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Code of Conduct

This Code of Conduct sets forth Retirement Clearinghouse’s basic standards of behavior. All employees of RCH must conduct themselves in accordance with these principles and standards.

RCH will promote and require ethical conduct of employees while providing services on its behalf. This ethical conduct includes, but is not limited to, the following:
  • Maintaining honesty and integrity, and avoiding conflicts of interest in personal and professional relationships.
  • Providing customers with information that is accurate, complete, objective, relevant, timely, and understandable.
  • Complying with all applicable rules and regulations of federal, state, and local governments, and other appropriate regulatory agencies.
  • Acting in good faith, responsibly, with due care, competence, and diligence, without misrepresenting material facts.
  • Respecting and safeguarding the confidentiality of information in accordance with applicable law, regulation and Retirement Clearinghouse policies. Confidential information acquired in the course of one’s work must not be used for personal advantage.
  • Sharing knowledge and maintaining skills important and relevant to customer and client needs.
  • Proactively promoting ethical behavior as a responsible partner among peers in the work environment.
  • Demonstrating responsible use of and control over all assets and resources employed or to which entrusted.
All employees must manage their personal and business affairs in such a way as to avoid situations that might lead to a conflict between them and their duties to RCH, its customers, and its shareholders. All employees must manage their personal and business affairs in such a way as to avoid situations that might lead to a conflict between them and their duties with RCH, its customers, and its shareholders. It is acceptable for employees to recommend family and friends for employment, as this does not constitute personal gain. However, an employee’s position must never be used, directly or indirectly, for private gain, to advance personal interest, or to obtain favors or benefits for themselves, family members, or anyone else.


RCH prohibits all forms of bribery and corruption. Our Code of Conduct prohibits bribery of government officials (both U.S, and non-U.S.), as well as private sector (commercial) bribery (“kickbacks”), including the offering, promising, authorizing or providing anything of value to any customer, business partner, vendor or other third party in order to obtain or retain business, to secure some other improper advantage, or to improperly influence, induce or reward the performance of an activity connected with our business. This prohibition applies to all improper payments, regardless of size or purpose, including “facilitating” payments, which are made to expedite or facilitate actions or services, unless otherwise previously approved. Employees who observe conduct that may violate this policy should report the suspected violation to the Finance & Risk Management Department for investigation. Reports will be investigated and treated as confidential to the extent permitted by law. Retaliation for good faith reports of suspected misconduct is strictly prohibited.

The purpose of this code is to reiterate the high standard of conduct that is associated with ethical business practices and to identify areas and situations where public trust and confidence might be compromised, or a law violated and to set forth guidelines governing such situations.

Failure to comply with these guidelines may result in disciplinary action up to and including termination of employment. The action taken will be commensurate with the seriousness of the conduct and an evaluation of the situation.


RCH Whistleblower Policy