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Corporate standards & expectations manual

You can hover over the circles below to view an abbreviated version of the Corporate Standards & Expectations.

Click the image above to view the entire Corporate Standards & Expectations Manual.

If you have questions on any of the standards or expectations, please feel free to reach out to the BBNC Compliance Department at compliance.bbnc.net.

Accounting 

Accounting

Department Head: Yuliya Mitchell, Vice President & Corporate Controller Standards, procedures and written controls help to prevent and detect unethical conduct.

Subsidiary Expectations

  • Design, implement, and maintain programs and controls to prevent, deter, and detect fraud
  • Design, implement, and maintain internal controls relevant to the preparation and fair presentation of the financial statements compliant with the General Accepted Accounting Principles (GAAP) and applicable federal and state laws, regulations, and industry standards
  • Adopt sound accounting policies
  • Maintain records, documentation, and information relevant to the preparation and fair presentation of the financial statements
  • Provide unrestricted access and the full cooperation of personnel to assist with internal and external audits
  • Provide requested information to BBNC as needed throughout the year
  • Timely and accurately report operating results to BBNC
  • Comply with the applicable , including the Revenue Recognition Policy-Fixed Contracts Policy
  • Assist with implementation of BBNC Finance Strategic Plan

Administration 

Administration

Department Head: Inez Bielefeld, Administrative Manager

Subsidiary Expectations

  • Submit Committee Meeting Materials in a timely manner
  • Communicate requests to travel to the BBNC Building

Communications 

Communications

Department Head: Carmell Engebretson, Communications Manager

Subsidiary Expectations

  • Properly describe and represent BBNC in all subsidiary marketing material, ensuring BBNC’s brand guidelines are followed when using BBNC’s logo or other assets.
  • Provide articles or subsidiary updates to be used in BBNC’s shareholder newsletter to BBNC’s Communications team each quarter or when appropriate.
  • Maintain a professional website that is updated regularly and reflects accurate information related to BBNC and provide BBNC with updates to subsidiary information that is needed on BBNC’s corporate website.
  • Provide BBNC’s Communications team with photography related to subsidiary work and industries that has proper licensing and permissions to be used in subsidiary and corporate brand material.
  • Read, understand, and comply with the Holding and Subsidiary Company Brand Guidelines in all material and websites. Reach out to BBNC’s Communications team for assistance when needed, or to make exceptions to the guidelines for special projects.
  • Consult the Quick Glance Brand Guidelines when using BBNC brand assets or describing BBNC in materials. The Quick Glance Brand Guidelines are specific to BBNC’s brand and do not apply to subsidiary-branded material unless BBNC is being described or logo/brand assets are being used.

Compliance 

Compliance

Department Head: Renee Wardlaw, Senior Director of Corporate Compliance & Associate General Counsel

Subsidiary Expectations

  • Adhere to the BBNC Code of Ethics and distribute documented standards that are easily accessible to applicable personnel.
  • Create a properly scoped Compliance and Ethics program with various levels of oversight by knowledgeable individuals, including a dedicated and experienced employee (i.e., Compliance Liaison) with sufficient authority to oversee the program.
  • Educate employees on relevant laws, regulations, and policies, so that appropriate conduct in the workplace reduces the probability of unethical conduct.
  • Ensure that executive and senior leadership model and reward high ethical behavior by delegating authority, hiring, and promoting others with a proven record of high character.
  • Review business activity to detect workplace concerns via internal resources and an anonymous communication channel and help identify areas or topics requiring additional monitoring or education.
  • Perform effective checks and balances to discourage unethical conduct while rewarding those who demonstrate ethical behavior.
  • Adhere to the Internal Reports & Investigations Policy and promote a corporate culture where incidents, allegations, reports and suspicions of potential misconduct and violations of law, regulations, and written standards are properly reported, reviewed, investigated, and resolved by appropriately qualified and trained investigators.
  • Establish a standard process to review contracts before execution, obtain proper approvals at the time of execution and track and store contracts after execution.
  • Comply with the Export Compliance Policy.
  • Establish a standard process to collect and analyze potential and actual conflicts of interests and disclose potential or actual unethical/illegal business practices.
    Create one central, cross-functional repository for policies, procedures, guidelines, etc.
  • Communicate new and revised policies to applicable parties (employees, independent contractors, vendors, etc.)
  • Implement and distribute a policy development process
  • Share the BBNC Code of Ethics and Business Conduct

Corporate Development

Corporate Development

Department Head: Nancy Schierhorn, Executive Vice President & Chief Corporate Development Officer

Subsidiary Expectations

  • Develop a strategic growth plan
  • Identify unique business, operating, regulatory, and industry characteristics relevant to its strategic growth plan
  • Source and evaluate potential transactions and investment opportunities
  • Integrate acquisitions with BBNC

Education Foundation 

Education Foundation

Department Head: Aleesha Towns-Bain, Executive Director

Subsidiary Expectations

  • Familiarize themselves with the Education Foundation

Finance & Treasury 

Finance & Treasury

Department Head: Ryan York, Executive Vice President & Chief Financial Officer

Subsidiary Expectations

  • Comply with the Subsidiary Dividend Policy
  • Complete weekly accounts payable and payroll file totals
  • Reconcile month-end cash balance of Central Treasury
  • Reconcile all commercial cards
  • Complete and distribute quarterly representation letters
  • Complete and distribute quarterly financial compliance certificate data
  • Provide immediate notification of any potential or actual fraud

Human Resources 

Human Resources

Department Head: Tony Brothers, Vice President, Human Resources

Subsidiary Expectations

  • Create and distribute compliant Employee Handbooks to applicable employees
  • Ensure adequate and timely compensation (e.g., bonus, profit sharing, 401k, LTI) to recruit and retain talented employees who are trained to fulfill their role
  • Optimize the employee onboarding experience
  • Promote employee recognition to build and maintain a highly engaged workforce.
  • Drive Diversity, Equity and Inclusion efforts to attract and retain a dynamic and diverse workforce

Information Technology 

Information Technology

Department Head: RC Woodson, Vice President, IT & Chief Information Officer

Subsidiary Expectations

  • Ensure adequate and appropriate data privacy and security to protect against unauthorized disclosure.
  • Manage various IT networks
  • Provide technical support and assistance to employees
  • Support and advise on IT applicable development
  • Provide strategic innovation and support to leadership
  • Develop, implement, test and periodically update a disaster recovery business continuity plan, including identification of when to escalate to Corporat

Land & Natural Resources 

Land and Natural Resources

Department Head: Daniel Cheyette, Vice President, Land and Natural Resources

Subsidiary Expectations

  • Be passionate about the Bristol Bay region, its landscapes, fisheries and people
  • Celebrate and share Bristol Bay culture, language and heritage
  • Understand BBNC’s Fish First Value and Responsible Resource Development Policy
  • Support, as appropriate, in-region infrastructure, energy and broadband project

Legal 

Legal

Department Head: Ethan Schutt, Executive Vice President & General Counsel

Subsidiary Expectations

  • Obtain and use qualified and experienced legal support and advice for subsidiary leadership and operations to protect the reputation of BBNC’s brand and its family of companies, minimize legal risk and exposure, and reduce costs
  • Perform corporate governance (registration and maintenance) of non-Alaska based entities/jurisdictions
  • Manage litigation and customer/vendor demands, including bond claims and FOIA requests, except employment matters
  • Provide monthly updates and prompt notification to BBNC Legal and Risk Management Departments of matters in compliance with the subsidiary Operating Agreement and as requested to ensure timely updates to BBNC’s Corporate Executive Leadership, BBNC’s Board of Directors and KPMG
  • Register and maintain intellectual property: trademarks, copyrights, and patents; protect confidential information and trade secrets

Operations

Operations

Department Head: Scott Torrison, Executive Vice President & Chief Operating Officer

Subsidiary Expectations

  • Comply with Entity Formation and Management Policy , Foreign Work Approval Policy, Joint Ventures and MPA Approvals , Contracting Compliance Policy , and Bonding and Surety Policy
  • Comply with Primary and Secondary NAICS revenue management
  • If the subsidiary business line contains 8(a)entities, must comply with all applicable laws and regulations (i.e., SBA 8(a) Business Development Program)
  • Adhere to subsidiary Operating Agreement

Records & Information Management 

Records & Information Management

Department Head: Nellie Phillips, Records & Information Manager

Subsidiary Expectations

  • Adhere to the RIM Policy and Records Retention Schedule
  • Secure, organize and maintain records and information required for active business use for efficient access
  • Transfer records out of active file areas that are no longer needed for active business use (typically after one year of inactivity)
  • Classify inactive records (hard-copy or electronic data) to capture the record type, records details and record dates to apply appropriate retention period.
  • Store, organize and label inactive records (onsite or with an offsite vendor) to ensure proper safeguard and separation of records for efficient access and retrieval when needed.
  • Retrieve inactive records promptly for business use (i.e., discovery, litigation).
  • With the approval of the BBNC Records and Information Manager, destroy inactive records that have met the retention period and are not subject to a document hold

Risk / Safety / Internal Audit 

Risk / Safety / Internal Audit

Department Head: William Gornto, Senior Vice President, Corporate Risk Management

Subsidiary Expectations

  • Identify and assess business and operational risks, including natural disasters, leadership gaps, physical security, cybersecurity, regulatory changes and other matters
  • Prioritize, manage, mitigate and report to risks
  • Develop, implement, test and periodically update a crisis management plan, including identification of when to escalate to Corporate
  • Develop, administer and enforce a safety program and culture based on industry standards that promotes a safe and healthy work environment for employees, and compliance with local, state and federal requirements. A safety program and culture includes training, prevention, accountability, accurate health/safety metrics, claim/case management, near miss reporting and a culture of no fear of blame.
  • Provide monthly updates and prompt notification to BBNC Legal and Risk Management Departments of litigation matters in compliance with the subsidiary Operating Agreement
  • Respond to BBNC requests for insurance renewal information.
  • Provide suggested areas for audit to the Corporate Internal Audit Work Plan with suggested projects
  • Participate in Corporate Internal Audit, when applicable.
  • Administer claims that are not subject to insurance or litigation, in accordance with the subsidiary Operating Agreement

Shareholder & Corporate Relations 

Shareholder & Corporate Relations

Department Head: Andria Agli, Vice President, Shareholder & Corporate Relations

Subsidiary Expectations

  • Become familiar with the services and benefits provided to BBNC shareholders and their families through the SCR department.
  • Participate in shareholder or corporate events when appropriate.
  • Utilize the SCR department to engage with BBNC shareholders, descendants and Bristol Bay communities.
  • Become familiar with BBNC, the Bristol Bay region, people, and cultures.

Shareholder Development 

Shareholder Development

Department Head: Carol Wren, Vice President, Shareholder Development

Subsidiary Expectations

  • Adhere to the Shareholder Hire Preference Policy: BBNC grants an employment preference first, to BBNC shareholders, their spouses or descendants, and second, to Alaska Natives, who meet the qualifications of the position.
  • Develop a business line shareholder development plan: This plan is tailored to the business line workforce needs and opportunities and outlines concrete goals that the business line intends to implement towards providing outreach, hiring, developing, advancing and retaining shareholders.
  • Provide a Quarterly Report, typically delivered at the appropriate Committee Meeting, memorializing the activities accomplished from the business line shareholder development plan

Tax 

Tax

Department Head: Kristy West, Senior Vice President, Tax

Subsidiary Expectations

  • Understand tax obligations applicable in each of the jurisdictions in which it operates.
  • Register for and maintain tax accounts associated with indirect tax filings in each jurisdiction.
  • Prepare, file, collect and remit indirect or transactional taxes where access to detailed books and records is necessary to determine tax obligations. Examples of indirect tax include, but are not limited to, payroll, sales, excise, gross receipts and property taxes.
  • Provide requested information required for financial statement tax reporting, estimated tax calculations and tax return compliance as needed throughout the year.
  • Maintain a fixed asset depreciation system to include tax method depreciation schedules as needed for tax return compliance.

Accounting 

Policies

Standards, procedures and written controls help to prevent and detect unethical conduct.

Best Practices

  • Create one central, cross-functional repository for policies, procedures, guidelines, etc.
  • Communicate new and revised policies to applicable parties (employees, independent contractors, vendors, etc.)
  • Implement and distribute a policy development process
  • Share the BBNC Code of Ethics and Business Conduct

Governing Authority

Board of Directors
Executive Leadership  

A Compliance and Ethics Program Structure creates various levels of oversight by knowledgeable individuals to ensure that applicable policies and written standards of control are followed.

Best Practices

  • Define the scope of your industry-specific, risk-based compliance program
  • Document your Compliance & Ethics Program strategic plan and obtain leadership approval
  • Identify dedicated compliance personnel or personnel who accomplish Compliance & Ethics Program functions
  • Create a compliance and ethics budget

Standards & Expectations  

Accounting  
Administration  
Communications
Compliance  
Education on relevant laws, regulations, and policies so that expected conduct in the workplace reduces the probability of unethical conduct.

Best Practices

Training:
  • Offer training in multiple formats (electronic, live, interactive)
  • Track training completion
  • Measure employee satisfaction with training
  • Document the effectiveness of training (i.e., is there a reduction in risk because people are trained)
Education (Content):
  • Complete Annual Compliance & Ethics Training
  • Identify and complete industry-specific training (mandated by industry, regulations or legislation)
  • Identify and complete training that supports employee development and aligns with strategic goals
  • Provide training on new and revised policies, as requested or needed
Communication:
  • Communicate compliance events (policies, training, initiatives, industry changes)
  • Offer communication in multiple formats (email, website, intranet, newsletter)

Corporate Development

Education Foundation 
Finance & Treasury  
Human Resources  
Information Technology  
Land and Natural Resources 
Legal

Culture of Integrity

Duty to ensure that senior leadership models and rewards high ethical behavior by delegating authority, hiring, and promoting others with a proven record of high character.

Best Practices

  • Send Executive and Senior Leadership to the Annual Leadership & Compliance Conference
  • Promote a Speak Up, Speak Out culture
  • Reinforce the importance of compliance and ethics and obtain leadership support
  • Define specific compliance and ethics expectations
  • Assess employee perception of culture using culture surveys
  • Work with key stakeholders to remediate cultural issues

Operations

Records & Information Management  
Risk / Safety / Internal Audit  
Shareholder & Corporate Relations  
Shareholder Development  
Tax   

Monitoring, Auditing & Reporting

Continuous and routine review of business activity allows issues to be identified early on and remedied quickly. Open lines of communication increase early detection of issues and help identify areas or topics that require additional monitoring or education.

Best Practices

Monitoring:
  • Conduct wellness checks (via telephone, video call, or live) to promote a culture of integrity and appreciate employees who demonstrate ethical behavior
  • Maintain a database of applicable laws and regulations and track changes, as needed
  • If red flags appear, report the issue using the established reporting mechanism
Auditing:
  • Collaborate with the Internal Audit function to ensure that the compliance program meets industry standards
Reporting:
  • Maintain an anonymous hotline for employees to report misconduct
  • Create multiple channels for employees to report misconduct
  • Communicate the importance of speaking up and protections (i.e., no retaliation, anonymous reporting) for employees who report misconduct
  • Solicit employee feedback regarding reporting mechanisms