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Xiente Code of Conduct & Ethical Standards (HUD Compliance)

Commitment to Ethical Standards

Xiente is committed to conducting all business in accordance with the highest ethical standards, in full compliance with the U.S. Department of Housing and Urban Development (HUD) Administrative, National, and Departmental Policy Requirements.

All officers, employees, board members, and agents of Xiente are expected to act with integrity, accountability, and transparency in their relationships with clients, partners, vendors, and the communities we serve. These standards ensure public trust and reinforce Xiente’s mission to advance economic mobility and community transformation.

As outlined in Xiente’s official Code of Conduct submission , all actions taken on behalf of the organization must reflect honesty, fiscal responsibility, and a commitment to equitable service delivery.

Code of Conduct for Procurement (2 CFR 200.318(c))

In accordance with federal regulations:

  • Xiente maintains written standards of conduct governing the procurement of property and services.
  • These standards apply to all employees, officers, board members, and agents engaged in the selection, award, or administration of contracts supported by federal funds.
  • Xiente ensures that no real or apparent conflict of interest compromises procurement decisions.

An up-to-date, signed Code of Conduct is maintained and available in HUD’s Code of Conduct e-library as required.

Conflict of Interest Policy

General Prohibition

No employee, officer, board member, or agent of Xiente—nor any immediate family member or affiliated organization—may:

  • Obtain a financial interest or benefit from HUD-funded activities;
  • Participate in decisions where a real or perceived conflict exists;
  • Benefit from contracts, subcontracts, or agreements tied to Xiente-funded programs.

This prohibition applies during tenure and for one year thereafter.

Procurement-Related Conflicts

All procurement activities comply with:

  • 2 CFR 200.317 (State entities)
  • 2 CFR 200.318(c) (Non-state entities)

Organizational Conflicts

Xiente will not engage in contracts where:

  • Objectivity is impaired;
  • There is an unfair competitive advantage;
  • Impartial decision-making cannot be ensured.

Any identified conflict must be disclosed in writing to the awarding agency.

Disclosure Requirements

All staff must promptly disclose any actual or potential conflicts to the Executive Director. Failure to disclose may result in disciplinary action, including termination.

Immediate Family Definition

Includes spouse, parents, children, siblings, grandparents, grandchildren, in-laws, domestic partners, and household members.

Standards on Gifts and Gratuities

To protect integrity and prevent undue influence:

  • Employees may not accept gifts, gratuities, or favors exceeding $25 in value from clients, vendors, or partners.
  • Employees may not offer gifts to clients, minors, or vendors without prior written approval.

These standards reinforce fairness and prevent perceived or actual bias in service delivery.

Organizational Conduct Requirements

In alignment with HUD expectations, Xiente’s Code of Conduct:

  • Prohibits both real and apparent conflicts of interest;
  • Applies to employees, officers, agents, and immediate family members;
  • Addresses both individual and organizational conflicts;
  • Establishes clear administrative and disciplinary actions;
  • Requires transparency and accountability in all operations.

Failure to comply may result in:

  • Disciplinary action up to termination;
  • Referral to federal, state, or local authorities where applicable.

Administrative and Disciplinary Actions

Violations of this Code of Conduct will result in appropriate administrative or disciplinary measures, including:

  • Corrective action plans;
  • Suspension or termination of employment;
  • Removal from board service;
  • Referral for civil or criminal enforcement when warranted.

Xiente maintains zero tolerance for ethical violations that compromise program integrity or public trust.

HUD Reporting & Compliance Requirements

To remain eligible for HUD funding, Xiente:

  • Maintains and submits its Code of Conduct to HUD;
  • Discloses any potential conflicts of interest;
  • Ensures all procurement and operational policies meet federal requirements.

Failure to comply may result in disqualification from receiving HUD funds.

Organizational Contact Information

Xiente
174 Diamond Street
Philadelphia, PA 19122
Phone: 215-426-8734
Email: info@xiente.org

Responsible Official:
Eliezer Vila, Compliance Director

Why This Matters

Xiente operates in communities where over 90% of families served are living below the poverty line, facing systemic barriers to housing, employment, and economic mobility . Maintaining strong ethical standards is essential to:

  • Protect public resources;
  • Ensure equitable access to services;
  • Build trust with families navigating pathways out of poverty.