
even if no actual wrong-doing is involved.
Provisions on conflict of interest may, for instance, stipulate that conflict-of-interest policies should
be adopted addressing these elements:
Statement of purpose. The policy states what’s meant by conflict of interest and whom it
affects.

7. Guidance for conduct. Board and staff members are required to disclose any real, perceived,
or potential conflict right away. They should be banned from taking part in discussions and
decisions involving situations in which they or their family members and associates could
benefit in any direct or indirect way.
Annual disclosure. Board and staff members sign statements acknowledging their awareness
of the policy and identifying any real or potential conflicts they might be involved in.
2.2.4 Complaints procedures
The code of conduct should also provide for the establishment of complaints procedures towards
external and internal audiences to facilitate the reporting of wrongdoing or actions perceived to be
against the standards of the code. Where appropriate, this may be achieved by designating an
ombudsman mandated to respond to the stakeholders’ concerns and ensure that organizations stay
focused on their respective mandate, mission, values and principles. A critical issue in putting in place
a complaints procedure within a code of conduct is the protection of whistleblowers. There should
be credible and reliable mechanisms in place to protect the professional and personal interests of
whistle blowers.
2.3 Implementation and enforcement
Not all CSO/NGO codes of conduct have implementation and enforcement provisions. In fact, the
absence of these provisions is a key weakness cited in relation to self-regulation initiatives in general
and codes of conduct in particular. The Red Cross Code of Conduct, for instance, has no mechanisms
for verifying whether signatories comply with the code, and no means by which a breach of the code
can be reported.8 The South African NGO Coalition’s (SANGOCO) Code of Ethics, on the other hand,
gives no indication of what will happen if an NGO fails to comply, and that there is no evidence of any
organization being disciplined to date.9 While self-regulation inherently involves a voluntary aspect,
what organizations volunteer to do is undertake to be bound by the rules set forth in the code of
conduct. This commitment should give rise to a set of enforceable obligations once formally
committed. Otherwise, the code of conduct cannot achieve its core purpose, accountability. In the
absence of an enforcement mechanism, compliance may occur only among those most committed
to the code.
The implementation and enforcement section of a code of conduct contains provisions that explicitly
and specifically address implementation challenges and establishes adequate implementation
mechanisms. This starts with putting in place the necessary implementation structures and
procedures. Ideally, the code should make provisions for somebody to be in charge of the code's
implementation and reporting thereon in each participating organization, ideally a credible ethics
advisor that enjoys the trust of organization’s staff and members. There should also be provisions to
ensure for a second instance and/ or alternate channels in case the role of the ethics advisor be
8
International Federation of Red Cross and Red Crescent Societies (2004) ‘Code of good practice for
NGOs responding to HIV/AIDS: sign on implementation and accountability: options and
recommendations’, IFRC, Geneva (available at:
http://www.ifrc.org/what/health/hivaids/code/files/options_paper_sign_on_implementation.pdf)
9
E Hariss-Curtis (2002) ‘NGO codes of conduct: and exploration of the current debate’, in INTRAC
Informed, Bulletin 5, November, pp2-11. (available at:
(http://www.intrac.org/Intrac/docs/5Informed.pdf)

8. compromised (because her/himself in conflict of interest). There is also a need to develop an
implementation strategy that can be linked to other staff development initiatives such as training.
Successful implementation also requires a reporting mechanism, independent evaluation of the
success of implementation, independent compliance mechanisms and in some case the threat of
publicity if the code is broken. Effective implementation of the code in practice also greatly depends
on the nature of the oversight mechanisms in place to monitor compliance, detect and investigate
breaches of the code. The decision-making process for deciding whether an employee has breached
the code should be open, fair and transparent.
Good codes of conduct not only identify standards of behaviors but also spell out consequences to
apply in cases of breach, demonstrating willingness to take action in case of non-compliance with the
code’s provisions. In addition to sanctions, one could introduce a system of positive incentives to
reward staff and members that adhere to the code of conduct in an exemplary manner. Then, the
code should stipulate measures to enhance adherence to its provisions. The first prerequisite for
effective implementation is that the target audience needs to be aware of the existence of the code
and have sufficient knowledge of its provisions. The adoption of a code of conduct should also be
supported by awareness raising activities, such as the wide dissemination of the code to the target
audience and stakeholders, and training sessions. The regular assessment of the code’s impact is a
crucial element of the enforcement regime, with regular reporting mechanisms, analysis of
complaints made, and regular reviews.
3 Process of Developing a Code of Conduct for NGOs
The success of an initiative to develop a code of conduct for a coalition or group of CSOs/NGOs relies
to a large part on the target audience embracing the standards which the code of conduct promotes.
That is, a successful code of conduct is one that is grounded on a strong constituency with shared
values and objectives. That is, broad organizational representation and collective input are likely to
promote effective implementation. Moreover, the development process of the code provides a
unique opportunity for organisations to discuss common values, mission and obligations.
It is critical to engage the right people in the development process. Acceptance and understanding
of the code’s underlying values are likely to be higher if the code is not imposed on the people who
will be affected by it but developed through a participatory process with the active involvement of
the various stakeholders, either directly or through representatives. It is therefore advisable to
consult key stakeholders, particularly the organization’s beneficiaries, throughout the development
process. As NGOs are ultimately accountable to their beneficiaries, it is advisable to involve them in
the code’s development process and give them the power to hold the NGO accountable for its
actions.
For the organization, it’s a good and constructive way to get feedback from external constituencies
on what is seen as the mandate and obligations of the organization. It is also a way to communicate
the organization’s values and principles to the outside world. The document should ideally be
approved at the highest level of the organization to give it credibility. The managers should also be
seen as adhering to the highest rules of ethical conduct and behaviors.
The development does not stop with the production of the code and many codes continue to be
developed after they are adopted. Codes of conduct should be seen as living documents, which
evolve with the shape and challenges facing the organization.

9. 4 Conclusions: Assessment Standards
The following are the key assessment standards/issues emerging from discussion of the basis,
purpose and contents of CSO/NGO codes of conduct:
1. General
a. Is the code of conduct relevant to the CSO context in Ethiopia?
i. for the legislative /mandatory regulation framework for CSOs in Ethiopia?
ii. for the profile and membership of CCRDA?
iii. the number and profile of organizations intended to be covered?
b. Does the code of conduct have all the relevant sections?
i. general section indicative of organizational aspirations;
ii. a detailed section setting down specific principles, rules and policies which
members of the organization are expected to adhere to; and,
iii. a third section dealing with the management of the code of conduct
including structures, procedures and standards for the implementation and
enforcement of the substantive provisions.
c. Is the level of detail under each of these major sections appropriate for the nature
and purpose of the code?
2. General provisions
a. Does this section of the code of conduct cover the relevant issues?
i. its rationale and objectives (why)
ii. scope of application (who are the subjects)
iii. the underlying value framework (mission, principles, values)
iv. definitions for important or repeatedly used terms
b. Are the general and specific objectives properly designed and presented?
i. clearly stated
ii. relevant
c. Is the scope of application properly designed and presented?
i. clearly stated

10. ii. relevant in the context of the regulatory framework
iii. appropriate to CCRDA (criteria and profile of membership)
d. Are the shared visions, missions, principles and values properly designed and
presented?
i. stated clearly and in sufficient detail (additional principles and values that
should have been included)
ii. relevant in the context of the regulatory framework
iii. appropriate to CCRDA (criteria and profile of membership, vision, mission,
principles, values)
3. Specific rules and policies
a. Does this section of the code of conduct cover the relevant issues?
i. Internal governance rules
ii. Accountability rules
iii. Rules for professional conduct
iv. Complaint procedures
b. Are the rules on internal governance properly designed and presented?
i. stated clearly and in sufficient detail (separation of management and
governance, transparent and democratic rules and procedures governing
appointments and elections, terms of office, and balanced regional or gender
representation)
ii. consistent with the general provisions of the code
iii. relevant in the context of the regulatory framework (CSP stipulations on
internal governance structures, mandates, processes and standards)
iv. appropriate to CCRDA (constituting documents of CCRDA and potential
members)
c. Are the rules on accountability properly designed and presented?
i. stated clearly and in sufficient detail addressing the key elements of
accountability (downward and upward accountability; mechanisms such as
regular reporting, financial independence and transparency, sound financial
management and accounting, annual audited financial statements, and
annual general meetings; participatory measures)

11. ii. consistent with the general provisions of the code
iii. relevant in the context of the regulatory framework (CSP stipulations on
upward and downward accountability)
iv. appropriate to CCRDA (profile of CCRDA and potential members, i.e. charities
and societies)
d. Are the rules on professional conduct properly designed and presented?
i. stated clearly and in sufficient detail (clear standards of behavior-permitted
and prohibited - in a range of situations; conflict of interest; organizational
code of conduct)
ii. consistent with the general provisions of the code
iii. relevant in the context of the regulatory framework (CSP stipulations on
officers; conflict of interest in the regulation)
iv. appropriate to CCRDA
e. Are the rules on compliant procedures properly designed and presented?
i. stated clearly and in sufficient detail (for external and internal stakeholders;
designated ombudsman; protection of whistleblowers)
ii. relevant in the context of the regulatory framework (CSP stipulations on
mandatory disclosure of misconduct?)
iii. appropriate to CCRDA
4. Implementation and enforcement
a. Does this section of the code of conduct cover the relevant issues?
i. Implementation challenges
ii. Mechanisms for implementation
iii. Enforcement provisions
b. Are implementation challenges clearly identified and addressed?
c. Are the mechanisms for implementation properly designed and presented?
i. stated clearly and in sufficient detail (structures and procedures; responsible
persons; alternate channels; implementation strategy; reporting
mechanisms)
ii. consistent with the general provisions and specific rules of the code

12. iii. relevant in the context of the regulatory framework
iv. appropriate to CCRDA (profile of CCRDA and potential members)
d. Are the enforcement provisions properly designed and presented?
i. stated clearly and in sufficient detail (non-compliance reporting mechanisms;
consequences to apply in cases of breach; a system of positive incentives;
awareness and dissemination; assessment and review of the code)
ii. relevant in the context of the regulatory framework
iii. appropriate to CCRDA (profile of CCRDA and potential members)
5. Process of development
a. Evidence of a process involving analysis aimed at addressing the four key questions
of accountability described earlier – who, to whom, for what, and how, as well as a
possible fifth – with what outcome?
b. Establishing shared values among intended subjects of the code
c. Engagement of all stakeholders, especially beneficiaries
d. Approval at the highest levels