Code of
Conduct
Workplace Responsibility 
Employee Handbook

Workplace Responsibility Employee Handbook

TABLE OF CONTENTS
Message from CEO Tay Yoshitani............................................................2
Our Values...............................................................................................4 
Code of Conduct......................................................................................6

Employee Ethics and Conflicts of Interest........................................8
Consultant Ethics and Conflicts of Interest.....................................15
Former Employee Ethics and Conflicts of Interest..........................24
Gifts and Hospitality.........................................................................27
Fraud Awareness and Prevention...................................................32
Loss Prevention..............................................................................36 
Electronic Systems.........................................................................38
Anti-Harassment..............................................................................45
Equal Opportunity............................................................................50
Violence in the Workplace...............................................................52
Substance Abuse............................................................................55
Employment of Relatives.................................................................58
Political Activities.............................................................................61
Reporting Concerns or Violations...................................................63 

The Workplace Responsibility Program.................................................67

To request this document in an alternative format, contact Human Resources and
Development, 206.787.3836.

A MESSAGE FROM CEO TAY YOSHITANI 
The Port of Seattle is integral to the success of our community. Wehave existed since 1911 to serve this region as an economic engine,
creator of jobs, facilitator of trade and travel, builder of critical trade and
transportation infrastructure, and steward of the environment. We have a rich
and successful history. We are recognized globally as a leader among peers.
Our legacy is full of outstanding facilities, operations and programs that serve our
customers and the public.
We also are a public enterprise, a local government, with a mandate to conduct
our business with transparency and openness. We have an obligation to
continually and readily provide information to the public about our activities,
business dealings and practices, and other matters. Port employees must
respect, accept and be vigilant about maintaining our transparent environment.
Our taxpayers are entitled to nothing less.
Great organizations are built on a solid foundation of ethical, open and respectful
business practices and behavior. It is from such a foundation that public trust
grows. Yet, hard-earned trust and a fine reputation can tarnish quickly because
of the improper or unethical actions of just a few people. That is why every Port
employee must accept responsibility for maintaining public trust by managing
the public's assetsand our good namewith care and integrity. Every Port
employee is accountable for exercising high ethical standards in all matters
involving the Port.
A team of employees developed the Workplace Responsibility Program and
this Code of Conduct, incorporating core values and policies that provide a
framework for ensuring the highest standards of business conduct, ethics and
workplace behavior. I am asking every Port employee to read and follow this
Code of Conduct and its policies. I am asking everyone to speak up if the
values or Code standards are not being upheld. Moreover, I expect every Port
manager to actively promote the Code values, policies and standards, to provide
regular opportunities for workgroup discussions on these matters and to coach
employees to a higher awareness of workplace expectations.
2

Conducting all Port Business with Integrity and Respect

The Port is committed to providing training and guidance that will enable
employees to comply with this Code. Our goal is to have an open culture where
employees ask questions if they are unsure of the rules or the expected behavior
in a particular situationa culture where employees know whom to ask and
where to get the information they need. With a unified focus on ethics, workplace
behavior and business standards, the Port will continue to be a highly motivated
and successful organizationone that generates pride both in our workforce and
in the communities we serve.














3

4

OUR VALUES
These core values were developed by Port employees to guide and shape the Port's philosophy and culture. We intend for these values 
to be reflected in all of our business transactions, our community
interactions and our workplace.

We conduct business with the highest ethical standards. 
Our business practices reflect integrity, accountability, honesty,
fairness and respect at all levels. 

We honor our commitments to one another, the
community and our customers. We provide outstanding
service and value to each other, our customers, the citizens of
King County and the region we serve. 

We are capable, high-performing people who appreciate
the privilege of public service. We practice open
communication, innovation, collaboration and transparency in
all interactions. 

We embrace the richness of a diverse workplace and
support employee development. We encourage a healthy
and diverse organization that enhances our contributions
locally and globally. 

We are responsible stewards of community resources and
the environment. We exercise care and wisdom in the use of
both financial and natural resources.


5

CODE OF CONDUCT
The Code of Conduct is a set of policies that forms the foundation for how
we do business. The Code collects in one place key policies to guide us in all
business dealings and the treatment of others. Familiarity with the Workplace
Responsibility Program and the Code and associated policies is a basic
requirement of your employment. If you have a question or ever think that one
of your fellow employeesor the Port as a wholemay be falling short of our
commitments, speak up. Failure to follow the Code of Conduct, including any of
its policies, could lead to discipline up to and including termination.

The Port has many other policies and procedures that employees are expected
to read, understand and follow. However, the Workplace Responsibility Policies
are compiled within this Code of Conduct because they are interrelated and
fundamental to how the Port conducts all aspects of its business. The Statement
of Values, this Code of Conduct, and the included policies apply to all Port
business transactions and workplace activities.

While our Code of Conduct is written with employees in mind, it also applies
to contractors, consultants and others who may be temporarily assigned to
perform work or services for the Port. Failure of a Port contractor or consultant
to follow the Code can result in termination of their relationship with the Port.
Employees whose active duties with the Port have been terminated, but who are
still receiving any pay (including paid time off) or benefits from the Port, are also
expected to comply with the Code.





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Conducting all Port Business with Integrity and Respect

On the following pages you will find the policies that specifically fall under the
Code of Conduct, including:

Employee Ethics and Conflicts of Interest, CC-1
Consultant Ethics and Conflicts of Interest, CC-2
Former Employee Ethics and Conflicts of Interest, CC-3
Gifts and Hospitality, CC-4
Fraud Awareness and Prevention, CC-5
Loss Prevention, CC-6
Electronic Systems, CC-7
Anti-Harassment, CC-8
Equal Opportunity, CC-9
Violence in the Workplace, CC-10
Substance Abuse, CC-11
Employment of Relatives, CC-12
Political Activities, CC-13
Reporting Concerns or Violations, CC-14






7

Employee Ethics & Conflict of Interest

EMPLOYEE ETHICS AND CONFLICT OF INTEREST
Serving the Port Loyally
CC-1 as of 1/1/10

I. The Port's Interests Come First

Port of Seattle employees are expected to serve the Port with the highest
standards of ethical conduct and to avoid situations that create a real or
perceived "conflict of interest." A "conflict of interest" exists when an employee's
duty to give undivided loyalty to the Port is influenced, or could be influenced,
by personal interest. The fact of a conflict of interest is not in itself a violation of
the policy. Instead, it is something that should be reported (see Section IV) so
the Port may ensure that decisions are not made that could be influenced by the
conflict of interest, or perceived to have been influenced by it.

Port employees must ensure that any outside activity or personal interest is kept
separate from their position at the Port and does not influence their business
judgment on the Port's behalf. Port employees need to use common sense and
keep the interests of the Port paramount at all times. In addition to avoiding
actual conflicts of interests, Port employees should avoid situations that could
appear to be a conflict of interest. 

Ethical issues and conflicts of interest are not always obvious or clear. It is far
better to raise issues in advance and get guidance than to make the wrong
judgment call. Thus, when in doubt, please review the situation with the
Workplace Responsibility Officer. 

This policy is intended to
Guide employees so that they consistently conduct Port business without
being influenced by considerations of personal advantage or gain
Help employees identify potential ethical concerns and conflicts of interest
Require employees to disclose potential conflicts of interest; and
Require employees to report potential policy violations
8

Conducting all Port Business with Integrity and Respect

No policy can adequately substitute for personal honesty, common sense and
good judgment. At a minimum, Port employees are expected to apply these
attributes to their daily job-related activities. Port employees are expected to
conserve and responsibly use the resources the public has entrusted to the Port,
to act in accordance with applicable laws, and to conduct all Port business in a
manner that will reflect positively on the Port, its employees and the community. 

II. Real or Perceived Conflicts of Interest 

Port employees must avoid real, or perceived, conflicts of interest between
their private activities and their duties and responsibilities as employees. At a
minimum, potential conflicts should be reported so that the Port may consider
what, if any, actions should be taken to ensure that decisions are not influenced
(or perceived to be influenced) by personal interests.

The following are examples of situations in which an employee may feel
conflicting loyalties between what is in the best interest of the Port and what may
be in the best interest of the employee. For purposes of this policy, "Relative" is
defined to include an employee's spouse, domestic partner, parents, children,
cousins, nieces, nephews, grandparents, grandchildren, in-laws, and any person
with whom the employee has a relationship that is substantially equivalent to any
of the above. 

A. Conflicts from Business Relationships 

A conflict of interest may exist when an employee, an employee's Relative, or
someone with whom an employee has a significant personal relationship, directly
or indirectly, has a Financial or Beneficial Interest in, or operates, an organization
that competes with the Port, is doing business with the Port, or plans to do
business with the Port. Employees should, therefore, avoid owning interests in
or operating companies that compete with the Port, or that sell (or plan to sell)
products or services to the Port, other than minimal amounts of stock in publicly-
traded companies. 

The Port's policy is to award business solely on merit, without favoritism, by
9

Employee Ethics & Conflict of Interest

securing the best product or service available at the best price. Therefore, an
employee must disclose to the Workplace Responsibility Officer the existence
of any Financial or Beneficial Interest which, because of its existing or potential
relationship to the Port, could create a present or future conflict of interest. An
employee shall be presumed to have knowledge of any Financial or Beneficial
Interest held by a Relative.

For purposes of this policy, "Financial or Beneficial Interest" is defined to include:
(a) a creditor, debtor or ownership interest in an amount or value in excess of
$1,500; (b) any employee, consultant or partnership arrangement; or (c) any
option to purchase real or personal property.

No employee shall have a Financial or Beneficial Interest, direct or indirect,
in any contract that may be made by, through or under the supervision of the
employee, or for the benefit of the Port. No employee shallaccept, directly or
indirectly, any compensation, gratuity or reward in connection with such contract
from any other person beneficially interested therein.

An employee shall not participate in any decision-making, review, approval,
selection, authorization or supervisory activity concerning any contract or Port
transaction in which he/she or his/her Relative has a Financial or Beneficial
Interest. 

B. Conflicts from Outside Employment

Working with any organization that has a business relationship with the Port, or
seeks to have one, results in a conflict of interest if that business receives, or
may receive, more favorable treatment as a result of the employee's relationship
with the business. As a result, working for those with whom the Port has a
business relationship is prohibited unless expressly approved in writing by the
Workplace Responsibility Officer. 

Even if outside employment is with an organization that does not have a business
relationship with the Port, conflicts of time and energy may arise. Accordingly,
salaried, exempt employees must obtain prior written approval from his or her
10

Conducting all Port Business with Integrity and Respect

Department Head before holding a job with another organization. If such approval
is granted, the employee acknowledges that satisfactory job performance with the
Port must be maintained and that no conflict of interest can exist. 

All employees with other jobs will continue to be judged by the same
performance standards and will be subject to the Port's scheduling demands,
regardless of any existing outside work requirements. If the Port determines that
an employee's outside work interferes with performance or the ability to meet
the Port's changing requirements, employees may be asked to terminate outside
employment in order to continue employment with the Port. 

C. Improper Compensation 

No employee may, directly or indirectly, ask for or give or receive or agree to
receive any compensation, gift, reward or gratuity from a source for performing
or omitting or deferring the performance of any official duty, unless otherwise
authorized by law. See also Gifts and Hospitality Policy. 

III. Use of Position for Personal Benefit 

One particular type of conflict of interest arises when an employee is in a position
to exploit his or her role with the Port to advance his or her personal interest. A
conflict of interest also arises when an employee may have competing loyalties
between his or her personal interests and the Port's business. Employees must
avoid circumstances in which it appears, or to a reasonable person might appear,
that the employee is requesting or otherwise seeking special consideration,
treatment or advantage because of the employee's position with the Port.

A. Obtaining Special Privileges 

Port employees shall not use their employment position to secure special
privileges or exemptions for themselves or a Relative. This includes obtaining
any information, item or service from Port customers, suppliers, contractors,
consultants, or lessees (or potential customers, suppliers, contractors,
consultants, or lessees) or other Port employees. It also includes an employee
11

Employee Ethics & Conflict of Interest

using his position at the Port to help a Relative get a job offer from the Port or to
obtain a job offer from a Port vendor.

B. Use of Port Equipment

Employees are expected to use Port-owned property and equipment for official
Port business. An employee shall not take or use Port-owned property and
equipment for personal purposes, convenience or profit. This includes taking or
using fleet vehicles, shop tools, fax machines, copiers, postage, office supplies,
cameras, cell phones and laptops. 

It is not a violation of this policy for an employee to (i) engage in the incidental
personal use of such property or equipment (such as sending/receiving personal
e-mails while using a Port-owned laptop) while at the workplace, or (ii) engage
in other incidental uses of such property or equipment that may be specifically
permitted by a CEO's adopted policy (such as an employee's use of a Port
assigned cell phone to make a long distance call to a family member while
traveling on Port business, in accordance with Procedure AC-2) or CEO written
authorization. See also Electronic Systems Policy.

C. Safeguarding Confidential Information

An employee shall not disclose "Confidential Information" to third parties.
"Confidential Information" includes, without limitation, any information in whatever
form that the Port considers to be confidential, proprietary information and that
is not publicly or generally available relating to: trade secrets (as defined by
the Uniform Trade Secrets Act); matters discussed during Executive Sessions;
requests for proposals; proposed or pending real estate transactions; personnel
matters; all matters not subject to public disclosure; attorney-client privileged
communications and attorney work product; research and development; product,
content and technology development plans; marketing; databases; inventions;
research data and mechanisms; procedures; engineering; purchasing;
accounting; sales; customers; advertisers; investors; suppliers; financial status;
contracts or employees.

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Conducting all Port Business with Integrity and Respect

The Port's definition of Confidential Information for purposes of an employee's
requirements under this policy covers more information than may fall within the
public records disclosure rules. While the Port is committed to transparency
as a public agency, it also is respectful of employees and wants to foster an
environment in which opinions may be aired without fear of publicity. It also
needs to be able to formulate business strategy internally and make decisions
about when such discussion is ready for more public debate. Thus, if you have
a question about whether information is confidential, please consult with the
Workplace Responsibility Officer before communicating it externally.

An employee shall not use Confidential Information in any manner that is
detrimental to the Port. This restriction applies regardless of whether the use or
disclosure of Confidential Information results in any benefit to the employee or
the employee's Relative.

An employee shall not use Confidential Information for the benefit of the
employee or employee's Relative. An employee shall not accept secondary
employment or engage in business or professional activities that the employee
might reasonably expect would require or induce him/her to disclose Confidential
Information.

IV. Duty to Report Conflicts of Interest

Employees must report to the Workplace Responsibility Officer all potential
situations that could present a real or perceived conflict of interest, including
Financial or Beneficial interests held by the employee in entities doing business
with the Port. The fact of a conflict of interest is not, in and of itself, a policy
violation. Rather, it is the failure to disclose a real or potential conflict of interest,
and/or taking action on behalf of the Port when there is a real or perceived
conflict of interest that is of concern to the Port.

After an employee discloses a real or potential conflict of interest, the Workplace
Responsibility Officer will document the disclosure and determine any steps
that should be taken to avoid the employee's participation in any decision.
Employees also should report all potential conflicts of interest, financial or
13

Employee Ethics & Conflict of Interest

otherwise, of another employee who is in a position to influence the selection,
non-selection, or conduct of business between the Port and any entity.

In an effort to assist employees in identifying and disclosing potential conflicts
of interest, the Port will periodically ask employees to complete a "Statement of
Financial or Beneficial Interests" and disclose information that may relate to an
actual or perceived conflict of interest.

V. Reporting Concerns or Violations

All employees have a responsibility for ensuring that this policy is followed.
Concerns and potential violations should be reported to the Workplace
Responsibility Officer, or anyone identified in the "Reporting Concerns or
Violations" policy. Supervisors and managers will be held to a higher level of
responsibility with respect to reporting potential violations. Supervisors and
managers who know of or receive reports of potential violations must promptly
report them to the Workplace Responsibility Officer. Employees will not be
retaliated against for reporting in good faith concerns or potential violations of this
policy. See "Reporting Concerns or Violations" policy for more detail.

For further information, please contact the Workplace Responsibility Officer.







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Conducting all Port Business with Integrity and Respect

CONSULTANT ETHICS AND CONFLICT OF INTEREST
Serving the Port Loyally
CC-2 as of 1/1/10

I. The Port's Interests Come First

Port of Seattle consultants ("Consultants") are expected to serve the Port with the
highest standards of ethical conduct and to avoid situations that create a real or
perceived "conflict of interest." A "conflict of interest" exists when a Consultant's
duty to give undivided loyalty to the Port is influenced, or could be influenced,
by personal interest. The fact of a conflict of interest is not in itself a violation of
the policy. Instead, it is something that should be reported (see Section IV) so
the Port may ensure that decisions are not made that could be influenced by the
conflict of interest, or perceived to have been influenced by it.

Consultants must ensure that any outside activity or personal interest is kept
separate from their position at the Port and does not influence their business
judgment on the Port's behalf. Consultants need to use common sense and keep
the interests of the Port paramount at all times. In addition to avoiding actual
conflicts of interests, Port Consultants should avoid situations that could appear 
to be a conflict of interest.

Ethical issues and conflicts of interest are not always obvious or clear. It is far
better to raise issues in advance and get guidance than to make the wrong
judgment call. Thus, when in doubt, please review the situation with the
Workplace Responsibility Officer.
This policy is intended to
Guide Consultants so that they consistently conduct Port business without
being influenced by considerations of personal advantage or gain
Help Consultants identify potential ethical concerns and conflicts of
interest
Require Consultants to disclose potential conflicts of interest; and
Require Consultants to report potential policy violations
15

Consultant Ethics & Conflict of Interest

No policy can adequately substitute for personal honesty, common sense
and good judgment. At a minimum, Consultants are expected to apply these
attributes to their Port-related activities. Consultants are expected to conserve
and responsibly use the resources that the public has entrusted to the Port, to act
in accordance with applicable laws, and to conduct all Port business in a manner
that will reflect positively on the Port, its employees, its consultants, and the
community.

II. Real or Perceived Conflicts of Interest

Consultants must avoid real, or perceived, conflicts of interest between their
private activities and their duties and responsibilities as Consultants. At a
minimum, potential conflicts should be reported so that the Port may consider
what, if any, actions should be taken to ensure that decisions are not influenced
(or perceived to be influenced) by personal interests.

The following are examples of situations in which a Consultant may feel
conflicting loyalties between what is in the best interest of the Port and what may
be in the best interest of the Consultant. For purposes of this policy, "Relative"
is defined to include a Consultant's spouse, domestic partner, parents, children,
cousins, nieces, nephews, grandparents, grandchildren, in-laws, and any person
with whom the Consultant has a relationship that is substantially equivalent to
any of the above.

A. Conflicts from Business Relationships

A conflict of interest may exist when a Consultant, a Consultant's Relative, or
someone with whom a Consultant has a significant personal relationship, directly
or indirectly, owns any significant interest in or operates an organization that
competes with the Port, is doing business with the Port, or plans to do business
with the Port. Consultants should, therefore, avoid owning interests in or
operating companies that compete with the Port, other than minimal amounts of
stock in publicly traded companies. 

16

Conducting all Port Business with Integrity and Respect

The Port's policy is to award business solely on merit, without favoritism, by
securing the best product or service available at the best price. There is a
potential conflict of interest if a Consultant or the Consultant's Relative has a
Financial or Beneficial Interest in a business that sells products or services to
the Port. For purposes of this policy, "Financial or Beneficial Interest" is defined
to include (a) a creditor, debtor or ownership interest in an amount or value in
excess of $1,500; (b) any employee, consultant or partnership arrangement; or
(c) any option to purchase real or personal property.

No Consultant shall have a Financial or Beneficial Interest, direct or indirect, in
any contract which may be made by, through or under the supervision of the
Consultant, or for the benefit of the Port. No Consultant shall accept, directly or
indirectly, any compensation, gratuity or reward in connection with such contract
from any other person beneficially interested therein.

A Consultant shall not participate in any decision-making, review, approval,
selection, authorization or supervisory activity concerning any contract or Port
transaction in which he/she or his/her Relative has a Financial or Beneficial
Interest.

A Consultant shall disclose to the Workplace Responsibility Officer the existence
of any Financial or Beneficial Interest that, because of its existing or potential
relationship to the Port, could create a present or future conflict of interest for the
Consultant. A Consultant shall be presumed to have knowledge of any Financial
or Beneficial Interest held by a Consultant's Relative.

The Port recognizes that Consultants operate their own businesses and
are under contract with the Port to provide services and products. The Port
acknowledges that a Consultant will have a financial interest in the contract that
the Consultant enters into with the Port and will participate in that negotiation
process. Thus, this section of the policy is intended to cover those situations that
involve products, services, contracts and business interests that are separate
from the Consultant's then-existing contract with the Port.

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Consultant Ethics & Conflict of Interest

B. Conflicts from Other Engagements or Employment

Working with, or providing services to, any organization that has a business
relationship with the Port, or seeks to have one, results in a conflict of interest if
that business receives, or may receive, more favorable treatment as a result of
the Consultant's relationship with the business. As a result, working for those
with whom the Port has a business relationship is prohibited unless expressly
approved in writing by the Workplace Responsibility Officer.

Even if the other organization does not have a business relationship with the
Port, conflicts of time and energy may arise. Accordingly, Consultants who have
been retained to provide their exclusive services to Port business must obtain
prior written approval from the person with whom the contract has been entered
before holding a job with, or providing services to, another organization. If such
approval is granted, the Consultant acknowledges that satisfactory performance
with the Port must be maintained and that no conflict of interest can exist.

C. Improper Compensation

No Consultant may, directly or indirectly, ask for or give or receive or agree to
receive any compensation, gift, reward, or gratuity from a source for performing
or omitting or deferring the performance of any official duty, unless otherwise
authorized by law. See also Gifts and Hospitality Policy.

III. Use of Position for Personal Benefit

One particular type of conflict of interest arises when a Consultant is in a position
to exploit his or her role with the Port to advance their personal interest. A
conflict of interest also arises when a Consultant may have competing loyalties
between personal interests and the Port's business. Consultants must avoid
circumstances in which it appears, or to a reasonable person might appear, that
the employee is requesting or otherwise seeking special consideration, treatment
or advantage because of the employee's position with the Port.

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Conducting all Port Business with Integrity and Respect

A. Obtaining Special Privileges

Consultants shall not use their employment position to secure special privileges
or exemptions for themselves or a Relative. This includes obtaining any
information, item or service from Port customers, suppliers, contractors,
consultants, or lessees (or potential customers, suppliers, contractors,
consultants, or lessees) or other Consultants. It also includes a Consultant using
his or her engagement with the Port to help a Relative get a job offer from the
Port or obtain a job offer from a Port vendor.

B. Use of Port Equipment

Consultants are expected to use Port-owned property and equipment for official
Port business. A Consultant shall not take or use Port-owned property and
equipment for personal purposes, convenience or profit. This includes taking or
using fleet vehicles, shop tools, fax machines, copiers, postage, office supplies,
cameras, cell phones and laptops.

It is not a violation of this policy for a Consultant to (i) engage in the incidental
personal use of such property or equipment (such as sending/receiving personal
e-mails while using a Port-owned laptop) while at the Port workplace or (ii)
engage in other incidental uses of such property or equipment that may be
specifically permitted by a CEO's adopted policy (such as an employee's use of
a Port assigned cell phone to make a long distance call to a family member while
traveling on Port business, in accordance with Procedure AC-2) or CEO written
authorization. See also Electronic Systems Policy.

C. Safeguarding Confidential Information 

A Consultant shall not disclose "Confidential Information" to third parties.
"Confidential Information" includes, without limitation, any information, in
whatever form, that the Port considers to be confidential, proprietary, information
and that is not publicly or generally available relating to: trade secrets (as
defined by the Uniform Trade Secrets Act); matters discussed during Executive
Sessions; requests for proposals; proposed or pending real estate transactions;
19

Consultant Ethics & Conflict of Interest

personnel matters; all matters not subject to public disclosure; attorneyclient
privileged communications and attorney work product; research and
development; product, content and technology development plans; marketing;
databases; inventions; research data and mechanisms; procedures; engineering;
purchasing; accounting; sales; customers; advertisers; investors; suppliers;
financial status; contracts or employees. The Port's definition of Confidential
Information for purposes of a Consultant's requirements under this policy covers
more information than may fall within the public disclosure rules.

While the Port is committed to transparency as a public agency, it also is
respectful of employees and wants to foster an environment in which opinions
may be aired without fear of publicity. It also needs to be able to formulate
business strategy internally and make decisions about when such discussion
is ready for more public debate. Thus, if you have a question about whether
information is confidential, please consult with the Workplace Responsibility
Officer before communicating it externally. (See also EX-19, Access to Port
Public Records.)

A Consultant shall not use Confidential Information in any manner that is
detrimental to the Port. This restriction applies regardless of whether the use or
disclosure of Confidential Information results in any benefit to the Consultant's or
the Consultant's Relative.

A Consultant shall not use Confidential Information for the benefit of the
Consultant or Consultant's Relative. A Consultant shall not accept secondary
employment or engage in business or professional activities that the Consultant
might reasonably expect would require or induce him/her to disclose Confidential
Information.

IV. Duty to Report Conflicts of Interest

Consultants must report to the Workplace Responsibility Officer all potential
situations that could present a real or perceived conflict of interest, including
Financial or Beneficial interests held by the employee in entities doing business
with the Port. The fact of a conflict of interest is not, in and of itself, a policy
20

Conducting all Port Business with Integrity and Respect

violation. Rather, it is the failure to disclose a real or potential conflict of interest,
and/or taking action on behalf of the Port when there is a real or perceived
conflict of interest that is of concern to the Port.

After a Consultant discloses a real or potential conflict of interest, the Workplace
Responsibility Officer will document the disclosure and determine any steps
that should be taken to avoid the Consultant's participation in any decision.
Consultants also should report all potential conflicts of interest, financial or
otherwise, of another employee or Consultant who is in a position to influence the
selection, non-selection, or conduct of business between the Port and any entity.

V. Expectations of Former Consultants

A. Disclosure Requirements

For one (1) year after Termination of Port engagement, a Former Consultant
must disclose his or her past Port engagement to the Port before participating
in any Port business or activity and must also disclose his or her past Port
engagement before participating in any proceeding before the Commission. The
disclosure shall be made in writing to the Port's Workplace Responsibility Officer 
and/or the Commission President, as the case may be.

B. Special Consideration Prohibited

A Former Consultant shall not request or otherwise seek special consideration,
treatment or advantage from other Port staff or Port Commissioners. A Former
Consultant shall avoid circumstances in which it might appear to a reasonable
person that the Former Consultant is requesting or otherwise seeking or
receiving special consideration, treatment or advantage from other Port staff or
Port Commissioners.

C. Appearances Before Commission

For one (1) year after "Termination" of Port engagement, a Former Consultant
may not appear before the Port Commission on behalf of another individual
21

Consultant Ethics & Conflict of Interest

or entity, whether or not for compensation of any kind, in relation to any case,
proceeding, application or matter in which such Former Consultant participated in
a decision-making, negotiation, review, selection, supervisory or other significant
activity during his/her period of Port engagement. By way of limited exception,
the Commission may waive this provision if so requested by a Former Consultant
and after public discussion and a finding by the Commission that the public or the
Port's interests would be better served. For purposes of this policy, "Termination"
of Port engagement is defined as the latest date on which the Consultant
provided services or was paid for services (in the case of a retainer).

D. Participation in Contracts with Port of Seattle

For one (1) year after Termination of Port engagement, a Former Consultant
may not participate as a competitor in any competitive selection process, or
have a direct or indirect Financial or Beneficial Interest in any contract that was
made by, authorized or funded by Port action in which the Former Consultant
participated in a decision-making, negotiation, review, selection, supervisory or
other significant activity during his/her Port engagement. "Financial or Beneficial
Interest" is defined to include (a) a creditor, debtor or ownership interest in an
amount or value in excess of $1,500; (b) any employee, consultant or partnership
arrangement; or (c) any option to purchase real or personal property.

E. Use of Confidential Information

A Former Consultant shall not disclose or use any Confidential Information
gained by reason of his/her Port engagement unless the information is a matter
of public knowledge or is available to the public on request.

F. Employment

No Former Consultant may accept an offer of employment or receive
compensation from an Employer if the Former Consultant knows, has reason to
believe, or the circumstances would lead a reasonable person to believe, that the
offer of employment or compensation was intended, in whole or in part, directly
or indirectly, to influence the Former Consultant or as compensation or reward for
22

Conducting all Port Business with Integrity and Respect

the performance or nonperformance of a duty by the Former Consultant during
his/her Port engagement. For purposes of this policy, "Employer" means any
person, partnership, association, corporation, firm, institution, or other entity,
whether or not operated for profit.

VI. Reporting Concerns or Violations

All Consultants have a responsibility for ensuring that this policy is followed.
Concerns or potential violations should be reported to the Workplace
Responsibility Officer. Consultants will not be retaliated against for reporting
concerns or potential violations of this policy.

For further information, please contact the Workplace Responsibility Officer.












23

Former Employee Ethics & Conflict of Interest

FORMER EMPLOYEE ETHICS AND CONFLICT OF INTEREST
Serving the Port Loyally
CC-3 as of 1/1/10

I. The Port's Interests Come First

Former Employees of the Port of Seattle who are engaging in transactions with
the Port shall do so in an ethical manner and in accordance with this policy. The
purpose of this policy is to ensure that Port employees are not influenced in their
decision-making and actions by the possibility of obtaining employment or other
advantages with third parties after leaving the Port. It is also designed to ensure
that Former Employees do not use their prior position at the Port for special
consideration or advantage.

II. Expectations of Former Employees

A. Special Consideration Prohibited

A Former Employee shall not request or otherwise seek special consideration,
treatment or advantage from other Port staff or Port Commissioners. A Former
Employee shall avoid circumstances which to a reasonable person might appear
that the Former Employee is requesting or otherwise seeking or receiving
special consideration, treatment or advantage from other Port staff or Port
Commissioners.

B. Appearances Before Commission

For one (1) year after "Termination" of Port employment, a Former Employee
may not appear before the Port Commission on behalf of another individual
or entity, whether or not for compensation of any kind, in relation to any case,
proceeding, application or matter in which such Former Employee participated in
a decision-making, negotiation, review, selection, supervisory or other significant
activity during his/her period of Port employment. By way of limited exception,
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Conducting all Port Business with Integrity and Respect

the Commission may waive this provision if so requested by a Former Employee
and after public discussion and a finding by the Commission that the public
or the Port's interests would be better served. For purposes of this policy,
"Termination" of employment is defined as the latest date for which the employee
is receiving any pay or benefits from the Port, even if the employee ceased to
provide services to the Port earlier in time. Termination includes all voluntary
and involuntary separations from employment, regardless of the reason for the
separation.

C. Participation in Contracts with Port of Seattle

For one (1) year after Termination of Port employment, a Former Employee may
not have a direct or indirect Financial or Beneficial Interest in any contract that
was made by, authorized or funded by Port action in which the Former Employee
participated in a decision-making, negotiation, review, selection, supervisory or
other significant activity during his/her period of Port employment. "Financial
or Beneficial Interest" is defined to include (a) a creditor, debtor or ownership
interest in an amount or value in excess of $1,500; (b) any employee, consultant
or partnership arrangement; or (c) any option to purchase real or personal
property.

D. Participation in Competitive Selection Process

For one (1) year after Termination of Port employment, a Former Employee
may not participate as a competitor in any competitive selection process for a
Port contract in which the Former Employee participated in a decision-making,
negotiation, review, selection, supervisory or other significant activity in any way
during his/her Port employment.

E. Disclosure Requirements

For one (1) year after Termination of Port employment, a Former Employee must
disclose his or her past Port employment before engaging or participating in any
Port business or activity. The disclosure shall be made in writing to the Port's
Workplace Responsibility Officer.
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Former Employee Ethics & Conflict of Interest

F. Use of Confidential Information

A Former Employee shall not disclose or use any Confidential Information gained
by reason of his/her Port employment unless the information is a matter of public
knowledge or is available to the public on request. See Employee Ethics &
Conflict of Interest policy for definition of "Confidential Information."

G. Employment

No Former Employee may accept an offer of employment or receive
compensation from an Employer if the Former Employee knows, has reason to
believe, or the circumstances would lead a reasonable person to believe, that the
offer of employment or compensation was intended, in whole or in part, directly
or indirectly, to influence the Former Employee or as compensation or reward for
the performance or nonperformance of a duty by the Former Employee during
his/her Port employment. For purposes of this policy, "Employer" means any
person, partnership, association, corporation, firm, institution, or other entity,
whether or not operated for profit.

III. Reporting Concerns or Violations

All employees and Former Employees have a responsibility for ensuring that
this policy is followed. Concerns or potential violations should be reported to the
Workplace Responsibility Officer, or anyone identified in the "Reporting Concerns
or Violations" policy. Supervisors and managers will be held to a higher level
of responsibility with respect to reporting potential violations. Supervisors and
managers who know of or receive reports of potential violations must promptly
report them to the Workplace Responsibility Officer. Employees will not be
retaliated against for reporting in good faith concerns or potential violations of this
policy. See "Reporting Concerns or Violations" policy for more detail.

For further information, please contact the Workplace Responsibility Officer.

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Conducting all Port Business with Integrity and Respect

GIFTS AND HOSPITALITY
Ensuring Sound Business Decisions, 
Avoiding Undue Influence 
CC-4 as of 1/1/10

I.                 Statement of the Policy

The Port of Seattle's policy is that gifts and hospitality should never influence
imminent business decision-making processes or cause others to perceive that
there is an influence. Employees may not solicit Gifts. The Port also discourages
employees from accepting Gifts from an actual or potential business partner.
The Port requires employees to follow this policy not only to protect the Port's
business reputation but also to protect employees from unfounded allegations of
improper behavior.

A Gift is defined as anything of value that is received without any consideration
provided in return. Hospitality is defined as services, meals, entertainment,
beverages, lodging, transportation, experiences, and other similar activities that
are received without any consideration, or for consideration that is below the
fair market value. For purposes of this policy, both gifts and hospitality will be
referred to collectively as "Gifts." Any Gift given to an employee's relative or
guest shall be attributed to the employee for purposes of this policy unless an
independent business, family, or social relationship exists between the donor and
the relative or guest.

Employees are encouraged to ask themselves the following questions when
evaluating Gifts:
If I accept this Gift, will I feel obligated to respond in some manner?
Is this Gift a "reward" for a business decision?
Is this Gift excessive in value?
Would the public likely be concerned to find out I had received this Gift?
If the answer to any of these questions is "yes," or even unclear, then the Gift
should not be accepted, regardless of its value.
27

Gifts and Hospitality

Gifts related to promotional hosting activities are covered under the Port's
Promotional Hosting; Trade/Business and Community Development Expenses
policy AC - 4. If you have questions about how this policy applies in a given
circumstance, please contact the Workplace Responsibility Officer.

II. Specific Guidelines Regarding Gifts

A. Solicitation of Gifts Prohibited 

An employee may not receive, accept, take, seek, or solicit, directly or indirectly,
any Gift if it could be reasonably expected (or appear to a third party) that the
Gift would influence the action or judgment of the employee, or be considered as
part of a reward for action or inaction. If you have any question about whether
accepting a Gift would be improper, please ask the Workplace Responsibility
Officer.

B. Gifts Accepted on Behalf of the Port

A Port employee may accept a gift of any value as long as it is for, and on behalf
of, the Port. Any Gift so accepted shall become the property of the Port and not
of the employee. An Employee shall report the acceptance of any Gift under this
Section to the Workplace Responsibility Officer within thirty (30) days of receipt.

C. $50 Limit on Gifts 

Even if the acceptance of the Gift is not solicited and even if accepting the Gift
would not influence the employee's action or inaction, the Port believes it is
appropriate to limit Gifts to a $50 value. Thus, an employee may not accept a
Gift for the employee's benefit with an aggregate value exceeding $50 from a
single source in a calendar year. "Single source" means any person, vendor
or business partner, whether acting directly or through any agent or other
intermediary. In other words, one vendor may not provide an employee with
more than $50 worth of Gifts in a year, as it could appear to be an effort to
influence decisions.

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Conducting all Port Business with Integrity and Respect

An employee also may not accept a single Gift that may have been purchased
by multiple sources that has a value in excess of $50. The term "single gift"
includes any event, item or group of items used in conjunction with each other
or any trip including transportation, lodging, and attendant costs. For example,
an employee may not accept a Gift of a sports outing that has been paid for by
several vendors if the value exceeds $50, even if each contributing vendor spent
less than $50 toward the Gift.

D. Exceptions to $50 Limit on Gifts 

The following Gifts are presumed not to influence an employee's action or
non-action on any matter and may be accepted without regard to the $50 limit.
However, in the event that facts suggest that a Gift could influence a business
decision, or create the appearance of influencing a business decision, then the
Port may request that the Gift not be offered or accepted.
Unsolicited flowers, plants, and floral arrangements
Unsolicited advertising or promotional items of nominal value, such as
pens and note pads
Unsolicited items received by an employee for the purpose of evaluation
or review, if the employee has no Financial or Beneficial Interest (See
Conflict of Interest Policy for definition) in the eventual use or acquisition
of the item by the Port
Informational material, publications, or subscriptions related to the
employee's performance of official duties
Food and beverages consumed at hosted receptions where attendance
is related to the employee's official duties, including admission to, and
the costs of food and beverages consumed at, events sponsored by
or in conjunction with a civic, charitable, governmental, or community
organization, provided that where the Gift exceeds $50 on a single
occasion, it shall be reported to the Workplace Responsibility Officer
Unsolicited Gifts from dignitaries from another state or a foreign country
and intended to be personal in nature
Occasional Gifts in the form of food and beverage in the ordinary
course of meals where attendance by the employee is related to the
performance of official duties. If you have a question about whether
29

Gifts and Hospitality

attendance is related to official duties, please consult with the
Workplace Responsibility Officer. Gifts in the form of food and beverage
that exceed $50 per person on a single occasion shall be reported to the
Workplace Responsibility Officer. "Occasional" means not more than
four to six times per year with the same business partner. 

III. Items Not Considered Gifts

The following items are excluded from the definition of Gift and may be accepted
by an employee or Relative without constituting a violation of this policy.
Items from family or friends where it is clear beyond a reasonable doubt
that the item was not given as part of any design to gain or maintain
influence in the Port
Items related to the outside business of a Port employee that are
customary and not related to the employee's performance of his/her
official duties
Items exchanged among employees or between employees and Port
Commissioners, or a social event hosted or sponsored by an employee
or Port Commissioner for co-workers
Payments by a governmental or nongovernmental entity of reasonable
expenses incurred in connection with a speech, presentation,
appearance, or trade mission made in the employee's official capacity.
"Reasonable expenses" are limited to travel, lodging, and subsistence
expenses incurred the day before through the day after the event.
Items an employee is authorized by law to accept, including, but not
limited to, items accepted in accordance with the Port's Promotional
Hosting; Trade/Business and Community Development Expenses policy
AC  4
Payment of enrollment and course fees and reasonable travel expenses
attributable to attending seminars and educational programs sponsored
by a bona fide governmental or nonprofit professional, educational,
trade or charitable association or institution. "Reasonable expenses" are
limited to travel, lodging, and subsistence expenses incurred the day
before through the day after the event. 

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Conducting all Port Business with Integrity and Respect

Items returned by the employee to the donor within thirty (30) days of
receipt or donated to a charitable organization within thirty (30) days of
receipt
Campaign contributions reported under chapter 42.17 RCW
Discounts available to an employee as a member of an employee
group, occupation, or similar broad-based group
Awards, prizes, scholarships, or other items provided in recognition of
academic or scientific achievement. Unsolicited tokens or awards of
appreciation in the form of a plaque, trophy, desk item, wall memento or
similar item.

IV. Reporting Concerns or Violations

All employees have a responsibility for ensuring that this policy is followed.
Concerns or potential violations should be reported to the Workplace
Responsibility Officer, or anyone identified in the "Reporting Concerns or
Violations" policy. Supervisors and managers will be held to a higher level of
responsibility with respect to reporting potential violations. Supervisors and
managers who know of or receive reports of potential violations must promptly
report them to the Workplace Responsibility Officer. Employees will not be
retaliated against for reporting in good faith concerns or potential violations of this
policy. See "Reporting Concerns or Violations" procedure.

For further information, please contact the Workplace Responsibility Officer.





31

Fraud Awareness & Prevention

FRAUD AWARENESS & PREVENTION
Promoting Trust and Vigilance 
CC-5 as of 1/1/10
I. Statement of the Policy

The Port of Seattle serves the public. Every Port employee has a responsibility to
earn and maintain the public's trust by using using taxpayer resources wisely and
preventing loss and fraud. The Port is committed to having a work atmosphere
of fraud awareness, where its employees, interns and volunteers, are skilled to
identify potential fraudulent activity and are supported when carrying out their
responsibility to immediately report such activity. Every employee is expected
to follow this policy and to immediately report known or suspected loss of public
funds or assets or "Fraud."

Fraud is a unique and particularly insidious form of dishonesty that is being
called out separately from the Port's related Loss Prevention Policy (EX 18),
to emphasize the seriousness of such acts. For purposes of this policy, the
Port defines "Fraud" broadly. It includes any act of deception that is, or could
reasonably be expected to, result in personal gain. It includes any situation
in which Port resources are diverted to an employee, or the employee's
Relative, friends, or associates, without authorization, which may also include
misappropriation. Fraud may exist whether there is actual harm to the Port or not.

The Port of Seattle has zero tolerance for Fraud. "Zero tolerance" means
that complaints of violations of this policy will be reviewed and any
violations will be addressed. The manner in which violations are addressed
will depend on the circumstances. Employees could be subject to
progressive discipline up to and including immediate termination. 
Employees must report suspected violations of this policy. See "Reporting
Complaints" policy for more detail.

"Relative" is defined to include an employee or a consultant's spouse,
domestic partner, parents, children, cousins, nieces, nephews, grandparents,
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Conducting all Port Business with Integrity and Respect

grandchildren, in-laws, and any person with whom the employee or consultant
has a relationship that is substantially equivalent to any of these.

II. Specific Purposes of this Policy

To ensure proper stewardship over public funds and assets, and provide
timely and proper handling of any known or suspected fraudulent activity
To comply with RCW 43.09.185, that requires State agencies and local
governments to immediately report any known or suspected loss of
public funds or assets to the State Auditor's Office (SAO)
To establish clear expectations and ensure consistent and timely action
by the Port
To ensure that losses are minimized; investigations and audits are not
hampered; and bond claims are not jeopardized 

III. What and How to Report
Employees must report any irregularity that reasonably leads a Port employee
to suspect Fraudregardless of amount or type. Early and vigilant reporting
will allow the Port to minimize losses by addressing matters before they become
larger issues. The reporting requirement also includes issues that have occurred
in the past but have only recently become apparent. When in doubt, report.
Employees also should report suspicions of Fraud even if the matter has been
referred to law enforcement. Any Port employee who becomes aware of or
suspects Fraud shall immediately report this to the Ethics and Compliance
Hotline, the Port's General Counsel, or the Workplace Responsibility Officer
even if it is also separately referred to the Port Police. Employees will not be
retaliated against for reporting concerns or complaints of suspected Fraud. See
"Reporting Concerns or Violations" policy.

IV. Investigation Process

A. Commitment to Review and Investigate

The Port will review and investigate concerns or complaints of Fraud, as outlined
in the Port's Reporting Concerns or Violations policy. Employees are expected
33

Fraud Awareness & Prevention

to fully cooperate with, and avoid any actions that may impede an audit or
investigation.

B. Fraud Response Committee

The following is additional information about the investigation process and the
Port's Fraud Response Committee. The Port will generally follow the process
outlined below. However, the Port reserves the right to take an approach that
best suits the particular situation and may not follow every step outlined below in
all cases.
The Port's Fraud Response Committee is comprised of the Deputy CEO,
General Counsel, Chief Financial Officer and the Accounting and Financial
Reporting Director. If any member of the Committee has or reasonably
believes they may have a conflict with any matter, they shall immediately
recuse themselves from any further participation in that matter.
The General Counsel or Workplace Responsibility Officer will respond to
reports of suspected fraud received through the Ethics and Compliance
Hotline, and will forward such reports to the Port Police. The Port Police
will forward all reports of suspected fraud brought to their direct attention
to the General Counsel and Senior Internal Audit Manager.
Following receipt of a report of Fraud, the General Counsel shall advise
the Commission President and Chief Executive Officer. In concert with the
Port Police and the Senior Internal Audit Manager, the General Counsel
shall make preliminary inquiries and review relevant documents for the
purpose of determining whether cause exists to pursue the matter further,
either as an employment matter or as a civil matter to recover funds or
assets. The General Counsel also may submit requests for additional
information through the Ethics and Compliance Hotline process as
necessary. The General Counsel then will draft a written recommendation
that the matter be pursued further or that the matter should be closed for
lack of substantiation. The General Counsel may not interfere with any
police investigation or any decision by the Port Police to refer a matter for
prosecution.
The General Counsel shall forward his or her recommendation to the
Commission President, the Chief Executive Officer and members of the
Fraud Response Committee. If the General Counsel recommends closing
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Conducting all Port Business with Integrity and Respect

the matter, the Commission President, the Chief Executive Officer, or any
member of the Fraud Response Committee may request further review
and the matter will be forwarded to the Fraud Response Committee.
If the Fraud Response Committee determines that further action is
necessary, the Committee will determine the appropriate next steps
including establishing the scope of the inquiry and determining whether
in-house resources or outside consultants should be used to conduct the
review.
The Senior Internal Audit Manager, or retained consultant as determined
by the General Counsel or by the Fraud Response Committee, shall
conduct an investigation to gather the facts, determine the nature of the
irregularity, and inform the General Counsel and/or Fraud Response
Committee.
At the point it is suspected or known that a Fraud has occurred, the Senior
Internal Audit Manager shall immediately notify the SAO in accordance
with RCW 43.09.185.
The General Counsel or the Fraud Response Committee shall
recommend the appropriate next steps for disciplinary action and
recovery of funds or assets, based on the Senior Internal Audit Manager's
or retained consultant's assessment and recommendations. Any
recommended actions shall be implemented pursuant to applicable Port
policies and procedures. Any such recommendations shall be coordinated
with any ongoing criminal investigation.
The Senior Internal Audit Manager shall notify the Risk Manager of
all known and suspected instances of fraudulent activity. The Risk
Manager, in coordination with General Counsel, shall determine whether
to file a claim against the Port's employee dishonesty insurance policy,
considering the circumstances.
Any Port employee in possession of or responsible for relevant financial,
operational and all other records shall protect them from loss or
destruction, and all original records related to the loss shall be secured in
a safe place until a full audit/investigation has been completed.

For further information, please contact the Workplace Responsibility Officer.

35

Loss Prevention

LOSS PREVENTION
Preventing Loss of Public Funds and Assets 
CC-6 as of 1/1/10

I. Statement of the Policy
The Port of Seattle serves the public. Every Port employee has a responsibility
to earn and maintain the public's trust by using taxpayer resources wisely and
preventing loss, whether accidental or intentional. Every employee is expected
to follow this policy and to immediately report known or suspected loss of public
funds or assets. See "Reporting Concerns or Violations" policy for more detail.
For concerns about potential fraudulent activity, please refer also to the "Fraud
Awareness and Prevention" policy.

II. Specific Purposes of this Policy
To ensure proper stewardship over public funds and assets, and provide
timely and proper handling of any known or suspected loss of such
funds or assets
To comply with RCW 43.09.185, that requires State agencies and local
governments to immediately report any known or suspected loss of
public funds or assets to the State Auditor's Office (SAO)
To establish clear expectations and ensure consistent and timely action
by the Port
To ensure that losses are minimized, investigations and audits are not
hampered, and bond claims are not jeopardized 

III. What to Report
The Port encourages reporting of losses. Early and vigilant reporting will allow
the Port to minimize losses by addressing matters before they become larger
issues. Thus, employees must report any irregularity that reasonably leads a
Port employee to suspect a loss of Port funds or assets, in accordance with this
policy. This includes all suspected losses including losses resulting from unlawful
36

Conducting all Port Business with Integrity and Respect

activity such as theft and fraudregardless of amount or type. It also includes
those that have occurred in the past but have only recently become apparent.
When in doubt, report. See "Reporting Concerns or Violations" policy.

A. Required Reporting 

Port employees must report all suspected or known losses of Port funds and
assets in accordance with this policy, subject to the exceptions set out in
Sections B and C below. This includes all suspected losses that have occurred
in the past, but only recently become apparent. Reports should be made in the
manner described in the "Reporting Concerns or Violations" policy.

B. Materiality of Reportable Losses
A loss of a "de minimus" amount, defined as under $50 (fifty dollars), may but
need not be reported. However, a pattern of suspected recurring losses that may
in aggregate exceed $50 must be reported. The full exposure to the Port can
only be determined by a thorough investigation. However, any loss resulting from
suspected unlawful activity such as theft and fraud must be reported regardless
of the amount of the loss.

C. Losses That Generally Need Not Be Reported 

The following activities generally need not be reported, which is consistent with
State Auditor's Office guidelines. However, those in leadership positions for the
related operations are responsible to monitor such activities for unreasonable
irregularities and take action in accordance with this policy as necessary.
Normal and reasonable "over and short" situations from cash receipting
operations. These transactions are to be recorded in the accounting
system as miscellaneous income and expense, respectively, and
monitored by cashier for any unusual trends.
Reasonable inventory shortages identified during a physical count.
These inventory adjustments are to be recorded in the accounting
system and monitored accordingly.

For further information, please contact the Workplace Responsibility Officer.
37

Electronic Systems

ELECTRONIC SYSTEMS POLICY
Using Our Systems Responsibly
CC-7 as of 1/1/10
I. Statement of the Policy
The Port of Seattle is committed to providing a work environment that
encourages the use of computers and electronic communications tools to support
our business. The Port expects all employees and contractors (who have been
provided access) to use the Port's electronic communications systems in a
responsible and respectful manner that furthers the best interests of the Port
and reflects well on the Port. This policy is designed to help you understand the
Port's expectations for use of its electronic communications systems (including
e-mail, instant messaging, text messaging, voice mail and the Internet), and
to help you use those resources wisely. This policy applies to all electronic
communications using Port equipment or Internet access, including but not
limited to company computers, mobile phones, portable electronic devices
and Internet access provided by the Port. It also applies to any electronic
communications which identify a person as employed by the Port.

II. Overarching Concepts
Common Sense and Good Judgment. No policy can adequately
substitute for personal common sense and good judgment. At a
minimum, Port employees are expected to apply these attributes to
their daily job-related activities and their electronic communications.
Employees should ask themselves: "Would I be proud to have this
printed on the front page of the newspaper?"
Respectful Treatment of Others. Employees may not use electronic
systems in any way that may be seen as insulting, embarrassing,
harassing, or offensive by other persons. Examples of forbidden
transmissions include sexually-explicit or X-rated messages, cartoons,
or jokes; unwelcome propositions or love letters; ethnic or racial slurs;
political, sexual or religious propositions or invitations, or any other
message that can be construed to be harassment or disparagement of
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Conducting all Port Business with Integrity and Respect

others based on their sex, race, sexual orientation, age, national origin,
or religious or political beliefs. Employees should not use electronic
systems to forward messages likely to embarrass the original sender.
No Right of Privacy: The electronic mail system, Internet access, and
other electronic systems have been installed by the Port to facilitate
business communications. Although each employee has an individual
password to access this system, it belongs to the Port. The Port
respects the individual privacy of its employees. However, employee
privacy does not extend to the employee's work-related conduct or to
the use of Port-provided equipment or supplies. Therefore employees
should never assume electronic communications are totally private and
confidential. Since your personal messages can be accessed by Port
management without prior notice, you should not use e-mail to transmit
any messages you would not want read by a third party.
The Port reserves the right, in its discretion and without employee
permission, to review any employee's electronic files, e-mail
messages and Internet usage to ensure that electronic systems are
being used in compliance with the law and with Port policies.
Incidental Personal Use: Electronic media and services are for
business use. Limited, occasional or incidental use of electronic media
for personal, non-business purposes is understandable and acceptable. 
However, employees need to demonstrate a sense of responsibility and
may not abuse the privilege. Any employee found to be abusing the
privilege of company-facilitated access to electronic media or services
will be subject to corrective action and/or risk having the privilege
removed.
Employees should take particular care to ensure that any personal
use of social media remains incidental. The nature of social media
is such that it can easily consume more productive work time than
is reasonable or incidental. Employees also should remember that
all content posted is subject to disclosure and review by the Port
and others.


39

Electronic Systems

III. Responsible Use 

The Port encourages employee use of technology resources and services to
facilitate Port business. This includes conducting research, collaborating with
co-workers, and communicating with others. Subscriptions to electronic news
groups and mailing lists are permitted only for a work-related purpose. Any other
subscriptions are prohibited.

Because the email system often feels like a less formal method of
communication than paper, and is not a face-to-face communication, users may
lapse into more casual communication styles or be more candid than usual.
Employees should use professional language and keep in mind that e-mail has
the potential to be forwarded, read by a third party or published in the media.
E-mail may be subject to public disclosure.

E-mail footers and signature blocks should generally be used to provide the
user's name, title and telephone number. Signature blocks may not contain
commercial, political, religious, or inappropriate references and must be
consistent with this policy.  

The Port prohibits use of the electronic systems that violate the Port's policies,
the law, or has the potential to damage the Port's community image or business
interests. We provide the following examples to illustrate what is not acceptable
use of the Port's systems:
Sending, receiving, or soliciting offensive, sexually-explicit, or harassing
statements, images or language including disparagement of others based
on their race, national origin, sex, sexual orientation, age, disability, or
religious or political beliefs
Browsing or downloading content from Internet sites containing sexually-
oriented images or information, gambling content, content associated with
violence or hate, spyware and hacking tools, or criminal activity
Updating, searching, reading personal Web sites or blogs that do not
relate to Port business, other than incidental use outside normal work time
Copying, disseminating, or reproducing information on the Internet that
has been authored by others without the express permission of the author
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Conducting all Port Business with Integrity and Respect

or copyright holder(s)
Downloading/installing software not licensed to the Port
Disclosing, sending, receiving, printing, or otherwise disseminating
proprietary data, trade secrets, or confidential informationincluding
Security Sensitive Information (SSI) (e.g., social security numbers, credit
card numbers, drivers' license numbers, PIN numbers, personal medical
information, etc.)in violation of the Port's confidentiality, privacy and
security policies, proprietary agreements, or local, state, or federal law
Soliciting, proselytizing, or advancing personal political purposes,
commercial ventures, religious or personal causes or outside
organizations, or engaging in other similar, non-job-related solicitations
Soliciting funds or services for charitable causes without prior approval
from the Director of Human Resources and Development
Sending chain letters, pyramid schemes, gambling, or engaging in any
other activity in violation of local, state, or federal law
Gaining access to Port technology services, systems, content, or
infrastructure by using any access-control mechanism not assigned to
the particular user ("impersonating"), or permitting another person to have
access by sharing one's Port credentials and passwords
Gaining, or attempting to gain, unauthorized access to any computers,
computer networks, databases, data, or electronically-stored information
Using, transmitting, changing, or deleting another user's files, documents,
software, or other media without the user's or manager's permission
Introducing destructive software or programs such as computer viruses,
Trojan horses, or worms, adware, spyware, keystroke-loggers, root kits, or
other malware into any computer, computer system, or network
Installing, implementing or using Peer-to-Peer networking systems such
as Kazzaa, Gnutella, BitTorrent, etc. on Port computers
Using systems and technology that disguise or alter the identifying
information of the computer user, such as external proxies or anonymizer
sites, for any purpose 

IV. Protecting Our Assets

Employees must take all reasonable precautions to prevent the loss or theft
of Port computers, PDAs, phones, USB Drives, portable media and other
41

Electronic Systems

information assets. At a minimum, passwords must be used on all Port
computers and PIN numbers must be used on all Port portable devices (e.g.,
PDAs, smart phones), unless a specific exception has been authorized, as in
the case of Blackberries used by certain public safety personnel. An employee
who learns of the loss or theft of a computer or other information asset shall
immediately notify their manager or supervisor and the ICT Service Desk
(206-787-3333). 

V. Protecting Our Systems

A. Managing Resources Wisely

Employees must take care to not overburden the Port's electronic systems by
saving unnecessary files, downloading unauthorized programs, exposing the
Port to allegations of copyright infringement, or introducing viruses. To that end,
unless an employee has approval of the Chief Information Officer, ICT Senior
Manager of Infrastructure, or Manager Enterprise Information Security, an
employee should not:
Alter any software, utility, or configuration parameters installed by ICT
Establish wireless access points/networks and/or modems anywhere on
the Port network
Attach any devices anywhere on the Port network infrastructure
(including printers, servers, routers, switches, firewalls, hubs, etc)
Customize the computer work station if doing so would result in
installing or downloading inappropriate or copyrighted content,
unlicensed software, or modifying security settings 

ICT may restore information technology systems to their original configuration at
any time if necessary to restore functionality, operability, or reduce risks to other
Port systems and infrastructure.

In addition, the ability to install or download software and make changes to the
workstation by the individual user may be revoked at any time for any reason.

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Conducting all Port Business with Integrity and Respect

B. Protecting Against Viruses

Employees must exercise caution to avoid the introduction of computer viruses
or other destructive files or programs into Port computers or the network. Where
employees are authorized to use their personal computers to gain access to the
Port network via some form of remote-access (e.g., VPN, Outlook Web Access
or OWA), those employees must maintain and apply current antivirus software
on that equipment and follow the procedures outlined below. At a minimum,
employees should not
Download or open e-mail attachments from unknown senders
Download files from the Internet and File Transfer Protocol (FTP)
servers without being sure of a file's security authenticity and security
Upload or send any file or program saved on any removable media and
originating from a computer outside the Port network, unless you have
taken reasonable precautions to ensure that the disk, file, or program is
free of any virus or other destructive file or program 

C. Enhancing Security through Passwords

Access to Port systems is only for authorized users. Access is restricted and
monitored via several means such as user identification and password. Also,
other means such as biometrics, smart cards, USB fobs, etc. can be used to
protect access to the Port network and resources. Users shall comply with the
following requirements and guidelines:
Passwords and other access-control tools must not be shared with
anyone including the Service Desk, co-workers or managers
Passwords and log on information are not to be publicly posted in
any manner or format, and are not to be left in an insecure location.
Employees are recommended to store their passwords in secure
password "safes."
If you believe your password or any other access-control tool has been
compromised, immediately change your password and contact the ICT 
Service Desk (206-787-3333). 

43

Electronic Systems

VI.     Appropriate Use Audits
Electronic auditing may be implemented, with or without notice, on any Port
network or on any Port resource to support identification, termination, and
prosecution of unauthorized activity. These electronic audit mechanisms may be
capable of recording the following:
Access to all computer and phone systems, including successful and
failed log-in attempts, connect time, and log-outs  
Inbound and outbound file and content transfers
Connections to and from external systems
Sent and received e-mail and voice mail messages
Specific information about Web sites visited, including uniform resource
locator (URL) of pages retrieved, and information downloaded
Date, time, and user associated with each event 

VII. Reporting Concerns or Violations
Employees are required to report all suspected security and/or policy violations
to the Director of Human Resources and Development, or anyone identified in
the "Reporting Concerns or Violations" policy. Employees will not be retaliated
against for reporting in good faith concerns or potential violations.

VIII.    Violations

Violations of this policy may result in disciplinary action including termination of
e-mail or Internet privileges, termination of employment, and/or referral of the
employee to law enforcement authorities for local, state and federal offenses.
Nothing in this policy shall be understood to prevent ICT personnel who are
authorized and responsible for the management and administration of the Port's
electronic systems from taking actions to protect those systems or carry out the
intent of this Policy. Further, nothing in this Policy shall be understood to limit
authorized Human Resources and Development, Records Management or Legal
Department personnel from taking such action, or requesting such information,
as may be necessary to comply with any legal obligation or their job duties.
For further information, please contact the Director of Human Resources and
Development.
44

Conducting all Port Business with Integrity and Respect

ANTI-HARASSMENT
Fostering a Respectful Workplace
CC-8 as of 1/1/10
I. Unlawful Harassment Will Not Be Tolerated

The Port of Seattle is committed to providing a respectful, supportive and
productive workplace for all employees that is free of verbal, physical and visual
forms of unlawful harassment. One of the Port of Seattle's core values is treating
co-workers, customers, contractors, vendors and community members with
respect. Consistent with that value, the Port of Seattle does not tolerate unlawful
harassment in the workplace.

Unlawful harassment refers to behavior that is not welcome, that is personally
offensive, that debilitates morale, and interferes with work effectiveness. It
includes, but is not necessarily limited to, unwelcome verbal or physical conduct
that is derogatory of an employee because of their age, race, color, national
origin/ancestry, religion, disability, Family Medical Leave Act (FMLA) use,
pregnancy, sex/gender, sexual orientation, whistleblower status, marital status,
military status, use of workers' compensation, transgender status, political beliefs,
or any other category protected by law ("Protected Status"). Not all disrespectful
activity rises to a level of severity and pervasiveness that would be considered
unlawful harassment. However, the Port strives to eliminate all disrespectful
conduct from the workplace.

The Port does not tolerate unlawful harassment or disrespectful conduct in the
workplace. This policy also applies to business-related activities that take place
outside of the workplace, such as business-related trips, meetings and social
events. The Port also will not tolerate unlawful harassment or disrespectful
conduct of any of its employees by non-employees (including customers, visitors,
and independent contractors).
The Port has a "zero tolerance" policy concerning harassment. "Zero
tolerance" means complaints will be reviewed and violations of this policy
will be addressed. Offending behavior will not be permitted to continue or
45

Anti-harassment

be repeated. The manner in which violations are addressed will depend on
the circumstances. Employees could be subject to progressive discipline
up to and including immediate termination.  

II. Harassment Defined

Prohibited harassment may take many forms, from passing along cartoons to
actual physical violence. We provide the following examples of what may be
considered harassment.

Nonsexual harassment based on race, national origin, religion, marital status,
sexual orientation, gender identity, age, disability (or other protected status) can
include the following:
Displaying or circulating in any manner pictures, objects, or written
materials (including graffiti, cartoons, photographs, posters, pinups,
calendars, magazines, figurines, novelty items) that demean or show
hostility to a person because of the person's Protected Status
Verbal conduct, including making or using derogatory comments,
epithets, slurs and jokes towards such groups or individuals based on
Protected Status
Asking unwelcome questions or making unwelcome comments about
another person's Protected Status 

Sexual harassment is generally defined as unwelcome sexual advances,
requests for sexual favors, or other visual, verbal or physical conduct of a sexual
nature when:
Submission to such conduct is made either explicitly or implicitly a
term or condition of employment (such as promotion, training, overtime
assignment, leave of absence)
Submission to, or rejection of, such conduct affects employment
opportunities
The conduct interferes with an employee's work or creates an
intimidating, hostile or offensive work environment 

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Conducting all Port Business with Integrity and Respect

Sexual harassment includes harassment based on another person's gender,
gender identity, sexual orientation or harassment based upon pregnancy,
childbirth, or related medical conditions. It also can include harassment of
another employee who is the same gender as the harasser.

Examples of sexual harassment include, but are not limited to:
Offering or conditioning an employment benefit, like a raise, a promotion
or a special job assignment, in exchange for sexual favors
Threatening or taking a negative employment action (such as
termination, demotion, denial of a leave of absence), or changing
performance expectations, after an employee has turned down a sexual
advance
Unwelcome sexual advances, like requests for dates or propositions for
sexual favors
Excessive, one-sided, romantic attention in the form of requests for
dates, love letters, telephone calls, e-mails or gifts
Visual or physical conduct, like unwelcome staring, leering, making
sexual gestures, whistling
Displaying or circulating in any manner and/or through e-mail, voice
mail or other electronic means pictures, objects, or written materials
(including graffiti, cartoons, photographs, poster, pinups, calendars,
magazines, figurines, novelty items) that are sexually suggestive
Verbal conduct, like making or using derogatory comments, epithets,
slurs, teasing and jokes of a sexual nature
Graphic verbal or written comments (including e-mails or other
electronic documents) about an individual's sex life or body
Sexually degrading words used to describe an individual
Suggestive or obscene letters, e-mails, notes or invitations
Asking unwelcome questions or making unwelcome comments
about another person's sexual activities, dating, personal or intimate
relationships
Unwelcome intentional touching of another person or other unwanted
intentional physical contact (including patting, pinching, shoulder rubs,
brushing up against another person's body, or impeding or blocking
movements)
47

Anti-harassment

III. Your Responsibilities

The Port is committed to taking reasonable steps to prevent harassment from
occurring and will take immediate and appropriate action when it knows that
unlawful harassment has occurred. To do this, however, the Port needs the
cooperation of all employees at all levels. All Port employees are responsible for
keeping our work environment free of harassment.

IV. What to Do if You Suspect Harassment

Harassment, particularly sexual harassment, is often difficult to define.
Misconceptions abound and people tend to have different notions of what
is appropriate conduct and what is not. Employees should never tolerate
inappropriate behavior. The Port encourages employees who are uncomfortable
with an interaction to make their feelings known to the offending employee, if they
are comfortable doing so. If the behavior does not stop, or if the employee is not
comfortable with this approach, then the employee should immediately report
the concern to the Director of Human Resources and Development or anyone
identified in the "Reporting Concerns or Violations" policy.

Supervisors and managers will be held to a higher level of responsibility with
respect to reporting potential violations. Supervisors and managers who know of,
or receive, reports or complaints of offending behavior must promptly report them
to the Director of Human Resources and Development. See "Reporting Concerns
or Violations" policy for more detail.

V. The Port's Commitment to Investigate and Act

The Port will promptly and thoroughly investigate all claims of harassment.
Complaints will be handled with sensitivity, discretion and confidentiality to
the extent allowed by the circumstances and the law. Please see "Reporting
Concerns or Violations" policy for more detail.

If the Port concludes that unlawful harassment occurred, prompt and effective
remedial action will be taken. This may include discipline of the harasser and
48

Conducting all Port Business with Integrity and Respect

other actions to remedy the effects of the harassment and prevent further
harassment. No action will be taken against any employee who in good faith files
a complaint of harassment or assists in the investigation of such a complaint.

VI. No Retaliation

This policy is also violated if an employee is fired, denied a job, subjected to
negative performance feedback or denied some other employment benefit
because the employee in good faith complained about harassment, or assisted in
an investigation of harassment.

Employees who believe they have been retaliated against for having reported
harassment or participated in an investigation should promptly report it to
the Director of Human Resources and Development or anyone identified
in the "Reporting Concerns or Violations" policy so that such concerns can
be investigated. Supervisors and managers will be held to a higher level of
responsibility with respect to reporting potential retaliation. Supervisors and
managers who know of or receive reports of potential retaliation must promptly
report them to the Director of Human Resources and Development. See
"Reporting Concerns or Violations" policy for more detail.

Employees who are found to have engaged in retaliation could be subject
to progressive discipline up to and including immediate termination.  

For further information, please contact the Director of Human Resources and
Development.




49

Equal Opportunity

EQUAL OPPORTUNITY
Ensuring Non-Discrimination and Reasonable Accommodation
CC-9 as of 1/1/10
I. The Port's Commitment to Equal Employment Opportunity

The Port of Seattle is an equal employment opportunity employer. The Port
embraces, and in fact relies on, having a diverse workforce. Every employee
has the right to work in surroundings that are free from all forms of unlawful
employment discrimination. The Port will not engage in, or tolerate, any
discrimination in the workplace prohibited by local, state or federal law.
Specifically, no employee will be discriminated against on the basis of his or her
age, race, color, national origin/ancestry, religion, disability, Family Medical Leave
Act (FMLA) use, pregnancy, sex/gender, sexual orientation, whistleblower status,
marital status, military status, use of workers' compensation, transgender status,
political beliefs, or any other category protected by applicable federal, state or
local law ("Protected Status"). 

II. Reasonable Accommodation of Disabilities and Religion

The Port recognizes that employees with physical or mental disabilities may
need reasonable accommodations to enable them to perform their essential
job functions. The need for accommodations is determined on a case by case
basis. Generally the Port and the employee will work together in an interactive
process to identify possible accommodations. The employee has an obligation
to cooperate with the Port in this process, which may include authorizing the
Port to communicate with the employee's health care providers concerning
the employee's condition, its impact on the employee's ability to perform job
functions, and possible reasonable accommodations. Please see the Port's
Disability Management policy for more information.

The Port also generally will offer reasonable accommodation for an employee's
sincerely held religious belief that conflicts with a workplace rule, unless doing so
would create an undue hardship.
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Conducting all Port Business with Integrity and Respect

Employees who want to request accommodation of a disability or religious belief
should contact the Director of Human Resources and Development. The Port will
evaluate requests consistent with current legal requirements.

III. Commitment to Inclusion

The Port expects its employees to embrace a higher standard of nondiscrimination
and inclusion than simply not discriminating and harassing others
based on Protected Status. It expects all employees to be tolerant and accepting
of our individual differences, to avoid stereotyping others with whom we interact
both at the Port and in the broader community based on protected characteristics
and to treat others with respect. Disrespectful treatment by Port employees of
our customers or members of the public is not consistent with the Port's values
and will not be condoned.

IV. Reporting Concerns or Violations

All employees have a responsibility for ensuring that this policy is followed.
Concerns or potential violations should be reported to the Director of Human
Resources and Development, or anyone identified in the "Reporting Concerns
or Violations" policy, even if the alleged improper conduct happened to someone
else. Supervisors and managers will be held to a higher level of responsibility
with respect to reporting potential violations. Supervisors and managers who
know of or receive reports of potential violations must promptly report them to
the Director of Human Resources and Development. Employees will not be
retaliated against for reporting in good faith potential violations of this policy.
See "Reporting Concerns or Violations" policy for more detail.

For further information, please contact the Director of Human Resources and
Development.


51

Workplace Violence

WORKPLACE VIOLENCE
Promoting a Safe Work Environment
CC-10 as of 1/1/10
I. Workplace Threats and Violence Will Not Be Tolerated

The Port of Seattle is committed to maintaining a safe and efficient working
environment where employees and the public are free from the threat of violence.
The Port also supports a proactive approach in identifying potential threats and
preventing workplace violence.

The Port does not tolerate any type of workplace violence committed by or
against employees. Employees are prohibited from making threats or engaging
in violent activities. The following behavior, while not an exhaustive list, provides
examples of conduct that is prohibited.
Causing physical injury to another person
Making threatening remarks
Aggressive or hostile behavior that creates a reasonable fear of injury to
another person or subjects another individual to emotional distress
Intentionally damaging Port property or property of another employee
Possession of ammunition, a firearm, weapon or other item intended to
be used as a weapon on Port property or while on Port business, unless
specifically authorized in connection with the performance of Port duties
(i.e. law enforcement, wildlife management, and other like positions)
Committing acts motivated by, or related to, unlawful harassment or
domestic violence 

II. Duty to Report Dangerous Situations

Port employees should report any potentially dangerous situation immediately to
a supervisor or the Director of Human Resources and Development. While the
Port does not expect employees to be skilled at identifying potentially dangerous
persons, employees are expected to exercise good judgment and to inform
his or her supervisor or the Director of Human Resources and Development of
52

Conducting all Port Business with Integrity and Respect

coworker behavior which could cause concerns. Examples include:
Discussing ammunition, weapons, or violent activity in such a manner
that causes one to reasonably believe that the employee could pose a
risk to the workplace
Bringing weapons or ammunition into the workplace, unless specifically
authorized in connection with the performance of Port duties (i.e., law
enforcement, wildlife management, and other like positions)
Displaying overt signs of extreme stress, resentment, hostility or anger
Making threatening remarks
Sudden or significant deterioration of performance
Displaying irrational or inappropriate behavior 

Employees who have concerns about domestic violence (either their own
situation or a co-worker's situation) are urged to contact the Director of Human
Resources and Development so that HRD professionals can work with such
employees to evaluate risks and minimize risk to the workplace.

Employees who encounter a threatening person should not attempt to challenge
or disarm that individual. Employees should remain calm, keep constant eye
contact and talk to the individual. If a supervisor can be safely notified of the need
for assistance without endangering the safety of the employee or others, such
notice should be given. Alternatively, if possible, call 911.

III. The Port's Commitment to Investigate and Act

The Port will promptly and thoroughly investigate all reports of workplace
violence. Reports will be handled with sensitivity, discretion and confidentiality
to the extent allowed by the circumstances and the law. Please see "Reporting
Concerns or Violations" policy for more detail. Any employee determined to have
engaged in workplace violence will be subject to disciplinary action, up to and
including termination.

IV. Reporting Violations of This Policy

All employees have a responsibility for ensuring that this policy is followed.
53

Workplace Violence

Concerns or potential violations should be reported to the Director of Human
Resources and Development, or anyone identified in the "Reporting Concerns
or Violations" policy. Supervisors and managers will be held to a higher level
of responsibility with respect to reporting potential violations. Supervisors and
managers who know of or receive reports of potential violations must promptly
report them to the Director of Human Resources and Development. Employees
will not be retaliated against for reporting in good faith concerns or potential
violations of this policy. See "Reporting Concerns or Violations" policy for more
detail.

For further information, please contact the Director of Human Resources and
Development.












54

Conducting all Port Business with Integrity and Respect

SUBSTANCE ABUSE
Promoting Personal Health and Safety
CC-11 as of 1/1/10

I. Statement of the Policy

Use of alcohol or drugs is a serious threat to personal health, workplace safety
and job performance. Moreover, maintaining a drug-free workplace is essential
to the Port's ability to deliver quality work and service, to the Port's image with
customers and the public, and to the Port's ability to maintain federal funding for
Port projects.

Port of Seattle employees are strictly prohibited from possessing, selling, or
being under the influence of illegal drugs and misused prescription medications
or other controlled substances while on the job, during work hours, in
company vehicles or in any other manner that may affect the employee's work
performance or the Port's interests. Any employee who is taking a prescription
medication should determine from his or her physician or pharmacist whether
the prescription drug could impair his or her ability to perform the job safely
and effectively. If the employee's performance may be so impaired, he or she
should advise his or her supervisor so that reasonable accommodations can be
considered.

The Port may permit the moderate consumption of alcohol at Port-sponsored
events. Even when alcohol is available at such events, employees are expected
to conduct themselves in a professional manner and only consume moderate
amounts so that their behavior is appropriate and does not create a possible risk
to the health or safety of the employee or others nor a risk of harm to the Port's
interests.

Employees are strictly prohibited from being impaired by the use of alcohol while
on the job, during work hours, in company vehicles or in any other manner that
may affect the employee's work performance or the Port's interests.
55

Substance Abuse

Any employee experiencing difficulties with drugs or alcohol is encouraged to
contact the Port's Employee Assistance Program or Human Resources before
the drug or alcohol issue affects his/her work performance. Human Resources
and Development can provide referrals to helpful resources.

To ensure compliance with this policy, the Company may require drug and
alcohol testing at its discretion. This includes testing based upon reasonable
suspicion, where management personnel reasonably suspect that an employee
may be under any influence of drugs or alcohol, or is otherwise violating this
policy.

II. Reporting Concerns or Violations

All employees have a responsibility for ensuring that this policy is followed.
Employees should report to the Director of Human Resources and Development,
or anyone identified in the "Reporting Concerns or Violations" policy, potential
violations of this policy or any other situation in which you reasonably believe that
an employee's use of alcohol or drugs could be impacting the employee's ability
to safely do the job. See "Reporting Concerns or Violations" policy.

Supervisors and managers will be held to a higher level of responsibility with
respect to reporting potential violations and also with respect to identifying and
reporting situations in which an employee's use of alcohol or drugs could be
impacting the employee's ability to safely do the job. Supervisors and managers
who know of, or receive, reports of offending behavior must promptly report them
to the Director of Human Resources and Development. Employees will not be
retaliated against for reporting suspected violations of this policy. See "Reporting
Concerns or Violations" policy.

III. The Port's Commitment to Investigate and Act

The Port will promptly and thoroughly investigate all reports of violation of this
policy. Complaints will be handled with sensitivity, discretion and confidentiality
to the extent allowed by the circumstances and the law. Please see "Reporting
Concerns or Violations" policy for more detail. The Port will impose disciplinary
56

Conducting all Port Business with Integrity and Respect

action, up to an including termination of employment, in the event of any of the
following:
(1) Violation of this policy
(2) A positive test result
(3) Refusal or failure to submit to testing when requested to do so
(4) Refusal to cooperate in the testing process
(5) Adulteration of any sample or tampering with any part of the testing 
process
Test results are handled as confidential records, and provided only to those with
a need to know the information.

For further information, please contact the Director of Human Resources and
Development.











57

Employment of Relatives

EMPLOYMENT OF RELATIVES
Avoiding the Appearance of Favoritism
CC-12 as of 1/1/10

I. Statement of the Policy

The Port of Seattle believes it is in the Port's best interests to keep business
and professional relationships separate from personal and family relationships,
wherever possible. To prevent real or perceived conflicts of interest or favoritism,
the Port provides the following guidelines.

"Relative" is defined to include an employee or a consultant's spouse,
domestic partner, parents, children, cousins, nieces, nephews, grandparents,
grandchildren, in-laws, and any person with whom the employee or consultant
has a relationship that is substantially equivalent to any of the above. 

When there will be employment of an employee or consultant's Relative such
employment will only occur where:
Neither will supervise, appoint, remove or discipline the other
Neither will evaluate or audit the work of the other
The employment relationship will not create a conflict of interest or the
appearance of favoritism

When there will be an engagement of an employee or consultant's Relative as a
consultant, such engagement will only occur where:
Neither the employee nor consultant shall evaluate or audit the work of
the Relative and vice versa
Neither the employee nor the consultant shall approve of payment for
the Relative
The business relationship will not create a conflict of interest or the
appearance of favoritism

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Conducting all Port Business with Integrity and Respect

II. Candidates for Positions

Port employees and consultants should not be involved in any way with a
Relative's candidacy for employment. Even recommending a Relative for
employment could be perceived, or experienced, as undue pressure by the
hiring team. To make such a recommendation carries an inherent conflict of
interest. The higher level the position of the employee who recommends a
Relative for employment, the greater the risk of real or perceived pressure to
hire the Relative. Thus, an employee's failure to follow this policy could subject
an employee to discipline up to and including termination. A consultant's failure
to follow this policy could lead to termination of the consultant's business
engagement with the Port.

When a Relative of a Port employee is a candidate for a Port position, the
candidate shall be judged the same as other applicants, based on his/her
individual qualifications, without influence from Relatives who are already
employed. Any interference or influence exerted by a Port employee regarding
employment, compensation, or working conditions of his or her Relative could
disqualify the candidate from employment and could be considered a violation of
this policy.

The Port also reserves the right not to employ Relatives of high-level employees
of its competitors or major vendors where such a restriction is a reasonable step
towards avoiding the actuality or appearance of a conflict of interest or to protect
confidential information.

III. Employees Who Become Related

If two employees become related (typically by marriage or a relationship
substantially similar), and their continued employment might create a conflict
of interest or the appearance of favoritism, one of the employees may be
transferred to another open position consistent with the employee's skills,
change supervisory authority, or provided alternate assignments that remove the
potential for a conflict of interest. The Port reserves the right to terminate the

59

Employment of Relatives

employment of an employee if the Port concludes that it is the best approach
under the circumstances to avoid real or perceived conflicts of interest.

IV. Reporting Concerns or Violations

All employees have a responsibility for ensuring that this policy is followed.
Concerns or potential violations should be reported to the Director of Human
Resources and Development, or anyone identified in the "Reporting Concerns
or Violations" policy. Supervisors and managers will be held to a higher level
of responsibility with respect to reporting potential violations. Supervisors and
managers who know of or receive reports of potential violations must promptly
report them to the Director of Human Resources and Development. Employees
will not be retaliated against for reporting in good faith concerns or potential
violations of this policy. See "Reporting Concerns or Violations" policy for more
detail.

For further information, please contact the Director of Human Resources and
Development.









60

Conducting all Port Business with Integrity and Respect

POLITICAL ACTIVITIES
Responsible Personal Participation
CC-13 as of 1/1/10
I. Statement of the Policy

Employees are encouraged to take an active individual interest in political
activities provided that participation does not give the impression employees are
representing the Port.

Employees are encouraged to participate in the affairs of government. In doing
so, the following guidelines should be considered:
Employees should not use Port equipment or facilities for the benefit of
a political campaign.
Intelligent participation requires knowledge and understanding of
government, candidates, and issues. Employees are urged to become
informed through individual and group study.
Participation must be of the employee's own volition and on their own
time.
Personal beliefs should not be communicated in any manner that could
cause another to construe such beliefs as official Port endorsement of
any particular candidate or issue. 

Port employees are not obligated to endorse or contribute funds or time to
any Port Commission candidate. Port employees choosing to support a Port
Commission candidate must do so on their own time, using non-Port facilities
and equipment.

II. Reporting Concerns or Violations

All employees have a responsibility for ensuring that this policy is followed.
Concerns or potential violations should be reported to the Workplace
Responsibility Officer, or anyone identified in the "Reporting Concerns or
Violations" policy. Supervisors and managers will be held to a higher level of
61

Political Activities

responsibility with respect to reporting potential violations. Supervisors and
managers who know of or receive reports or complaints of potential violations
must promptly report them to the Workplace Responsibility Officer. Employees
will not be retaliated against for reporting in good faith concerns or potential
violations of this policy. See "Reporting Concerns or Violations" policy for more
detail.

For further information, please contact the Workplace Responsibility Officer.














62

Conducting all Port Business with Integrity and Respect

REPORTING CONCERNS OR VIOLATIONS
Ensuring Compliance with Workplace Responsibility Policies
CC-14 as of 1/1/10

I. Each Employee's Role In Compliance
The Port of Seattle is committed to reviewing concerns and investigating potential
violations of its Workplace Responsibility policies, as well as concerns that the
Port has engaged in improper governmental activity.
Port employees should report, without fear of retaliation, any matter which they
believe could constitute a violation of the Port's Workplace Responsibility policies
or other improper governmental activity. This policy outlines the steps that the
Port generally will take to review and investigate concerns and complaints. This
policy also sets forth the Port's commitment to ensuring that employees who
make reports in good faith, or who participate in investigations, do not experience
retaliation. This protection extends to employees who report concerns of alleged
improper governmental activity, commonly referred to as "whistleblowers."
Workplace Responsibility/Code of Conduct Policies:
Employee Ethics and Conflicts of Interest
Consultant Ethics and Conflicts of Interest
Former Employee Ethics and Conflicts of Interest
Gifts and Hospitality
Fraud Awareness and Prevention
Loss Prevention
Electronic Systems
Anti-Harassment
Equal Opportunity
Violence in the Workplace
Substance Abuse
Employment of Relatives
Political Activities
63

Reporting Concerns or Violations

II. Expectations of Supervisors and Managers

All employees have a responsibility for ensuring that each of the Workplace
Responsibility/Code of Conduct policies is followed. Supervisors and managers
will be held to a higher level of responsibility with respect to reporting potential
violations of the policies described above. Supervisors and managers who know
of or receive reports or complaints of offending behavior must promptly report.

III. How to Report

To report a concern or potential violation employees should contact any one of
the following:
Workplace Responsibility Officer
General Counsel
Director of Human Resources and Development
Ethics & Compliance Hotline: 1-877-571-5237, 24 hours a day, 
7 days a week 

An employee who reports his/her own improper action does not automatically
receive immunity from disciplinary action. However, the fact that an employee
voluntarily reports his or her own possible policy violations may be favorably
considered when evaluating disciplinary action.

IV. Confidentiality

Except as necessary to facilitate a thorough investigation, any person within the
Port receiving information about a concern or potential violation of a Workplace
Responsibility policy shall keep all information received as confidential as
possible. This includes the names of the persons involved and the nature of the
concerns or violations.

V. No Retaliation

No retaliatory action will be taken against any employee who in good faith
reports a concern or potential violation of a Workplace Responsibility policy, or
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Conducting all Port Business with Integrity and Respect

who assists in the investigation of one. The Port's commitment to non-retaliation
includes protection of those employees who report complaints of alleged
improper governmental activity, commonly referred to as "whistleblowers."

Employees are prohibited from using their official authority or position to prevent
or interfere with an employee reporting violations of Workplace Responsibility
policies.

Employees who believe they have been retaliated against for having made a
complaint or participated in an investigation must promptly notify any one of
the resources listed in Section III of this policy so that such concerns can be
investigated. Appropriate corrective measures will be taken if allegations of
retaliation are substantiated.

VI. The Investigation Process

The Port will promptly and thoroughly review all reported concerns and alleged
violations of its Workplace Responsibility policies. Reports will be handled
with sensitivity, discretion and confidentiality to the extent allowed by the
circumstances and the law. Generally this means that details are shared only
with those who have a need to know so that the Port can conduct an effective
investigation.

There may be a preliminary investigation to determine whether the concern or
allegation constitutes a potential policy violation, as a rational and legitimate
explanation may exist for the reported activity. If a full investigation is deemed
appropriate, decisions will be made about whether to conduct internally or by
retaining an outside investigator. The Port will conduct the investigation as swiftly
as feasible.

The reporting employee typically will be requested to provide relevant details,
such as the dates(s), location(s), names(s) of witnesses, or information about the
alleged improper actor(s)/action(s). Other persons with relevant information may
be interviewed as needed. During the investigation, steps may be taken, when
appropriate, to minimize contact between the reporting employee and the alleged
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Reporting Concerns or Violations

improper actor. In the case of harassment allegations, changes may include
schedule changes, temporary transfers or investigatory leave, usually for the
alleged harasser.

After the investigation is completed, the Port generally will discuss its findings
with the reporting employee, the alleged improper actor, and possibly others
directly concerned with the matter.

If the Port concludes that a policy violation occurred, prompt and effective
remedial action will be taken. This may include discipline of the improper actor(s)
and other actions to remedy the effects of the violation and to prevent further
violations.

The Port also will be responsible for fulfilling other statutory reporting
requirements that may be necessary, including those required by the Washington
State Auditor's Office.

For further information, please contact the Workplace Responsibility Officer.









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Conducting all Port Business with Integrity and Respect

THE WORKPLACE RESPONSIBILITY PROGRAM
The Port is committed to achieving a culture grounded in ethical behavior
and compliance, and has a designated Workplace Responsibility Officer who
has overall responsibility for ensuring the effectiveness of the Workplace
Responsibility Program. This program recognizes that most employees and
contractors want to perform effectively, do the right thing, and seek help in
uncertain situations. The Port will provide tools and training to assist them.

Compliance elements of the Workplace Responsibility Program include:

Clear Advice and Reporting Mechanisms. Employees should direct questions
and report potential violations of the Code of Conduct to any one of the following:
Workplace Responsibility Officer
General Counsel
Director of Human Resources and Development
Ethics & Compliance Hotline: 1-877-571-5237, 24 hours a day, 
7 days a week

Education and Training. Practical and effective training and education is
an essential facet of the Workplace Responsibility Program. Annual training
requirements will address clear guidelines and opportunities to have questions
answered.

Hiring and Promotion of Personnel who Embrace Compliance. The Port will
hire, promote and appropriately compensate employees and contractors who are
committed to and who foster a culture of compliance.

Employee Discipline. The Port does not tolerate unethical or inappropriate
behavior in its employees and contractors. There will be clear consequences for
inappropriate behaviors.

Auditing and Monitoring. The Workplace Responsibility Program will monitor
and audit its effectiveness on an ongoing basis.

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Workplace Responsibility 
Employee Handbook
January 2010

Ethics & Compliance Hotline:
1-877-571-5237
24 hrs / 7 days
Workplace Responsibility Officer
206-787-4930