Code of Business Conduct & Ethics

Updated June 2023

Vitamin Angels expects all members of its community, including employees, contractors and consultants, vendors, partnering organizations, and members of its Boards of Directors and Advisors (“VA Community”) to conform to the highest ethical standards and to meet or exceed ethical and legal obligations in the performance of their efforts on behalf of Vitamin Angels (“VA”). Vitamin Angels prides itself on its reputation of integrity and excellence in its programs and services. This reputation is one of VA’s strongest assets. It is expected that all members of the VA Community acting with, for or on behalf of Vitamin Angels uphold the highest standards of ethical behavior and practices. Vitamin Angels’ Code of Business Conduct and Ethics provides standards and guidance for all activities relating to the support of its mission.

Vitamin Angels is committed to ethical business dealings. All members of our VA Community are expected to exercise ethical and other professional standards at all times. Additionally, the VA Community always abides by international, federal, state and local laws and regulations, as well as follows policies set by the leadership team and Board of Directors of Vitamin Angels.

Governance and Accountability

Vitamin Angels has a Board of Directors engaged to ensure that the organization has sufficient resources and adheres to the best governance practices, in each case, to ensure that the organization is able to carry out and advance its mission. The Board of Directors is responsible for various activities including, but not limited to:

  • Ensuring the sustainability of Vitamin Angels, including that the organization has sufficient and appropriate financial, human, and other resources to fulfill and advance its mission;
  • Reviewing and approving the Strategic Plan and Annual Operating Plan and monitoring VA’s performance against those plans;
  • Selecting, appointing, supporting, and evaluating the Chief Executive Officer and President, including establishing their respective primary responsibilities;
  • Supporting the Chief Executive Officer and President and staff of Vitamin Angels; review the performance and objectives and set the compensation for the President;
  • Reviewing and approving major policies, procedures, and objectives;
  • Building competent Board of Directors and Board of Advisors – setting criteria for new members of each board, ensuring proper orientation and evaluation processes are in place for each board, and ensuring a strong and functionally effective Board of Directors and Board of Advisors;
  • Personally understanding and abiding by the highest standards of legal and ethical integrity of Vitamin Angels and at all times acting in a manner that is in the best interest of Vitamin Angels’ mission and brand.

Legal Compliance

Vitamin Angels is committed to conducting its programs and services in a lawful and ethical manner, in full compliance with all federal, state and local laws and regulations.

Vitamin Angels will only employ, contract, or partner with individuals or entities with proper credentials, experience, and expertise. All business communications on behalf of Vitamin Angels will be truthful and, where appropriate, supported by accurate and complete records.

Financial Management

Vitamin Angels is committed to managing its funds responsibly. This includes ensuring that all assets are safeguarded, that financial statements are in conformity with generally accepted accounting principles, and that finances are managed with responsible stewardship. All personnel with a role in the management of Vitamin Angels fiscal operations are expected to uphold the policies outlined in the Vitamin Angels Financial Policies and Procedures Manual.

Transparency and Disclosure

As a non-profit organization dependent upon financial support from generous individual and corporate donors, Vitamin Angels is committed to providing comprehensive and timely information to the public and members of the its Community. All information about Vitamin Angles will fully and honestly reflect the policies and practices of the organization. All financial, organizational, and program reports will be complete and accurate in all material respects.

Basic informational data will be maintained on Vitamin Angels’ website, such information shall include:

  • Corporate contact information;
  • Mission and vision statements;
  • Description of activities;
  • Form 990, audited financial statements, and annual report;
  • Names of Board Members and appointed corporate officers.

Relationships With Program Partners, Corporate Donors, Vendors, and Third Parties

Before entering into a partnership with an external partner (donor, program partner, vendor, contractor, etc.), Vitamin Angels shall determine if the partnership may have negative consequences in any country where VA works, or to VA’s mission; and / or any negative impact on VA’s reputation. If these impacts cannot easily and transparently be avoided, Vitamin Angels will refrain from entering into the partnership.

It is the intention of Vitamin Angels to partner with individuals and organizations whose practices are aligned with VA’s Code of Conduct. Such practices include, but are not limited to, the following:

  • Respecting human rights
  • Anti-terrorism and anti-lobbying
  • Child labor
  • Anti-Slavery
  • Anti-Bribery
  • Equal Employment Opportunity
  • Anti-Fraud and Corruption
  • Protecting women’s and children’s health

Diversity, Equity, and Inclusion

Vitamin Angels was founded upon the belief that everyone deserves a chance at a healthy life. Implicit in our continued existence as a public health organization is the reality that inequities exist and persist. We are committed to promoting fair and equitable practices, and to embedding those values in every aspect of our work, from who we serve and why, to how we approach collaboration, and the culture within our own workplace.

Vitamin Angels is committed to fostering an inclusive environment for every member of the VA Community. Our success is measured by the individual and shared experience of our team; in our ability to create a safe space where everyone’s voice can be heard, diverse perspectives and experiences are valued, and everyone feels they belong.

Real, meaningful, and lasting change can only occur when everyone takes part. At the organizational level we are focused on evaluating and improving practices related to hiring, training, career advancement, partnerships, communications, and leadership. We have established a council with representation across the organization and different professional and personal backgrounds dedicated to building a community where diversity, equity, and inclusion (“DEI”) is a reflex, not an initiative.

Equal Employment Commitment

Vitamin Angels believes that all persons are entitled to equal employment opportunity. It does not discriminate against qualified employees or applicants because of age, race, religious creed, color, national origin, ancestry, physical disability, mental disability, medical condition, genetic information, marital or registered domestic partner status, sex (including pregnancy, childbirth, breastfeeding and/or related medical conditions), reproductive health care decisions, gender, gender identity, gender expression, transgender status, sexual orientation, status as a victim of domestic violence or sexual assault or stalking, military or veteran status, or any other status protected by federal, state, or local laws (“Protected Characteristic”). Vitamin Angels also does not discriminate against anyone based on the perception that the person has any of these Protected Characteristics or is associated with a person who has, or is perceived as having, any of these characteristics. Equal employment opportunity will be extended to all persons in all aspects of the employer-employee relationship, including recruitment, hiring, upgrading, training, promotion, transfer, discipline, layoff, recall, and termination.

Prohibition Against Discrimination, Harassment, Sexual Harassment, and Bullying

Vitamin Angels is committed to providing a work environment that is free of discrimination, harassment, including sexual harassment, and bullying. Vitamin Angels strictly prohibits discrimination or harassment in any form against an individual because of that person’s Protected Characteristic.

Fraud and Corruption

Vitamin Angels upholds a zero-tolerance approach regarding fraud and corruption. Vitamin Angels will identify and promptly investigate any suspected fraudulent or related dishonest activity against Vitamin Angels or other parties with whom Vitamin Angels has dealings. Vitamin Angels will take appropriate disciplinary and legal actions to include the possibility of termination of employment or contractual agreement, restitution, and forwarding information to the appropriate authorities for prosecution.


Vitamin Angels is committed to conducting business with the highest ethical standard and will not knowingly provide material support or resources to any group or individual on the Office of Foreign Assets Control’s Specially Designated Nationals and Blocked Persons List (OFAC SDN List). Members of the VA Community warrant that they have not provided and will not provide any material support or resources to any individual or entity that it knows, or has reason to know, as an individual or entity that advocates, plans, sponsors, engages in or has engaged in terrorist activity. Any funds received or distributed by members of the VA Community will be used solely for their intended purpose and will not be diverted to terrorists or terrorist organizations. VA funds will not be used for the purpose of any payment to persons or entities if such payment or import or export of goods is prohibited by United States Laws or Executive Orders, by a decision of the United Nations Security Council taken under Chapter VII of the Charter of the United Nations, including under the United Nations Security Council Resolution 1373 and related resolutions, by EU regulations, or other laws that prohibit the provision of resources and support to individuals and organizations associated with terrorism and the terrorist related lists promulgated by the government of the United States of America, the United Nations, or the European Union.

Child Labor

Vitamin Angels is committed to conducting business with the highest ethical standards and will not engage in the use of child labor, nor will it enter into service agreements that use child labor. For this purpose, child labor is defined according to Article 3 of ILO Convention No. 182, and refers to the exploitation of children under the age of 14 through any form of work that deprives children of their childhood, interferes with their ability to attend school, and is mentally, physically, socially, and morally harmful.


Vitamin Angels shall engage in any activity, practice or conduct which would constitute an offense under anti-slavery legislation in the U.S, U.K. Modern Slavery Act 2015, or comparative legislation in jurisdictions where contracted services are performed. This encourages fair and equal treatment for all persons, the provision of safe and healthy working conditions, respect for the environment, the adoption of appropriate management systems, and the conduct of business in an ethical manner.


Vitamin Angels agrees and warrants that the funds provided to Vitamin Angels will not be used to influence the outcome of any election for public office, to support lobbying activities, or to otherwise support attempts to influence local, state, federal or foreign legislation. Vitamin Angels may, however, use donated funds to raise awareness to and advocate for the promotion of Vitamin Angels’ mission.


Vitamin Angels prohibits all forms of bribery and corruption. Vitamin Angels prohibits the bribery of government officials (both U.S. and non-U.S.) as well as private sector (commercial) bribery, including the offering, giving or promising (or authorizing someone to offer, give, or promise) an improper benefit, directly or indirectly, with the intention of influencing or rewarding the behavior of someone to obtain or retain an advantage.

Monitoring and Enforcement

Vitamin Angels is committed to full and ongoing enforcement of this Code of Business Conduct and of the standards contained in Vitamin Angels’ policies. As a condition of employment or appointment, all members of the VA Community are expected to rigorously comply with all applicable laws, rules, regulations policies, and procedures.

Vitamin Angels is mindful of the obligation to report suspected wrongdoing that adversely affects the organization. Vitamin Angels is committed to providing an environment of integrity that encourages the disclosure of violations of law, policy, and other standards to the Vitamin Angels leadership team, while protecting from reprisal its employees and other members of its community who make a good-faith disclosure of suspected wrongful conduct occurring at Vitamin Angels.

Questions or concerns regarding a violation of the law, policy, or other standards can be found in Vitamin Angels’ policy on Equal Employment Opportunities. Additional information can be found by consulting Vitamin Angels’ Whistleblower Policy.

Whistle Blower Protection

Vitamin Angels will not tolerate any form of retaliation against any member of the VA Community who reports a complaint or assists in the investigation regarding a claim for failure to be provided equal employment opportunity. If a member of the VA Community believes they are a victim of discrimination or harassment, including sexual harassment, they have the right to complain without fear of retaliation and are encouraged to come forward so that corrective action can be taken.

Federal and state law forbid retaliation against those who oppose discrimination or sexual harassment, complain about such discrimination or sexual harassment to Vitamin Angels, or file a complaint, testify, assist, or participate in any manner in an investigation, proceeding, or hearing conducted by state governing agencies. If a member of the VA Community feels they have been retaliated against, they should contact the People Operations team at If an employee believes that a member of the People Operations team has retaliated against them, they may make a report to any of the following Vitamin Angels Executives: Chief Executive Officer, Chief Financial Officer, or Chief Operations Officer. In California, they may also call the California State Attorney General’s Whistleblower Hotline at 1-800-952-5225.

Further, in accordance with Whistleblower protection statutes, Vitamin Angels will not tolerate any form of retaliation against any member of the VA Community who reports a complaint or assists in an internal or external investigation regarding a claim of suspected violations of any federal or state law; suspected violations of any noncompliance with local, state, or federal rules and regulations; or, unsafe work conditions, or work practices that impact employee safety or health.

Conflicts of Interest

Vitamin Angels is committed to clarity of our mission and vision, free of any appearance of conflict or impropriety, for this reason Vitamin Angels has adopted the following Conflicts of Interest Policy. A conflict of interest is considered to be any personal or financial interest or involvement in any customer, client, competitor, or supplier of Vitamin Angels, including outside employment or consulting. Furthermore, employees may not give or accept gifts, loans, or favors from persons having business relationships with Vitamin Angels. The receipt or giving of small gifts or casual entertaining for business purposes, however, is not prohibited.

Related-Party Transactions

Related-party transactions occur between two or more parties with interlinking relationships. These transactions should be disclosed to the Board of Directors and evaluated to ensure they are made on a sound economic basis. The organization should pursue any related-party transactions that are clearly advantageous to the organization, but should avoid those that represent conflicts of interest.

Vitamin Angels’ employees or Board of Directors may undertake transactions with related parties only in the following situations:

  • The audited financial statements of the organization fully disclose material related-party transactions;
  • Related parties are excluded from the discussion and approval of related- party transactions;
  • There are competitive bids or comparable valuations;
  • The disinterested members of the Board of Directors approves the transaction as one that is in the best interest of the organization.

Disclosure Requirements

If an employee or any of his or her close relatives (spouse, domestic partner, child, sister, brother, parent, grandparent, or in-laws) has, or is considering having, a personal or financial interest in a customer, client, competitor, or supplier of Vitamin Angels, or real estate adjacent to a Vitamin Angels location, the employee must disclose the interest or relationship to the Chief Financial Officer at Vitamin Angels as soon as possible.

Resolution of Conflict of Interest

Whenever these issues arise, the employee should contact the Chief Financial Officer at Vitamin Angels to discuss the issue. Vitamin Angels reserves the right to determine whether any relationship represents an actual or potential conflict of interest in violation of this policy.

Disciplinary Action for Violations of this Policy

Failure to promptly disclose actual or potential conflicts of interest to the Chief Financial Officer at Vitamin Angels may result in discipline, up to and including dismissal.


Vitamin Angels is committed to respecting the property rights of all those with which we do business, including beneficiaries and outside businesses. In their actions on behalf of Vitamin Angels, all members of the VA Community will act in a manner consistent with this respect of the property of others.

Each member of the VA Community will ensure that all applicable laws, standards and policies regarding the confidentiality of Vitamin Angels’ records are upheld. Additionally, members of the VA community will ensure that all private information owned by others, but in the custody and possession of Vitamin Angels, be held in confidence and not utilized outside of the use contemplated by the owner of the information without the express permission of the owner.

Vitamin Angels is committed to protecting its intellectual property by registering logos, trademarks, and copyrights and protects its confidential information by taking precautions to prevent inappropriate disclosures or loss. All members of the VA Community share a responsibility to protect VA’s intellectual property and confidential information. Members will not disclose any confidential or proprietary information obtained as a result of their involvement with Vitamin Angels. Confidential or proprietary information includes all non-public information.