Introduction
The FIDO Alliance is a non-profit industry organization that works to replace passwords with simpler, secure methods of authentication. It consists of hundreds of members varying in size and geographical diversity, and collaborates with industry partners and regulators around the world.
To help fulfil its mission, the FIDO Alliance has adopted this Code of Conduct, as an ethical framework for its interactions both within the alliance during working group and committee meetings, both online and in person, and for staff and volunteers representing the FIDO Alliance when meeting with other members, non-members, industry partners and regulators.
The FIDO Alliance believes that compliance with high ethical standards is key to meeting its objectives as well as being to the benefit of all stakeholders.
FIDO Alliance acknowledges that its member companies may have their own Code of Conduct or equivalent and anticipates that this Code of Conduct shall complement and reinforce those. This Code of Conduct shall apply to the FIDO Alliance staff and contractors at all times, as well as to its Members as their conduct relates to the activities of the FIDO Alliance.
1. NEUTRALITY
The FIDO Alliance maintains strict political, religious and philosophical neutrality.
2. EQUALITY
The FIDO Alliance and its Members shall respect the principles of equal treatment and equal opportunities between human beings. The FIDO Alliance and its Members abide by the principle of non-discrimination on the basis of, notably, race, origins, social group, sexual orientation, religion, beliefs, abilities, opinions or language.
3. PROTECTION FROM HARASSMENT
The FIDO Alliance and its Members bring together individuals from all over the world. All participants shall treat and be treated fairly, politely and with respect by their colleagues. Unacceptable behaviours include any form of harassment (sexual or otherwise), abusive, discriminatory, derogatory, demeaning, offensive, or dangerous conduct, as well as other behaviours that would be considered inappropriate within a professional setting.
4. PRIVACY & CONFIDENTIALITY
The FIDO Alliance and its Members shall apply the FIDO Alliance Privacy Policy and shall adhere to the applicable legal framework on data protection.
The FIDO Alliance and its Members shall maintain the confidentiality of non-public information, including confidential information provided by third parties, according to the FIDO Alliance Membership Agreement.
5. RESPECT FOR THE RULE OF LAW
The FIDO Alliance and its Members are committed to respecting the rule of law, in particular the laws, rules and regulations applicable to their activities depending on the jurisdiction at hand. In doing so, the FIDO Alliance and its Members should take into full consideration prevailing international decisions, treaties, conventions, and trade controls.
6. HONESTY & FAIR COMPETITION
The FIDO Alliance and its Members are required to adhere to the highest standards of honesty, respect, truth, fairness, and ethical behaviour. When communicating to other parties or to the public, the FIDO Alliance and its Members shall use best efforts to ensure the accuracy of statements and shall refrain from providing false, inaccurate or otherwise misleading information.
The FIDO Alliance is committed to complying with all applicable antitrust laws and regulations, and, by joining the alliance and executing the FIDO Alliance Membership Agreement, its Members agree to limit discussions to subjects that relate to the purposes of the FIDO Alliance, whether or not such discussions take place during formal meetings, informal gatherings, or otherwise.
7. NO CORRUPTION OR CRIMINAL ACTIVITIES
Neither the FIDO Alliance nor its Members shall use threats, bribes or other illegal means contrary to national anti-corruption laws to influence the adoption or implementation of laws, rules or regulations, or the content of court decisions. In the absence of national legislation, the FIDO Alliance and its Members shall abide by best international practices on anti-corruption in the private and public sectors.
8. NO CONFLICT OF INTEREST
FIDO Alliance Members commit to disclose any interest that could reasonably be considered to involve a conflict of interest and to refrain from any activity directly or indirectly giving rise to a conflict of interest.
9. PROHIBITION ON CONDUCT BRINGING THE FIDO ALLIANCE INTO DISREPUTE
FIDO Alliance and its Members will not engage in any conduct which brings FIDO into disrepute or jeopardises the integrity of its activities.
10. SOCIAL MEDIA
Participants’ use of social media can pose risks to the FIDO Alliance’s reputation and mission, and can even jeopardize the FIDO Alliance’s compliance with business rules and laws. To minimize these business and legal risks, the FIDO Alliance expects participants to adhere to the following guidelines and rules regarding social media use.
- Participants are responsible for what they personally communicate in social media and should remember that what they write might be made public, even if they initially intend for the communication to be private. Participants shall make clear in their personal social media activity that they are speaking on their own behalf. They will write in the first person and use their personal addresses and account names when communicating via social media. If a participant discloses their affiliation with the FIDO Alliance, they will also include a disclaimer that their views do not represent those of FIDO Alliance.
- Participants will use good judgment about what they post and remember that anything they say can reflect on the FIDO Alliance, even with the inclusion of a disclaimer.
- Participants must strive to be accurate in their communications about the FIDO Alliance and remember that their statements have the potential to result in liability for themselves or the FIDO Alliance. The FIDO Alliance encourages professionalism, respect and honesty in social media and all other communications. Participants should be mindful that the FIDO Alliance’s policies and procedures, and this Code, apply to their social media activity as well, including those policies and standards related to confidentiality, non-discrimination and harassment.
- If a participant is contacted for comment about the FIDO Alliance for publication, including in any social media or news outlet, they should direct the inquiry to marketing@fidoalliance.org .
11. IMPLEMENTATION
The FIDO Alliance is bound to this Code of Conduct at all times. The FIDO Alliance Members shall adhere to this Code of Conduct, in addition to their own ethical and compliance rules, when conducting any activities associated with the FIDO Alliance. Any external consultants engaged by Members shall also be required to adhere to this Code of Conduct as it relates to their activities concerning the FIDO Alliance.
Members, participants and staff who have concerns about conduct are encouraged to raise them in the first instance by emailing the Executive Director or another member of the FIDO Management Team directly, or where that is not appropriate, the Board President. Where a concern is raised informally, the recipient will acknowledge it in writing and work with the complainant to determine whether a formal complaint under this process is warranted.
Where a formal complaint is appropriate, it may be filed by emailing conduct@fidoalliance.org. This address is monitored by FIDO Alliance’s General Counsel, who will route complaints to the Executive Director or, where the complaint concerns the Executive Director, to the Board President. Complaints should include a description of the conduct in question, the date and context in which it occurred, and the names of any individuals involved, to the extent known.
All complaints will be treated confidentially to the extent permitted by the investigation process, and will be acknowledged within five (5) business days of receipt. Outcomes will be determined in accordance with Section 12 of this Code of Conduct. Upon the conclusion of the investigation and determination of the outcome, a follow-up will be provided to the submitter of the complaint.
Any general questions regarding this Code of Conduct may be directed to help@fidoalliance.org.
12. FAILURE TO FOLLOW THE CODE OF CONDUCT
If a participant engages in unacceptable behaviour, FIDO may take any action it deems appropriate, up to and including expulsion and/or disqualification from FIDO meetings, events and programs without warning.
Based on the nature of or continued conduct, failure to adhere to one or more of the principles of the Code of Conduct will be reviewed by the FIDO Board, which may suspend or terminate the membership of the Member concerned or require the person concerned to be replaced by the Member with immediate effect.
