As Libra Foundation Executive Officers, we pledge to:

• Engage in and promote ethical behavior, including ethically handling actual or apparent conflicts of interest between personal and professional relationships;
• Avoid conflicts of interest and disclose situations in which such a condition could reasonably be expected to arise;
• Take all appropriate measures to maintain the confidentiality of non-public Libra Foundation information and to, unless necessitated by legal or regulatory processes, prevent its disclosure;
• Take all reasonable measures to ensure responsible use of and control over Libra Foundation's assets and resources;
• Where required, promote full, fair, accurate, understandable and timely disclosure of reports and documents regarding Libra Foundation’s financial activities, in accordance with the following guidelines:
  • all accounting records, and the reports produced from such records, must be in accordance with all applicable laws;
  • all accounting records must fairly and accurately reflect the transactions or occurrences to which they relate;
  • all accounting records must fairly and accurately reflect, in reasonable detail and in accordance with generally accepted accounting principles, the Foundation’s assets, liabilities, revenues and expenses;
  • all accounting records must not contain any materially false or intentionally misleading entries;
  • no transactions should be intentionally misclassified as to accounts, departments or accounting periods;
  • all transactions must be supported by accurate documentation in reasonable detail and in all material respects be recorded in the proper account and in the proper accounting period;
  • no information should be concealed from the Foundation’s independent auditors; and
  • compliance with the Foundation’s system of internal controls is required.
• Comply with applicable laws, rules and regulations;
• Make every effort to cooperate with Libra Foundation and its independent public auditors, and refrain from taking any action to fraudulently influence, coerce, manipulate or mislead any such auditors;
• Avoid self-dealing with the Foundation and otherwise remain cognizant of the regulations set forth surrounding disqualified individuals in Section 4946(a) of Internal Revenue Code; and
• Promptly report violation of Libra Foundation's Code of Ethics to an appropriate supervising party.

Foundation executives agree to abide by this Executive Officers' Code of Ethics and consent to being held responsible for any breach of the Code. Infractions may be met with disciplinary action, up to and including termination of employment. Violations of this Code may also constitute breaches of the legal code and may result in civil and criminal penalties for the individual(s) responsible for such an infraction, that individual’s supervisors and/or Libra Foundation.