Code of Conduct for Vendors and Contractors of Ocean Reef Club, Inc.

This Code of Conduct has been prepared to describe the Club’s expectations regarding the conduct of all individuals who perform work for the Club.  This Code of Conduct applies to all vendors and contractors (and their employees, subcontractors and agents) who provide services or goods to Ocean Reef Club.
This Code of Conduct provides you with an easy-to-follow guide to the Club’s expectations.  Each of you is responsible for your actions, as well as ensuring to the best of your ability that those with whom you work or subcontract abide by this Code of Conduct. It describes your responsibilities to the Club’s members and employees and other members of Ocean Reef community. The pages that follow are not intended to answer every question or address every situation that may arise, but they do offer important guidance for the work we do and information on where to go when you have questions or wish to report a concern.
The Club encourages you to read this Code of Conduct carefully and ask questions, share ideas and provide feedback. At Ocean Reef Club, trust, transparency and confidentiality are essential to our work and our relationships with the individuals we serve, their families, our partners, our employees, and each other.

Ocean Reef Club will not tolerate any retaliation against anyone who makes a good faith report of a suspected violation of a law, regulation, policy or this Code of Conduct, or who cooperates in the investigation of such a report.  Suspected or alleged retaliation must be reported so that the Club has an opportunity to look into it and address it as appropriate. As with any concerns under this Code of Conduct, you can report suspected retaliation to your Ocean Reef Club contact, or to any director or manager of Ocean Reef Club.

Ocean Reef Club has chosen to contract with you or your company to provide products or services, either directly to Ocean Reef Club or to the individuals we serve and their families. As part of your contract, Ocean Reef Club expects you to follow applicable laws, rules and regulations and this Code of Conduct in performing your responsibilities.

It is essential that you take time to read and understand this Code of Conduct so you can:

In addition to this Code of Conduct, there may also be other documents you need to refer to and rely on when providing services under your agreement with Ocean Reef Club. For example, there may be a written agreement with Ocean Reef Club, regulations or standards related to the work that you do, and expectations that Ocean Reef Club has based on its contractual agreement with you. It is your responsibility to be familiar with all of the standards that govern the services you provide to or under agreement with Ocean Reef Club.

Suspected violations of this Code of Conduct or any provisions of your agreement with Ocean Reef Club will be reviewed and addressed as appropriate. When a violation of the Code of Conduct or your agreement has been identified, it may constitute a material breach of your agreement with Ocean Reef Club. This may lead to termination of your contract, recoupment of payments made to you, and/or referral for criminal prosecution or civil action if appropriate.

If you have any questions about this Code of Conduct, or wish to report a possible violation of the Code of Conduct, the best place to start is your Ocean Reef Club contact. If for any reason that is not practical or comfortable, please speak with any Ocean Reef Club director or manager.

Ocean Reef Club expects that you will not accept, offer or participate in any fraud, kickbacks, bribes or other arrangements designed to induce referrals or business.

If you receive an inquiry, subpoena or other legal document regarding services you provide to Ocean Reef Club or the individuals it serves, please immediately notify your Ocean Reef Club contact, so that we can ensure that appropriate confidentiality and other considerations are met.

If your agreement with Ocean Reef Club requires that you have a particular credential or license, it is up to you to maintain that credential and/or license, and you must inform your Ocean Reef Club contact immediately if your credential or license becomes encumbered or restricted or is not renewed or maintained.  When a required credential or license is renewed, you should provide a copy to your Ocean Reef Club or program contact.
Contractors are responsible for ensuring that any employees, agents, or subcontractors assigned to perform services under the contract with Ocean Reef Club are in compliance with applicable federal and state employment and immigration laws and licensing requirements, and obtain and maintain all appropriate insurances (e.g., liability, workers’ compensation) for their workforces.

Prior to delegating your work to an affiliate or entering into an agreement with any subcontractor, Ocean Reef Club reserves the right to conduct a background check to ensure that the individual performing the contracted-for services has the appropriate credentials.  We also confirm that the individual is not precluded from providing services to Ocean Reef Club as a result of, for example, a disqualifying criminal record.

Every vendor or contractor is expected to conduct business on behalf of Ocean Reef Club with integrity, honesty and high moral standards. This includes truthfulness in billing, accounting, and financial reporting practices.  Ocean Reef Club expects that you will document and bill accurately for services that are actually provided, and to comply with all laws and regulations related to documentation and billing practices.

You are likely to be provided with or obtain confidential and/or private information about the Club and/or the individuals served by Ocean Reef Club. (In this Code of Conduct we are collectively referring to all of this as “Confidential Information.”)  Confidential Information means any information, knowledge, or data of any nature and in any form (including information that is electronically transmitted or stored on any form of magnetic or electronic storage media) relating to the past, current, or prospective business or operations of Ocean Reef Club, that at the time or times concerned is not generally known to persons engaged in businesses similar to those conducted or contemplated by the Club, whether produced by the Club or any of its consultants, agents, or independent contractors, whether or not marked confidential, including without limitation information relating to the Club’s members, products and services, business plans, business acquisitions, processes, product or service research and development ideas, methods or techniques, training methods and materials, and other operational methods or techniques, quality assurance procedures or standards, operating procedures, files, plans, specifications, proposals, drawings, charts, graphs, support data, trade secrets, supplier lists, supplier information, purchasing methods or practices, distribution and selling activities, consultants’ reports, marketing and engineering or other technical studies, maintenance records, employment or personnel data, marketing data, strategies or techniques, financial reports, budgets, projections, cost analyses, price lists, formulae and analyses, employee lists, customer records, customer lists, customer source lists, proprietary computer software, and internal notes and memoranda relating to any of the foregoing.  The following are some of the requirements you must follow regarding confidentiality in your relationship with Ocean Reef Club:

Inappropriate disclosure of Confidential Information could lead to termination of your contract with Ocean Reef Club, as well as possible legal action. If there is an unauthorized disclosure of Confidential Information, you should immediately inform your Ocean Reef Club contact.

It is expected that there will be no unlawful use of drugs or alcohol in any location where services are provided to Ocean Reef Club or the individuals we serve. While the presence of alcohol, prescription drugs and over-the-counter medications may be permissible in a service setting, all alcohol/drug storage and use must be lawful, and must comply with applicable laws and licensing requirements.

The Club provides services that are non-discriminatory to individuals regardless of race, ethnicity, national origin, age, gender, sexual orientation, religion, disability, or any other status that may be protected under applicable law. Any incident or situation that you believe involves possible discrimination should be brought to the immediate attention of your company and Ocean Reef Club contact.

When you are working under agreement with Ocean Reef Club, you are expected to be sensitive to the concerns, values and preferences of others, and behave in a manner that supports and promotes a diverse and respectful environment.

We strive to have open communication and address problems in a mutually respectful way, taking into account individual situations.

You should avoid any actions that may involve, or may appear to involve, a conflict of interest with the products or services you provide to or under agreement with Ocean Reef Club. You should disclose to your Ocean Reef Club contact any situation where a conflict of interest may arise involving you or your immediate family.  A conflict of interest may arise when you or someone you associate with in your independent business:


The following questions provide a good guideline for those in doubt about a specific course of conduct:

  1. Will my actions be ethical in every respect?
  2. Will my actions fully comply with the law and my agreement with Ocean Reef Club?
  3. Will my actions be questioned by my peers, family or the general public?
  4. How would I feel if my actions were reported in the newspaper?
  5. How would I feel if someone else acted in the same way?
  6. Will my actions appear to be proper?
  7. Will my actions be seen as fair?

Potential conflicts can usually be resolved by using good judgment. You are encouraged to seek clarification of, and discuss questions about, potential conflicts by talking to your Ocean Reef Club contact.

Ocean Reef Club expects that you will not provide gifts or payments of any kind to any government representative or government employee while in the course of providing products or services under agreement with Ocean Reef Club.

It is Ocean Reef Club’s position that neither we nor anyone with whom we do business gives, solicits or receives gifts or gratuities which are or appear to be in exchange for personal or professional advantage or gain. Reasonable small tokens from or to a third party may be acceptable, provided that they do not place you or the other party under any obligation, are not frequent, and would not be misconstrued by a reasonable person as a bribe.  As a contractor or vendor, you should know that employees of Ocean Reef Club are only allowed to accept gifts of less than $100 in value from you before obtaining permission from a senior level leader in the organization. Moreover, during a time when you or your company is being considered for renewal or change to your agreement to provide services to Ocean Reef Club, any gift to an employee of Ocean Reef Club would be considered inappropriate.  Business gratuities, where you invite an employee of Ocean Reef Club to join you at a non-work-related event, are acceptable so long as they are infrequent and otherwise don’t place our employee under any obligation to you or your company.


Our third party harassment policy aims to address harassment of Club employees. Ocean Reef Club will not tolerate harassment of Club employees, even if it means having awkward conversations with vendors or contractors or losing business.  Ensuring our employees are safe in our workplace is a first priority for the Club.

This policy applies to all vendors and contractors of Ocean Reef Club, and their employees, subcontractors and agents.  We aim to protect every employee, intern or volunteer regardless of level, function, seniority, status or protected characteristics like race, gender and sexual orientation.

Harassment is any kind of behavior that humiliates, victimizes or threatens a person, like directing racial slurs and making sexual advances. Even seemingly harmless actions, like calling an employee constantly outside work for non-emergencies and without prior agreement, can constitute harassment. Innuendos, veiled threats and inappropriate or offensive jokes are all included in our definition.

The Club prohibits harassment of its employees.  Suspected violations of this no harassment policy will be reviewed and addressed as appropriate. When a violation of the no harassment policy has been identified, it may constitute a material breach of your agreement with Ocean Reef Club.