An Information Ethic for All Information Professions

Paper presented at the North America- Computing and Philosophy Conference@ Carnegie Mellon University- Pittsburgh

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Abstract

Professional informing and information associations can be identified according to the functions of the professions they represent. The information professions address issues of content, interpretation, and transmission. These roles play an important role in the formulation and implementation of the codes of ethics as well as in their application to the management of the association and to the professional lives of their members.

That said; information professional association codes of ethics, as different as they are, can be abstracted to a more generalized synthetic, syncretic “meta-code.” This is possible because the underlying interests and concerns of the information professions have similar ends.

Introduction

Let us consider three major professional groupings concerned with the management of information in at least one respect – its content, its interpretation, or its transmission. Let us posit further that there is considerable overlap amongst the functions of these three professional groupings, but that there is also considerable difference among them. Moreover, within each of these three major groupings there are subgroups, each with considerably different functions and perspectives on their professional and social roles.

Because each of these different subgroups has different professional and social functions, their professional practices necessarily differ. For example, consider the four general information professions concerned with content: the librarian, the archivist, the records manager, and the museum curator. The librarian is chiefly concerned with making information available to a prescribed public, the archivist and the museum curator seek to preserve artifacts while guarding heritage, and the records manager strives to maintain access to specific information for a specific period of time for a specific audience. In the performance of their tasks, the librarian, the archivist, the records manager, and the curator may undertake similar tasks but often to different ends.

Or consider philosophical differences between the postal and telephone services on the one hand and cable delivered entertainment on the other. As a matter of social policy, universal telephone and postal service have been established as virtually an essential right in the United States over the past century. This ability to communicate has been seen as essential. This is certainly not the case with cable television, in part because there are alternatives (satellite reception) and in part because the right to be entertained is not yet fully established.

The computer science discipline incorporates a number of sub-disciplines, some of which have emerged fairly recently. According to the ACM (ACM, Computing Curricula 2001), these include:

These computer science applications carry in part or in all information content, transmission, and interpretative functions.

If we accept that there are at least three different information functions in society – transmission, content, and interpretation – and uncountable and overlapping sub-groupings within and among the three major groupings; is it unreasonable to suggest that any information ethic that might exist that addresses all three would be necessarily be ambiguous at best. Or can it be abstract and syncretic?

We recognize that information is created, transmitted, interpreted, stored, retrieved, reinterpreted, retransmitted, recreated, and so on. We are all involved in information processes at all times. There are very few entities if any that are purely concerned with the content or transmission or interpretation of information only. Almost all have some mix of concerns. Figure 1, a classical three-circle Venn diagram, suggests overlap in the abstract.

The oldest “industries” have tended to incorporate all three of the information functions. The storyteller not only transmitted his or her tale through the telling of the tale, s/he simultaneously interpreted it, and managed (in his or her head and in the heads of others) the content.

Today’s transmission industries are somewhat less concerned with content and interpretation, but they are very concerned with the quality, quantity, and efficiency of the movement and delivery of the message. These industries are those that move messages but often are unaware of the content of those messages. These include industries of long standing like the post, telegram and telegraph (PTTs), until very recently in most countries government monopolies; private teamster services like Railway Express, UPS, and the various cartage companies; more recently private courier services like Federal Express; and now the Internet with its several communications aspects like e-mail, telnet and the World Wide Web. With certain key exceptions, these transmission media do not concern themselves with the content of the message they carry, they concern themselves with the quality of the service by which they carry the message. Thus, the ethical implications information theory as defined by Claude Shannon for telephony has equal play in the elimination of “transmission noise” for other “similar” professions.

We tend to confuse transmission industries with the hybrid transfusion industries. There are, of course, significant exceptions to this particularly where there are overlaps in function. The television and radio industry cannot be conceived as a purely transmission industry because they play an integral role in the creation and interpretation of the material they distribute. These industries are concerned on a variety of grounds – some economic and some social and moral – with the content, with the message contained in the product they transmit.

Perhaps radio and television broadcasters are required to be more sensitive to the content of their transmissions because they use a publicly owned and publicly accessible resource, the airways. Other movers of goods and services have traditionally been less constrained in what they move but more concerned in how they move what they move. Not to put too fine a point on it, the form the information transmission takes dictates its quality control. Removing “Shannonesque” noise from an electronic transmission differs significantly in a technical sense from developing transportation routing plans for package delivery, but both seek to improve the efficiency in the movement of the message. And neither is concerned with the content of the message.

We have long had government and private sector service providers moving artifacts of one sort or another. Postal and cartage services have been with us for centuries. In recent decades, a number of companies have emerged that compete with the post offices as well as traditional cartage companies. These include FedEx, UPS, and others. These latter companies have been extremely innovative in reducing “shipping noise.” FedEx founder Fred Smith is purported to have said that information about the package is as important as the package itself. Maintaining that chain of information represents an ethical principle for that company and other successful competitors.

The ethics codes for professions related to the moving of people tend to stress safety over other factors (see for example the Code of Ethics of the Airline Pilots Association http://www.alpa.org/alpa/DesktopModules/ViewDocument.aspx?DocumentID=181). Codes of ethics for government employees tend to emphasize behaviors that may result in conflicts of interest or the appearance of the potential for the conflict of interest by those employees in the fulfillment of their official functions (see for example the code of ethics of the New Jersey Department of Transportation at http://www.state.nj.us/lps/ethics/dotcode.pdf).

Content is defined in very complex ways. The contents organizations concern themselves not only with the ideas or concepts contained within books, journals, and other artifacts, but with the artifacts themselves. As a result, content organizations include a wide range of institutions, among which are libraries, archives, museums, and records management facilities.

By definition the “working purposes” of these organizations differ. They differ in part by the type of artifact collected but also in terms of the use to which the artifact is put. Libraries, archives, and records management facilities bear a superficial similarity to one another and employ many of the same procedures and applications in their work. Yet their basic principles in content/artifact management are fundamentally quite different and these differences are reflected in codes of ethics. According the Society of American Archivists:

Archivists select, preserve, and make available documentary materials of long-term value that have lasting value to the organization or public that the archivist serves. Archivists perform their responsibilities in accordance with statutory authorization or institutional policy. They subscribe to a code of ethics based on sound archival principles and promote institutional and professional observance of these ethical and archival standards. http://www.archivists.org/governance/handbook/app_ethics.asp

The American Library Association’s Code of Ethics is a very broad and sweeping statements of principle. Contrast this code with that of the Colegio de Bibliotecarios de Chile. The Chilean Code is very detailed, in part because the Colegio de Bibliotecarios regulates the profession. And the Chilean código de ética serves in part as “statute.”

Or again consider the differences between the Code of Ethical Business Practice of the Association of Independent Information Professionals and the ALA Code of Ethics. The AIIP has narrower aims than the ALA and these narrower aims are reflected in the code. The AIIP code is no less ethical, it has a different focus. Its focus is different in part because it has as part of its orientation for-profit considerations that the non-profits are less concerned.

Museums have generally a different orientation and so too do their codes of ethics. Museums collect and display artifacts for their cultural and educational value. They perceive their role in a wider perspective, often one with a trusteeship or stewardship function (see for example the Canadian Museums Association - http://www.museums.ca/ethics/ethicstoc.htm) and with a responsibility toward cultural preservation and maintenance. Museums collect with a predisposition against disposition.

Yet, contrast all of these with the Association of Records Managers and Administrators Code of Professional Responsibility that defines the profession as that which is “…responsible for managing the creation, use, maintenance, and disposition [emphasis added] of records generated in the normal functioning of all types of organizations.” http://www.arma.org///publications/ethics.cfm. By and large, information professionals do not have as part of their professional charge the disposition of information, but that is an important aspect for the records manager.

Interpretation

The interpretative groups cover a very wide range of industries and individuals and include artists, journalists, scholars, and everyone else who uses information for almost any purpose. Despite the apparent wide variation of the interpretive fields, their codes of ethics are remarkably similar. Several examples follow when reduced to their essentials.

The Code of Ethics of the Society of Professional Journalists is deontological in nature (http://www.spj.org/ethics_code.asp). It recognizes the interpretative role of journalists and defines "[t] he duty of the journalist ... to further those ends by seeking truth and providing a fair and comprehensive account of events and issues." The Radio Television News Directors Association of Canada defines the first function of journalism as that of to inform the public (http://www.cbsc.ca/english/codes/rtnda.htm). This is done in a fair, balanced, and non-sensationalized way. Similarly, the code of ethics of the International Association of Business Communicators (http://www.iabc.com/members/joining/code.htm) demands fair and balanced communications in part because of the import of the message but also because of the need to provide fair and balanced service to their patron base.

And finally, the American Association of University Professors Statement on Professional Ethics (http://www.aaup.org/statements/Redbook/Rbethics.htm) carries a recognition of the need to communicate the truth as it is understood, a position taken by all other professions that filter and interpret data and that produce information and knowledge.

Transmission, Interpretation, and Content

It is suggested above that the computer science professions, when taken as a whole, share the three primary information profession functions of transmission, interpretation, and content. The ACM Code of Ethics is provided in Appendix I. This code has three major components: section one, general moral imperatives, section two, more specific professional responsibilities, and section three, organizational leadership imperatives. Section four addresses adherence to the code.

The first section contains elements found in most codes of ethics. It calls upon its membership to act positively and at the same time to do no harm. Positive action includes:

Conclusions

This brief exploration of codes of ethics of various information professions suggests wide variation in approaches and provision. Nevertheless, is it possible to abstract the codes sufficiently across types and professions to achieve a syncretic as well as synthetic code of ethics across information professions (see Koehler and Pemberton 2000 for just such an attempt for the library professions)? A second question might be, is it useful to try to identify such a syncretic, synthetic code?

To answer the second question first, the value lies in finding the commonalities, the threads that cohere the information professions and their underlying value structures. If indeed we can demonstrate that professionals in one region share similar values (Koehler et al 2000), perhaps the information professions also share at least a number of values as well. That would suggest that despite different functions, from a value perspective the information professions are not so different from one another as it might first appear. Librarians and archivists can share a concern for the safety of their patrons just as those in the transport or transmission industries can equally concerned with appropriate service for their customers. Safety and service may be defined and provided in somewhat different ways, but it is safety and service nevertheless.

The first question is at the same time both more simple and more complex than the second. These codes of ethics can be abstracted to a point of meaninglessness. Nearly all information professions codes of ethics call upon practitioners to provide good service. Yet good service for one profession may be in fact poor service in another. In developing a syncretic code, we are not so concerned with specific behaviors, but rather with a set of abstract behaviors or behaviors that conform to normative professional guides as defined by each profession. Thus, our concern is not with specific behaviors but rather with “meta-behaviors.”

In an examination of information professions ethics codes therefore, we find a general but not a specific parallelism in their provisions. Information professionals are expected and directed to provide appropriate service in an appropriate environment to their clients in a timely manner, in whatever way those services, environments, and timetables are defined by each of the professions. As service, environment, delivery schedules, and other variables are differentiated among the information professions so are their specific ethical expectations. The syncrenism, if indeed that is a word, that has emerged lies not in the detail (the place of the devil we are told), but perhaps in the sense of duty, of deontology that information professionals of all kinds bring to the delivery of their services and skills. We can draw closing conclusions from the Canons of Ethics of the Society of Broadcast Engineers (http://www.sbe.org/pdf/canon.pdf), a deontological code: “the [practitioner] will cooperate in extending the effectiveness of the … profession by interchanging information and experience … .” The practitioner is further charged to uphold the character of the profession and to avoid questionable practices. They are to “…strive to be fair, tolerant, and open minded.” Sufficiently abstracted, these are goals information professionals of all stripes can aspire to.

Michael Pemberton and I (Koehler and Pemberton 2000: 39) offer a syncretic code based on an analysis of national library association codes of ethics:

ACM, Computing Curricula 2001. Available: http://www.computer.org/education/cc2001/final/chapter03.htm

Koehler, Wallace 2002. "The Organizations that Represent Information Professionals: Form, Function, and Professional Ethics" in Barbara Rockenbach and Tom Mendina, eds., Ethics and Electronic Information: A Festschrift for Stephen Almagno. Jefferson, NC: McFarland: 59-73.

Koehler, Wallace and J. Michael Pemberton. 2000. "A Search for Core Values: Towards a Model Code of Ethics for Information Professionals," Journal of Information Ethics 9, 1: 26-54.

Koehler, Wallace, Jitka Hurych, Wanda Dole, and Joanna Wall, "Ethical Values of Information and Library Professionals -- An Expanded Analysis." International Information & Library Review, 32 (3/4) 2000: 485-506.

Lester, June and Wallace Koehler. 2003. Fundamentals of Information Studies: Understanding Information and Its Environment. NY: Neal-Schuman.

Pallier, Denis. 1961. Les Bibliothèques. Paris: Presses Universitaires de France

1. GENERAL MORAL IMPERATIVES.

This principle concerning the quality of life of all people affirms an obligation to protect fundamental human rights and to respect the diversity of all cultures. An essential aim of computing professionals is to minimize negative consequences of computing systems, including threats to health and safety. When designing or implementing systems, computing professionals must attempt to ensure that the products of their efforts will be used in socially responsible ways, will meet social needs, and will avoid harmful effects to health and welfare.

In addition to a safe social environment, human well-being includes a safe natural environment. Therefore, computing professionals who design and develop systems must be alert to, and make others aware of, any potential damage to the local or global environment.

"Harm" means injury or negative consequences, such as undesirable loss of information, loss of property, property damage, or unwanted environmental impacts. This principle prohibits use of computing technology in ways that result in harm to any of the following: users, the general public, employees, employers. Harmful actions include intentional destruction or modification of files and programs leading to serious loss of resources or unnecessary expenditure of human resources such as the time and effort required to purge systems of "computer viruses."

Well-intended actions, including those that accomplish assigned duties, may lead to harm unexpectedly. In such an event the responsible person or persons are obligated to undo or mitigate the negative consequences as much as possible. One way to avoid unintentional harm is to carefully consider potential impacts on all those affected by decisions made during design and implementation.

To minimize the possibility of indirectly harming others, computing professionals must minimize malfunctions by following generally accepted standards for system design and testing. Furthermore, it is often necessary to assess the social consequences of systems to project the likelihood of any serious harm to others. If system features are misrepresented to users, coworkers, or supervisors, the individual computing professional is responsible for any resulting injury.

In the work environment the computing professional has the additional obligation to report any signs of system dangers that might result in serious personal or social damage. If one's superiors do not act to curtail or mitigate such dangers, it may be necessary to "blow the whistle" to help correct the problem or reduce the risk. However, capricious or misguided reporting of violations can, itself, be harmful. Before reporting violations, all relevant aspects of the incident must be thoroughly assessed. In particular, the assessment of risk and responsibility must be credible. It is suggested that advice be sought from other computing professionals. See principle 2.5 regarding thorough evaluations.

Honesty is an essential component of trust. Without trust an organization cannot function effectively. The honest computing professional will not make deliberately false or deceptive claims about a system or system design, but will instead provide full disclosure of all pertinent system limitations and problems.

A computer professional has a duty to be honest about his or her own qualifications, and about any circumstances that might lead to conflicts of interest.

Membership in volunteer organizations such as ACM may at times place individuals in situations where their statements or actions could be interpreted as carrying the "weight" of a larger group of professionals. An ACM member will exercise care to not misrepresent ACM or positions and policies of ACM or any ACM units.

The values of equality, tolerance, respect for others, and the principles of equal justice govern this imperative. Discrimination on the basis of race, sex, religion, age, disability, national origin, or other such factors is an explicit violation of ACM policy and will not be tolerated.

Inequities between different groups of people may result from the use or misuse of information and technology. In a fair society, all individuals would have equal opportunity to participate in, or benefit from, the use of computer resources regardless of race, sex, religion, age, disability, national origin or other such similar factors. However, these ideals do not justify unauthorized use of computer resources nor do they provide an adequate basis for violation of any other ethical imperatives of this code.

Violation of copyrights, patents, trade secrets and the terms of license agreements is prohibited by law in most circumstances. Even when software is not so protected, such violations are contrary to professional behavior. Copies of software should be made only with proper authorization. Unauthorized duplication of materials must not be condoned.

Computing professionals are obligated to protect the integrity of intellectual property. Specifically, one must not take credit for other's ideas or work, even in cases where the work has not been explicitly protected by copyright, patent, etc.

Computing and communication technology enables the collection and exchange of personal information on a scale unprecedented in the history of civilization. Thus there is increased potential for violating the privacy of individuals and groups. It is the responsibility of professionals to maintain the privacy and integrity of data describing individuals. This includes taking precautions to ensure the accuracy of data, as well as protecting it from unauthorized access or accidental disclosure to inappropriate individuals. Furthermore, procedures must be established to allow individuals to review their records and correct inaccuracies.

This imperative implies that only the necessary amount of personal information be collected in a system, that retention and disposal periods for that information be clearly defined and enforced, and that personal information gathered for a specific purpose not be used for other purposes without consent of the individual(s). These principles apply to electronic communications, including electronic mail, and prohibit procedures that capture or monitor electronic user data, including messages,without the permission of users or bona fide authorization related to system operation and maintenance. User data observed during the normal duties of system operation and maintenance must be treated with strictest confidentiality, except in cases where it is evidence for the violation of law, organizational regulations, or this Code. In these cases, the nature or contents of that information must be disclosed only to proper authorities.

The principle of honesty extends to issues of confidentiality of information whenever one has made an explicit promise to honor confidentiality or, implicitly, when private information not directly related to the performance of one's duties becomes available. The ethical concern is to respect all obligations of confidentiality to employers, clients, and users unless discharged from such obligations by requirements of the law or other principles of this Code.

2. MORE SPECIFIC PROFESSIONAL RESPONSIBILITIES.

2.1 Strive to achieve the highest quality, effectiveness and dignity in both the process and products of professional work.

Excellence is perhaps the most important obligation of a professional. The computing professional must strive to achieve quality and to be cognizant of the serious negative consequences that may result from poor quality in a system.

Excellence depends on individuals who take responsibility for acquiring and maintaining professional competence. A professional must participate in setting standards for appropriate levels of competence, and strive to achieve those standards. Upgrading technical knowledge and competence can be achieved in several ways:doing independent study; attending seminars, conferences, or courses; and being involved in professional organizations.

ACM members must obey existing local, state, province, national, and international laws unless there is a compelling ethical basis not to do so. Policies and procedures of the organizations in which one participates must also be obeyed. But compliance must be balanced with the recognition that sometimes existing laws and rules may be immoral or inappropriate and, therefore, must be challenged. Violation of a law or regulation may be ethical when that law or rule has inadequate moral basis or when it conflicts with another law judged to be more important. If one decides to violate a law or rule because it is viewed as unethical, or for any other reason, one must fully accept responsibility for one's actions and for the consequences.

Quality professional work, especially in the computing profession, depends on professional reviewing and critiquing. Whenever appropriate, individual members should seek and utilize peer review as well as provide critical review of the work of others.

2.5 Give comprehensive and thorough evaluations of computer systems and their impacts, including analysis of possible risks.

Computer professionals must strive to be perceptive, thorough, and objective when evaluating, recommending, and presenting system descriptions and alternatives. Computer professionals are in a position of special trust, and therefore have a special responsibility to provide objective, credible evaluations to employers, clients, users, and the public. When providing evaluations the professional must also identify any relevant conflicts of interest, as stated in imperative 1.3.

As noted in the discussion of principle 1.2 on avoiding harm, any signs of danger from systems must be reported to those who have opportunity and/or responsibility to resolve them. See the guidelines for imperative 1.2 for more details concerning harm,including the reporting of professional violations.

Honoring one's commitments is a matter of integrity and honesty.For the computer professional this includes ensuring that system elements perform as intended. Also, when one contracts for work with another party, one has an obligation to keep that party properly informed about progress toward completing that work.

A computing professional has a responsibility to request a change in any assignment that he or she feels cannot be completed as defined. Only after serious consideration and with full disclosure of risks and concerns to the employer or client, should one accept the assignment. The major underlying principle here is the obligation to accept personal accountability for professional work. On some occasions other ethical principles may take greater priority.

A judgment that a specific assignment should not be performed may not be accepted. Having clearly identified one's concerns and reasons for that judgment, but failing to procure a change in that assignment, one may yet be obligated, by contract or by law, to proceed as directed. The computing professional's ethical judgment should be the final guide in deciding whether or not to proceed. Regardless of the decision, one must accept the responsibility for the consequences.

However, performing assignments "against one's own judgment" does not relieve the professional of responsibility for any negative consequences.

Computing professionals have a responsibility to share technical knowledge with the public by encouraging understanding of computing, including the impacts of computer systems and their limitations. This imperative implies an obligation to counter any false views related to computing.

2.8 Access computing and communication resources only when authorized to do so.

Theft or destruction of tangible and electronic property is prohibited by imperative 1.2 - "Avoid harm to others." Trespassing and unauthorized use of a computer or communication system is addressed by this imperative. Trespassing includes accessing communication networks and computer systems, or accounts and/or files associated with those systems, without explicit authorization to do so. Individuals and organizations have the right to restrict access to their systems so long as they do not violate the discrimination principle (see 1.4). No one should enter or use another's computer system, software, or data files without permission. One must always have appropriate approval before using system resources, including communication ports, file space, other system peripherals, and computer time.

3. ORGANIZATIONAL LEADERSHIP IMPERATIVES.

BACKGROUND NOTE:This section draws extensively from the draft IFIP Code of Ethics,especially its sections on organizational ethics and international concerns. The ethical obligations of organizations tend to be neglected in most codes of professional conduct, perhaps because these codes are written from the perspective of the individual member. This dilemma is addressed by stating these imperatives from the perspective of the organizational leader. In this context"leader" is viewed as any organizational member who has leadership or educational responsibilities. These imperatives generally may apply to organizations as well as their leaders. In this context"organizations" are corporations, government agencies,and other "employers," as well as volunteer professional organizations.

3.1 Articulate social responsibilities of members of an organizational unit and encourage full acceptance of those responsibilities.

Because organizations of all kinds have impacts on the public, they must accept responsibilities to society. Organizational procedures and attitudes oriented toward quality and the welfare of society will reduce harm to members of the public, thereby serving public interest and fulfilling social responsibility. Therefore,organizational leaders must encourage full participation in meeting social responsibilities as well as quality performance.

3.2 Manage personnel and resources to design and build information systems that enhance the quality of working life.

Organizational leaders are responsible for ensuring that computer systems enhance, not degrade, the quality of working life. When implementing a computer system, organizations must consider the personal and professional development, physical safety, and human dignity of all workers. Appropriate human-computer ergonomic standards should be considered in system design and in the workplace.

3.3 Acknowledge and support proper and authorized uses of an organization's computing and communication resources.

Because computer systems can become tools to harm as well as to benefit an organization, the leadership has the responsibility to clearly define appropriate and inappropriate uses of organizational computing resources. While the number and scope of such rules should be minimal, they should be fully enforced when established.

3.4 Ensure that users and those who will be affected by a system have their needs clearly articulated during the assessment and design of requirements; later the system must be validated to meet requirements.

Current system users, potential users and other persons whose lives may be affected by a system must have their needs assessed and incorporated in the statement of requirements. System validation should ensure compliance with those requirements.

3.5 Articulate and support policies that protect the dignity of users and others affected by a computing system.

Designing or implementing systems that deliberately or inadvertently demean individuals or groups is ethically unacceptable. Computer professionals who are in decision making positions should verify that systems are designed and implemented to protect personal privacy and enhance personal dignity.

3.6 Create opportunities for members of the organization to learn the principles and limitations of computer systems.

This complements the imperative on public understanding (2.7). Educational opportunities are essential to facilitate optimal participation of all organizational members. Opportunities must be available to all members to help them improve their knowledge and skills in computing, including courses that familiarize them with the consequences and limitations of particular types of systems.In particular, professionals must be made aware of the dangers of building systems around oversimplified models, the improbability of anticipating and designing for every possible operating condition, and other issues related to the complexity of this profession.

4. COMPLIANCE WITH THE CODE.

The future of the computing profession depends on both technical and ethical excellence. Not only is it important for ACM computing professionals to adhere to the principles expressed in this Code, each member should encourage and support adherence by other members.

4.2 Treat violations of this code as inconsistent with membership in the ACM.

Adherence of professionals to a code of ethics is largely a voluntary matter. However, if a member does not follow this code by engaging in gross misconduct, membership in ACM may be terminated.

This Code and the supplemental Guidelines were developed by the Task Force for the Revision of the ACM Code of Ethics and Professional Conduct: Ronald E. Anderson, Chair, Gerald Engel, Donald Gotterbarn, Grace C. Hertlein, Alex Hoffman, Bruce Jawer, Deborah G. Johnson, Doris K. Lidtke, Joyce Currie Little, Dianne Martin, Donn B. Parker, Judith A. Perrolle, and Richard S. Rosenberg. The Task Force was organized by ACM/SIGCAS and funding was provided by the ACM SIG Discretionary Fund. This Code and the supplemental Guidelines were adopted by the ACM Council on October 16, 1992.

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