In this section of our website, you will find some important internal documents that guide our work: our standards of conduct, code of ethics, executive compensation process outline, equal employment opportunity guidelines and non-retaliation policies. These policies guide the work of every employee, officer and director at the Conrad N. Hilton Foundation. We are currently updating our policies and board committee charters, which will be reflected here later this year.

As an integral part of our work, we encourage grant recipients and other partners of the Conrad N. Hilton Foundation to share knowledge and best practices, in an effort to continually improve our operations, and we hold ourselves to the same standard. We actively promote greater transparency in our work by explaining our funding and sharing information online in an open and user-friendly way.

In 2010, Candid (formerly the Foundation Center) launched Glasspockets, an initiative designed to promote greater transparency in philanthropy. We have been a proud member since 2012 and continue to improve access to our data on an ongoing basis. The criteria outlined on Glasspockets do not represent a mere checklist of options to attain full transparency but rather a path to continually question and improve our practices.

You can find information about our grantmaking on our website, which is updated on a monthly basis. Please send us your feedback and let us know if you have any questions.


All employees are expected to be polite, courteous, attentive, and to respond promptly to every grantee, visitor, colleague, business associate, caller and each other. In addition, it is important that staff adopt standards of conduct and behavior designed to:

  • preserve the quality, fairness and openness of Foundation program development, review, funding and oversight processes;
  • protect the integrity of Foundation decision-making and governance processes; and
  • help avoid situations that represent inappropriate intrusions on their time, privacy, or other personal or professional interests and responsibilities.

It is impossible to conceive all of the possible situations that could result in unethical conduct by an employee. It is the employee’s duty to question any course of action that could be construed as illegal, unethical, a conflict of interest, or any appearance thereof. If such a situation arises, the employee has the obligation to report the problem to the Vice President for Operations who, if necessary, will report it to the President for further action, if warranted.

Political Activities

The Foundation encourages employees to be active in civic matters. However, before becoming involved in any political activity that has the potential to cause a conflict with employees’ work for the Foundation, employees should report such prospective activity to the Vice President for Operations for the purpose of ascertaining:

  • all political activity must be confined to other than normal work hours;
  • no Foundation equipment or facilities can be used;
  • there will be no other evidence of Foundation involvement.

Off-Duty Conduct

Employees should consider themselves representatives of the Foundation at all times. Therefore, they are expected to conduct their affairs in a manner that does not adversely affect the Foundation’s integrity, reputation or credibility. Illegal off-duty conduct that adversely affects the Foundation or ability to perform their job will not be tolerated.


Being an employee of a grantmaking foundation entails certain responsibilities beyond that of legal business practices including a course of personal ethics that must be above reproach. It is our employees’ duty to see that grant requests presented to the Board of Directors are the result of independent and impartial investigation and recommendation. In addition to avoiding any conflict of interest problems or other ethical problems, it is important that employees avoid any appearance of unethical practices even though there may be no moral or ethical wrongdoing. Even though a private foundation does not normally sign as many contracts or purchase as many materials and supplies as does a conventional profit-making business, the legal requirements in doing so are much stricter for foundations.

As a general rule, all actions of an employee affecting the Foundation shall be in the Foundation’s best interests and not for the employee’s personal advantage. In considering any decision regarding an organization or person with which an employee is affiliated, the Foundation shall avoid any transaction that results in any direct or indirect benefit to the affiliated employee or which would constitute self-dealing under Internal Revenue Code Section 4941.

Legal Practices

It is the duty of every officer and employee of the Foundation acting in their assigned capacity, to be familiar with all laws, rules and regulations pertaining to that person’s position and each person is responsible for carrying out their assigned duties in accordance with such laws, rules and regulations.

In addition, the Tax Reform Act of 1969 has imposed additional legal requirements upon private foundations and because of this, it is important that officers and employees adhere to strict operational procedures to prevent any violation. For example, the Act prohibits any dealings with “disqualified persons.” Disqualified persons include directors, officers, substantial contributors and members of their families, and controlling and controlled entities. For this reason, any contractual arrangements entered into by the Foundation should be done so only through the Vice President for Operations or President.

Foundations are specifically and particularly precluded from entering into political activity and no employee is permitted to enter into any political activity that may be construed as being attributed to the Foundation. By way of example and not limitation, political activity cannot be carried on during work time, nor can Foundation equipment, supplies or facilities be used in any political effort. Foundations may not engage in any activity that supports or opposes either candidates for public office or political parties. Such support or opposition is partisan political activity. In contrast, encouraging the public to vote, educating voters about the candidates and educating candidates can all be nonpartisan activities, if they are carried out in a way that does not suggest bias for a political candidate or party.

Funding public policy advocacy is legal. Private foundations can support public charities that employ lobbying strategies, without making a taxable expenditure. General support grants can be used for all activities—including advocacy—permitted by a nonprofit’s 501(c)(3) status. As long as a general support grant is not earmarked for lobbying, there is no risk to the Foundation, even if the grant is subsequently used for lobbying. Private foundations can even support specific projects that include a lobbying component, as long as the grant does not exceed the non-lobbying portion of the grantee’s budget.

Ethical Practices

A definition of ethical practices for employees of a private foundation is difficult to formulate. Not only must an employee avoid situations in which a clearly unethical situation may arise, the employee must also avoid situations that may raise the appearance of impropriety. In all of their professional relations, the employee should keep one rule uppermost: “to avoid any situation that creates a conflict of interest in which the employee’s independence can be questioned, even though the employee is not involved in the decision-making process, and in all situations whether independence can be questioned or not, to make a full disclosure.” The key words employees must keep in mind are “conflict of interest” and “full disclosure.”

The Foundation does not discourage activities in which a conflict of interest or loyalties may arise, such as serving on a board of directors or as a trustee or advisor of grantee organizations. In such instances, the employee should disclose the relationship to the Vice President for Operations of the Foundation. For some instances in which an ethical problem may arise, the Foundation’s policy is as follows:

Gifts. Officers and employees cannot solicit, accept or agree to accept, at any time of the year, for themselves or on behalf of the Foundation, any gift, which directly or indirectly benefits them, from any person or firm having or seeking a business relationship with, or to be the recipient of a grant from the Foundation, or from an employee or agent of such person or organization. However, this prohibition does not apply to the acceptance over a twelve month period (from each person or organization) of gifts totaling not more than $100, except that in no event shall gifts of cash ever be accepted. This prohibition does not apply to acceptance of gifts from relatives, provided the occasion is one in which a gift from the particular donor would normally be expected, and the gift is not excessive.

A gift is defined as any item of tangible value, any service of value, any purchase price lower than that which is normally charged, any favor that enhances the employee materially, and any benefit or other thing of value (including cash or certificates), any of which are given without adequate consideration.

Charity Events. The Foundation has a policy against purchasing tickets to charitable functions for employee’s use. Employees, on occasion, may be invited to charitable events, to meals, and/or to other entertainment functions. In most instances, the employee may accept, providing the function gives the employee a better understanding of the affairs of the proposed grantee. The employee should always pay whenever practical and make an effort to reciprocate whenever possible. Allowances will be made to the employees by the Foundation for this purpose.

Honorarium, Expenses and Outside Work. Employees are encouraged to write articles and to speak or lecture before various groups as a representative of the Foundation. If such a person is authorized to represent the Foundation, the Foundation will pay all travel and related expenses. Should the recipient organization wish to reimburse the Foundation, the Vice President for Operations will decide if reimbursement is appropriate. Honorariums, or other forms of payment other than small gifts of appreciation, are not allowed. It is the policy of the Foundation to pay salaries that are adequate, reasonable, and competitive within the field of philanthropy, and the Foundation expects employees to devote their full energies to the Foundation. Outside employment that interferes with an employee’s ability to perform their job duties to the Foundation’s expectations is not allowed. Full-time employees may not accept outside employment without first discussing the matter with their manager and obtaining the approval of the Vice President for Operations.

Required Conduct

It is obvious that it is impossible to conceive all of the possible situations which may arise that will result in unethical conduct by an employee. It shall be the duty of each employee to question any course of action that could be construed as illegal, unethical, a conflict of interest, or any appearance thereof. When such a situation arises, the employee has the obligation of reporting the problem to the Vice President for Operations who, if they cannot resolve the problem, reports it to the President, who may request a ruling from either the legal counsel for the Foundation, or the Compensation and Personnel Committee, or both.

Whenever an employee receives a gift, the acceptance of which is questionable, they should immediately notify the Vice President for Operations who will take the following action:

  1. Permit the employee to accept the gift because it is of nominal value.
  2. Require the employee to return the gift to the donor explaining the Foundation’s gift policy.
  3. Donate the gift to the Foundation or another charity, with or without a letter explaining the Foundation’s gift policy.

Each employee shall keep a record of all gifts received and shall file a report annually of such record with the Vice President for Operations. Each employee shall notify the Vice President for Operations of any position they are holding, or is contemplating holding, such as a directorship or other position with a grantee organization, in which a conflict of interest may arise. Such information shall be filed in the employee’s personnel file.

Confidentiality of Information

The Foundation’s private information and information collected about others which is deemed private shall not be divulged except in strict accordance with established policies and practices.

Non-Discriminatory Employment Practices

It shall be the Foundation’s practice in both the hiring, retention and promotion of its employees, to afford equal opportunity to all, including encouraging the disadvantaged to seek employment; however, selection will be on the basis of merit and ability without discrimination. All employees are responsible for supporting this policy.


Any employee violating this Code of Ethics shall be subject to disciplinary action, up to and including dismissal.


The Conrad N. Hilton Foundation fully subscribes to and utilizes best practices and compliance with IRS codes and regulations in determining compensation at all levels within the Foundation, with particular attention to Board and executive compensation, including incentive compensation for our investment staff.


The Conrad N. Hilton Foundation is an equal opportunity employer and makes employment decisions on the basis of merit. Foundation policy prohibits unlawful discrimination based on race, color, creed, religion, gender (including gender identity and gender expression), sexual orientation, national origin, ancestry, age, physical or mental disability, medical condition, sex (including breastfeeding and conditions related to breastfeeding), genetic characteristics and information, marital status, registered domestic partner status, military and veteran status or any other consideration made unlawful by federal, state, or local laws.

The Foundation is committed to compliance with all applicable laws providing equal employment opportunities. This commitment applies to all persons involved in Foundation operations and applies to all terms and conditions of employment, including recruitment, hiring, placement, assignments, promotion, transfer, discipline, termination, layoff, recall, leaves of absence, compensation, employee benefits, training and all other terms and conditions of employment.

The Foundation offers reasonable accommodations to qualified individuals with physical or mental disabilities to the extent the accommodation will enable them to perform the essential functions of the job and will not create an undue hardship.

In addition, in accordance with California law, the Foundation does not discriminate against employees on the basis of a lawful change of name, Social Security Number or federal employment authorization document; receipt of Medi-Cal coverage; or having a California driver’s license with a “federal limits apply” notation.

Complaint Process

If an employee of the Foundation believes they have been the subject of harassment or other conduct prohibited by this policy or believes they have witnessed such conduct, the employee is encouraged to bring their complaint or concern to the Vice President of Talent and Culture, Vice President for Operations, or the President as soon as possible after the incident. However, if the employee is not comfortable with discussing the issue with any of these persons, they can bring the complaint to a manager or senior management who will refer their complaint to one of these persons. The employee will be asked to provide details of the incident or incidents, names of individuals involved and names of any witnesses. Employees are encouraged to communicate complaints in writing, but this is not mandatory. We also encourage individuals who believe they are being harassed to firmly and promptly notify the offender that their behavior is unwelcome. Because this may be difficult, such direct communication is not a requirement of filing a complaint. The Foundation will immediately undertake an effective, thorough and objective investigation of the allegations. Confidentiality will be maintained throughout the investigatory process to the extent consistent with adequate investigation and appropriate corrective action.

Any manager who sees or hears about conduct that may constitute harassment under this policy must immediately contact Talent and Culture. All workers, including managers and supervisors, have a duty to cooperate in the Foundation’s investigation of alleged harassment.

If the Foundation determines that harassment or other prohibited conduct has occurred, effective remedial action will be taken in accordance with the circumstances involved. Any employee determined by the Foundation to be responsible for harassment or other prohibited conduct will be subject to appropriate disciplinary action, up to and including termination. A Foundation representative will advise all parties concerned of the results of the investigation. The Foundation will not retaliate against the employee for filing a complaint and will not tolerate or permit retaliation by management, employees or co-workers.

If a party to a complaint does not agree with its resolution, that party may appeal to the Board of Directors.

False and malicious complaints of harassment, discrimination or retaliation may be the subject of appropriate disciplinary action.

The Foundation encourages all individuals to report any incidents of harassment or other prohibited conduct forbidden by this policy immediately so that complaints can be quickly and fairly resolved.

The Foundation will provide education and training on diversity and harassment to increase knowledge and awareness of conduct that may be perceived by others in the workplace as harassment. The appropriate training will be provided to all managers and employees of the Foundation.

Although the Foundation has limited authority to discipline a non-employee harasser (such as a client, customer, contractor, vendor or supplier), it will take remedial action aimed at ensuring that the conduct stops.


The Conrad N. Hilton Foundation is committed to operating with integrity through business practices that are in compliance with applicable laws, regulations and policies, which include complete financial reporting and sound financial stewardship of its assets. Employees have the responsibility to report any circumstance of which they have actual knowledge, or a reasonable good faith belief, that the Foundation’s internal controls, auditing functions, accounting systems or governance policies are compromised or threatened.

Therefore, employees will not be subject to disciplinary or retaliatory action by the Foundation or any of its employees or agents as a result of:

  • disclosing information internally or to a government or law enforcement agency where they have reasonable cause to believe that the information discloses a violation or possible violation of federal or state law or regulations;
  • reporting suspected conflicts of interest, self-dealing, unethical behavior or concerns about the Foundation’s internal controls, auditing function, accounting systems, or governance in good faith; or
  • reporting harassment in good faith.

Procedure for Reporting Suspected Improprieties

Employees are encouraged to discuss issues and concerns with their managers, the Vice President of Talent and Culture or senior management. Reports may be submitted verbally or in writing, but the reports should contain enough information to substantiate the concern and allow appropriate investigation to begin. Reports may be submitted anonymously. All reports will be received and acted upon in confidence to the maximum extent possible.

Individuals who report apparent unlawful or unethical behavior will suffer no retaliation of any kind for reports made in good faith and/or honest belief that the behavior reported was unlawful or unethical. Such retaliation would include firing, demotion, suspension, harassment, failure to be considered for promotion or any other type of discrimination. Failure to cooperate with or impeding an investigation, or knowingly providing false information, will result in disciplinary action. Reports of potentially improper activity and related investigations will be kept confidential to the extent possible, consistent with the need to conduct an appropriate investigation.

The Foundation will take action, up to and including termination, against a person who has committed an offense even though they cooperate with the investigation.