Code of Ethics

I. Preamble

The Food and Drug Administration Alumni Association, Inc. (FDAAA) is a non-stock, non-profit and non-lobbying organization incorporated in the State of Maryland. Member- ship in the FDAAA is open to both alumni and current employees of the U.S. Food and Drug Administration (FDA).* As such, opportunities will arise for fraternization between government regulators and persons who are professionally active in job areas that are or may be affected by FDA policies and regulations.

To protect the integrity of the Association and its relationship with FDA, and to guard against individuals becoming members of the FDAAA for the purpose of advancing their private economic interests, this Code of Ethics (also hereinafter referred to as “the Code”) sets forth the ethical standards to which members of the FDAAA are expected to adhere and by which their actions as Association members will be judged.

The standards of conduct prescribed in the Code are not intended to confer responsibilities to FDA employees beyond what they are required to adhere to by virtue of their employment or to absolve them from their ethical responsibilities as defined by federal law and regulation.

II. Ethical Standards

In the interest of ensuring that the Food and Drug Administration Alumni Association is an organization of uncompromising integrity and high moral purpose, all members (including members of chapters affiliated with FDAAA), regardless of membership category, are expected to abide by the following:

(a) A Member shall not knowingly take any action or make any statement intended to influence the conduct of the FDAAA in such a way as to confer financial benefit on any person, corporation, or entity in which the individual has a personal or business interest.

* The FDAAA does not discriminate on the basis of race, color, creed, sex, national origin, marital status, political or religious beliefs, family, social or cultural background, or sexual orientation.

This means, for example, that a member shall not endeavor to obtain from another Association member who is also an FDA employee information to which the individual is not otherwise entitled (this includes trade secret, commercial confidential and other information related to internal FDA policy and regulatory action), nor attempt to influence FDA policy or action in a manner other than that which any member of the general public is legally entitled.

(b) A Member shall not disclose any confidential or sensitive information obtained from the Food and Drug Administration in the course of providing expert services on behalf of the FDAAA as part of a volunteer, contractual or other temporary employment arrangement.

(c) A Member shall not utilize membership in the FDAAA to engage in any lobbying activity intended to influence legislation pending before any legislative body or specific action by any agency of government that may impact the authorities, policies, or financial standing of the Food and Drug Administration. Public testimony or other presentations made by FDAAA members for the purpose of providing general and unbiased information to broaden understanding of FDA’s mission may be allowed. Witnesses/presenters are encouraged to give prior notice to and obtain approval from the Association.

(d) A Member shall not utilize membership in the FDAAA to promote partisan politics, engage in electoral politics, or advance specific religious beliefs.

(e) A Member shall not use or authorize the use of the name, logo, motto or property belonging to the FDAAA for personal gain or commercial advantage.

In instances when an FDAAA Member is believed or alleged to have acted contrary to the ethical standards described in the Code, members are encouraged to bring such matter(s) to the immediate attention of the Association’s Board of Directors for review and appropriate action. Persons against whom complaints or allegations are made shall be accorded full opportunity to respond in writing and/or in person. If a complaint or allegation is corroborated by clear and convincing evidence, the FDAAA Executive Committee may exercise its authority to apply one or more sanctions commensurate with the severity of the ethical violation (i.e., warning, suspension and expulsion). Persons being sanctioned shall have the right to appeal to the Association’s Board of Directors.

Adopted on this date by the FDAAA Board of Directors: March 3, 2003

III. Disciplinary Action

In instances when an FDAAA Member is believed or alleged to have acted contrary to the ethical standards described in the Code, members are encouraged to bring such matter(s) to the immediate attention of the Association’s Board of Directors for review and appropriate action. Persons against whom complaints or allegations are made shall be accorded full opportunity to respond in writing and/or in person. If a complaint or allegation is corroborated by clear and convincing evidence, the FDAAA Executive Committee may exercise its authority to apply one or more sanctions commensurate with the severity of the ethical violation (i.e., warning, suspension and expulsion). Persons being sanctioned shall have the right to appeal to the Association’s Board of Directors.

Adopted on this date by the FDAAA Board of Directors: March 3, 2003