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================================================= Ethics Today Online Published
by the Ethics Resource Center =======================================================
**************************************************************************** The past year seems to have flown by. It was September 2002 when Ethics Today moved from print to electronic format. Some of us - like me - were romantically attached to the idea of a paper document, but our ability to provide the most current information with almost instantaneous transmission was just too attractive. All of us at the Ethics Resource Center have been gratified by the response to the new format and content. This was corroborated by the responses to our July survey. I was especially struck by the diversity of our readers -- from compliance officers to college professors, from corporate senior executives to journalists. The sectors represented were just as diverse, including individuals from all segments of our society: accounting, education, information technology, law, government and non-profits. The wide range of topics covered evidently resonated with those individuals concerned about ethics. More than 50% of respondents were very interested in business ethics, character education, codes of ethics, corporate social responsibility, global ethics, government, and professional ethics. We are obviously "hitting home" with our selection of topics. Readers responded positively, as well, to the decision by staff to focus on particular issue areas of ethics within each issue. Our features, guest columns, "Ask the Expert" and theme related articles appear to be the most popular. The article lengths and focus seem to be just about right, as is the monthly format. Some found the publication a bit too long, and we will adjust that in future additions. Interestingly, most readers didn't care when we sent the electronic version out. Most importantly, readers were far more interested in the content than format and timing. The number of individuals receiving and downloading Ethics Today has increased exponentially. In July, almost 2900 copies were sent via email and more than 1750 visitors accessed the current issue of Ethics Today on the website. It is a reminder of how important the issue of ethics is in today's world. We appreciate all of your feedback that will help to ensure the continued quality of our publication. Stuart C. Gilman, President During our first year online, Ethics Today published the following essays by ERC President Stuart Gilman in his president's column:
Read these previous "Words from
the President" at: ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ ** Building Ethics Institutions and Ethics Capacity in Developing Countries The ERC seeks to build organizational ethics and good governance capacity in developing countries as a means of advancing their economic and social development. Since 1995, the ERC has assisted local ethics institutions to develop the necessary capacity and technical expertise to provide a wide range of business and organizational ethics resources, services and products to their communities. The growing network includes:
The ERC's approach to providing technical assistance to international partners is guided by the following principles: 1) Local ownership of the ethics agenda. We seek out committed local partners and assist them in surfacing their own cultural values in emulating internationally accepted standards of organizational ethics and good governance. 2) Coalition building. A successful and sustainable ethics agenda typically requires active support by a broadly based coalition of stakeholders from a number of sectors (government, business, civil society). This is particularly true of developing nations where the level of development of individual sectors puts constraints on their ability to undertake independent, sector-based reform oriented initiatives. 3) A focus on local capacity building. The ERC typically engages in accelerated local capacity building using a proprietary catalog of train-the-trainer curricula to prepare local consultants in the delivery of customized training programs in:
In the rest of this fact sheet, Director of International Programs Alex Zalami describes the process by which the ERC determines the feasibility and long-term viability for ethics centers abroad, and how it helps them transition to operational and financial independence. Read the rest of this article at: ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ In addition to reporting generally on the Centers' goals and accomplishments, Ethics Today asked Ethics Center directors to comment on the ethics environment in their country and the impact of their center on the ethical climate. ** Ethics Institute of South Africa (EthicSA) EthicSA and staff have appeared numerous times in the national print, radio and television media, delivered more than 30 presentations at conferences and workshops, and published dozens of articles, reports and other materials. The website, due to be revised this month, contains numerous resources, including a hefty number of articles and citations to references in the area of bio-medical ethics. EthicSA also publishes a twice-weekly e-mail based newsletter pertaining to national and international business events. The Center has recently completed Business Ethics South Africa (BESA) 2002: Corporate Ethics Indicator, based on a survey designed with the assistance of ERC Senior Researcher Joshua Joseph, that provides South Africa with a national benchmark for corporate ethics governance and management initiatives. The full report, which includes ethics management best practices, will be available for purchase from EthicSA. Get a PDF copy of the Condensed Research
Report at: ERC's Principal Consultant Frank Navran visited the Center in March and April 2003, assisting with the development of business ethics management consulting proposals, providing in-house training and capacity building, fine-tuning the BESA survey and the Center's new membership plan and providing other expertise. About the state of ethics in South Africa, CEO Willem A. Landman says: "It is impossible to address this question adequately in a few sentences, but some indicators stand out. The publication of the King II Report in 2002, a benchmark corporate governance document, set the tone for corporations and other organizations to operate ethically. A whole industry has developed in its wake. EthicSA is one of the most prominent players in respect to ethics management support, with the King Committee having given us special recognition in a number of ways. The problem is how to match capacity with overwhelming demand! EthicSA's business ethics survey (BESA 2002) is the first comprehensive initiative to benchmark business ethics in corporations in South Africa, based on King II and the US Federal Sentencing Guidelines for Organizations (FSGO) (1991) as standard-setting documents." "Anticorruption agencies and initiatives have multiplied and there is truly a new focus on eradicating fraud and corruption in South Africa. There is complete commitment to this from the Presidency. EthicSA has been involved in several anticorruption workshops to help ensure that commitments translate into practice." About the future, Mr. Landman writes: "EthicSA will be launching its organizational membership plan in September. Organizations will be able to join EthicSA, with EthicSA providing ethics support and monitoring services in return for commitments to verifiable ethics management initiatives by organizations and the payment of an annual fee. We are determined that this plan will put organizational ethics in South Africa on a new level." Read more about the Ethics Institute
of South Africa at:
TEDMER was launched in January 2003 in an event that also highlighted the Turkish Survey on Business Ethics, adapted for Turkey from the ERC's 2000 National Business Ethics Survey. Since then, the center has worked toward establishing and improving relationships with a number of other ethics organizations, including university ethics clubs and non-governmental organizations (NGO's). Managing Director Necati Guler made a presentation at the National Congress of Medical Ethics in June 2003, and Frank Navran spoke to and conducted workshops for university ethics clubs during his visit to the center in May 2003. Also during that visit, Frank started the training for TEDMER's "Ethics Officer Certificate Program" which will continue during his visit next month. Get a PDF copy of the Turkish National
Business Ethics Survey at: TEDMER is also developing "Ethics Volunteers" working groups, a quarterly ethics magazine and an "Ethics Bowl" for university ethics clubs, as well as planning an international conference on business and political ethics. With the technical assistance of Frank Navran, the center is also preparing an "Ethics Leaders Program". Managing Director Necati Guler writes: "Although a very short period of time has passed since the launch of TEDMER, there has been a substantial increase in awareness on issues related to ethics. Through different media, TEDMER is trying to spread the message that 'ethical business is good business'. Our Ethics Officer Certificate Program that we started with the great contribution from ERC has received a lot of coverage. This has made quite a few companies and institutions take the matter more seriously. "Along with TEDMER, a couple of other NGO's are very much involved with the efforts to spread ethics and integrity as well as stopping corruption and the Government just passed a decree to fight corruption. There is also a law now being considered to establish an 'Ethics Committee for all Public Sector and Government Officials'. I believe, as long as it is correctly and fairly passed at the Parliament, this is a big step towards an ethical society." As for the future, Mr. Guler says: "In addition to our Ethics Officer Program, we plan to have an Ethics Leader Program which will enable us to get the heads of the organizations involved as well. Since we plan to make our members have a board member who deals specifically with ethics issues in the company, such a program will be a very important element for progress in our local environment." Read more about the Turkish Ethical
Values Center at:
Transparencia por Colombia adapted an ERC-designed methodology for larger companies that allows enterprises to orient their decision-making process and employee behavior towards ethical standards. They developed another methodology for small and middle enterprises, which has spread through trade unions, universities and small and middle enterprises' associations. Transparencia por Colombia also worked on the introduction of Integrity Pacts to help government, businesses and civil society groups fight corruption in the field of public contracting. Under an Integrity Pact, bidders competing for the supply of goods and services provide a binding assurance that they have not paid any bribes in order to obtain this contract and that they will not do so in the future. The Integrity Pacts were designed by Transparency International and were adapted by the Colombian chapter to the conditions of the country. Forty Integrity Pacts have been signed by 254 domestic and 48 international firms. In addition, more than 600 public servants in loyalty and management positions have signed Ethical Declarations. Transparencia has worked with students at 10 universities to make them reflect on the application of ethical values to specific realities they experience first hand. During a March visit to the Center, ERC Principal Consultant Frank Navran spoke to a group of 300 university students on the subject of social responsibility and ethics and how they are relevant in Latin America, and Colombia in particular. During that visit, Frank also engaged in staff training on a wide range of ethics issues, including the role, responsibilities and population of an ethics office and an ethics committee (EC), investigations, confidentiality / anonymity issues, data gathering and reporting and interface with senior executives and boards. Transparencia por Colombia has developed an "Integrity Index for Public Institutions" designed to help monitor the evolution of corruption and integrity in the country. The Index is published annually and measures the performance of the main public institutions in areas such as transparency, control and punishment, and efficiency and institutionality. Read the press release for the 2002
report at: About the ethics environment in Colombia, communications director Diana Suarez says: "Despite having in the country a forward-looking legislation and a favorable institutional framework towards integrity, the situation regarding corruption is still worrying:
Read more about Transparencia por Colombia
(Spanish language only) at:
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ ** Ethics and Corruption at Home and Abroad: The Urgency of Building an Integrity Culture On June 22, 2003, Frank Vogl, President of Vogl Communications and ERC Board member, spoke to the Goodwill Delegate Assembly 2003 at the Annual Meeting of Goodwill Industries International Inc. His presentation discussed the need for all organizations to redouble good governance efforts, especially in light of the U.S. corporate scandals. "At the core of organizational good governance is the building of an integrity culture," he said. "The leaders of every organization must not just have a meaningful institutional code of ethics, but a plan to ensure they are seen across their organizations as ethical role models. Their pro-active stance, backed by superb ethics-directed communications and employee training, ensure that an ethical culture is built and sustained. Organizations that fail to assign the highest priority to this challenge will lose their reputations in due course. They will fail." Mr. Vogl, one of the 12 founders of Transparency International who received the ERC's 2000 Pace Award, also discussed at length the issue of international corruption and payment of bribes and facilitation payments by U.S. and other firms. On the positive side, he said, "There is ample evidence that organizations with a very strong ethical culture can impress people overseas with their firm adherence to basic values. Organizations can enter a country and tell official and business counterparts immediately and directly - we don't pay bribes. We are here for the longer-term. We are here to act as good citizens. We are here to work with you to the benefit of your people. We can bring our experience and knowledge to your needs - but we do not pay bribes." He concluded with a discussion of "pragmatic ethics management", in which he laid out a seven-point checklist of key actions that will help an organization grow in strength. Read the full text of his speech at: ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ ** Good Governance Efforts by Donor Agencies Jerry O'Brien, Democracy Specialist for USAID and former Director of International Programs at ERC, spoke in April 2003 at the Annual Conference of the International Consortium on Governmental Financial Management which met under the title "Reducing Poverty and Corruption: An Integrated Approach to Good Governance". His remarks on "Good Governance Efforts by Donor Agencies" focused on the ways in which USAID promotes good governance and democracy in the field and how the agency works with host countries to institute good governance at the national and local levels through programmatic activity. During his speech, O'Brien considered the links between governance and development and between governance and democracy. He stated that while democracy is not in itself a guarantee of good governance, it creates the political space within which to fight for good governance. "The view that poor governance and corruption are the key impediment to development has been steadily gaining adherents in the development and foreign policy fields for some time now", he continued, citing the Administration's planned Millennium Challenge Account and the programs supported by USAID to help host countries improve governance. Read the text of this presentation
at: ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ **Book Review: Varieties of Ethical Reflection: New Directions for Ethics in a Global Context According to ERC Programs Manger Jerry Brown, while the anthology "Varieties of Ethical Reflection" presents some cultural and religious information often missed in studies in the United States, it concentrates more on Asian philosophical sources and lacks the truly global perspective promised in the title. "Individual articles stand out and have weight and value," he notes in his review. Although limited in range, he says, "The book is a starting place for better understanding of ethics from a global perspective." Read the rest of this review at: ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ ** Press Release: Boost Ethics Education and Training for Young People "Corporate leaders and business schools need to strengthen their focus on youth," said national ethics experts gathered in Washington DC for the July 2003 ERC Fellows meeting. According to the August 5 press release, "Ethics education and training for young people by corporations and business schools is essential for the future of business integrity" Fellows Program Chairman Stephen Potts, former Director of the US Office of Government Ethics, said, "Too many corporate leaders are failing to pay adequate attention to ethics training for young people in the American workforce. At the same time, many business schools are failing today to provide tomorrow's generation of corporate leaders with the ethics education vital for the health of American business." Read the full press release at: ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ ** ERC Fellows Discuss Role Modeling, Ethics Effectiveness Other topics discussed at the Fellows meeting, which took place July 23-25, include Ethical Role Modeling in Business, Examining the Effectiveness of Ethics Programs, and Challenges for Global Business Ethics. Guest Knight Kiplinger, editor in chief of The Kiplinger Letter, Kiplinger's Personal Finance Magazine and KiplingerForecasts.com, gave the keynote address and led the discussion on perspectives and issues in organizational ethics. The Fellows also agreed to consider the following issues for potential future projects:
Read more about the ERC Fellows Program
at: ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ ** The Enron Effect: Ethics in the Workplace On July 22, ERC President Stuart Gilman delivered a live webcast on "The Enron Effect: Ethics in the Workplace" as part of a series of free seminars offered by PlaceWare, a subsidiary of Microsoft, and covering business topics from top organizational leaders. The webcast was taped and can be heard on the Web by following the instructions below. In his presentation, Stuart states that, for the average American worker, the ethical climate in the workplace has improved, and backs up his words with findings from the ERC's National Business Ethics Survey 2003. As a result of "The Enron Effect", he explains, employees are more positive about ethics in their own workplace, leaders and organizations are more proactive and leaders understand that ethics is not an abstract concept, but a critical part of a healthy company. Other topics include:
The latter part of his presentation deals with continuing areas of concern, such as the reluctance of certain groups of employees to report observed misconduct -- and the reasons that they do not do so. He also notes that transitioning organizations and smaller organizations may be more vulnerable. Listen to the recorded audio and watch
the presentation's synchronized slides at: Please note: You will be asked to register with your name before viewing the webinar. You may also need to install Real Audio player or Windows Media Player. Or read the PowerPoint presentation
in PDF, without the accompanying lecture, at: Please note: You will need Acrobat Reader to view this presentation. ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ ** Ask the Expert: How Do Globalization and the U.S. Corporate Scandals Affect Ethics? Instead of posing just one question, ET prints a couple of questions and answers from Principal Consultant Frank Navran's response to an email interview with a Turkish journalist following his latest visit to the country. In this month's Ask the Expert, Frank responds to the following questions:
Read the answers at: ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ Corporate Codes of Ethics and Sarbanes-Oxley The July 2003 issue of Wall Street Lawyer featured an article co-authored by ERC Principal Consultant Frank Navran and Edward L. Pittman, who is an attorney with the firm of Thelen Reid & Priest. The article gives an overview of codes of ethics and the issues to consider in implementing the spirit and the letter of the new ethics disclosure rules written pursuant to Section 406 of the Sarbanes-Oxley Act. The co-authors answer a number of code-related questions, including:
They conclude by emphasizing the importance of an effective overall ethics program and addressing the role of the Board of Directors. A sidebar entitled "Directors' Guide to Assessing an Ethical Culture" is included. Read "Specific Points for a Director
to Examine In Determining The Effectiveness Of An Ethics Program",
on which the Director's Guide was based, at: Read more about the requirements imposed
by Sarbanes-Oxley on Thelen Reid & Priest's web page on Corporate
Governance, Public Company Disclosure and Accounting Reforms at: Get more information about Wall Street
Lawyer, a subscription publication, at: ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ ** Chairman of the Board Ken Frazier's Term Extended The ERC Board of Directors has extended for one year the term of Kenneth C. Frazier as chairman of the ERC Board of Directors. Mr. Frazier, Senior Vice President and General Counsel at Merck & Co., Inc., has been a member of the ERC Board since 2000 and is currently serving as Chairman of the Board. Mr. Frazier is a graduate of Pennsylvania State University and of Harvard Law School. After receiving his J.D., he joined the Philadelphia office of the firm of Drinker, Biddle & Reath, where he remained for 14 years and became a partner in the Litigation Department. In 1992 he left private practice to become Vice President, General Counsel, and Secretary of Astra/Merck Group. In 1994 he was named Vice President for Public Affairs of the parent company, Merck & Co., Inc. He took on the additional responsibilities of Assistant General Counsel in 1997, and in 1999 he became Vice President and Deputy General Counsel. Later in the same year he assumed his present position as Merck's Senior Vice President and General Counsel, based at company headquarters in Whitehouse Station, New Jersey. Mr. Frazier is a founding board member of the Cornerstone Christian Academy, a private elementary school in Philadelphia, where many of the students are high-risk children. In 1999, he and his wife Andrea established a scholarship in Liberal Arts at Penn State for students whose ethnic, cultural, or national background contribute to the diversity of the student body. This year, he underwrote 10 scholarship subscriptions of MAXIMize the Moment, the ERC's online character education resource tool, donating one to the Academy and offering others to schools in need around the country. In addition to serving on the ERC and Cornerstone Boards, Mr. Frazier is a member of the Board of Legal Services of New Jersey, and on the Advisory Boards of CorporateProBono.Org, National Legal Aid and Defender Association, University of Pennsylvania's Law & Economic Center, Seton Hall University's Health Law & Policy Center, and The Rand Institute for Civil Justice. He is a member of the American Law Institute, American Bar Association, Association of General Counsel, Council on Foreign Relations, and Pennsylvania Bar Association. The ERC staff joins in extending our gratitude to Mr. Frazier for his tireless leadership. ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ ** The Results are In: Reader Survey and Opinion Poll In July, in lieu of our monthly opinion poll, we asked that readers take a short survey concerning the format, content and delivery of Ethics Today Online. We appreciate the responses of all who participated and will use them to guide us as we develop the editorial and strategic plans for Ethics Today Online Volume 2. Also in July, we extended the June opinion poll in which we asked if, during the past year, you had personally observed conduct that you thought violated the law or your organization's standards of ethical business conduct and, if so, did you report it? The results:
See the results of last month's poll
at: Our regular opinion poll feature will return in the September 2003 issue. ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ ** Online Index to Ethics Today to Debut in September We are putting the finishing touches on an index to all of the articles that appeared in Ethics Today Online between our first issue in September 2002 and this final issue of the editorial year. The index, which will be published online by the first week in September, lists items according to the same four major categories used in our online resource section: Organizational Ethics, Character Education, Global Ethics and Integrity, and General Ethics topics. Articles will also be indexed by sub-categories and keywords. Look for announcements about the Ethics
Today Online Index and other new features at: ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ ** Publications and Media Coverage -- The July/August 2003 issue of the Conference Board's "Across the Board" magazine contained two articles by persons related to the ERC: - "Are You Serious
About Ethics?" by Patrick J. Gnazzo and former ERC Fellow George
R. Wratney, discusses the issue of confidentiality as it relates
to ethics programs. Employees who seek to raise issues but are timid
or fearful want more than a conditional assurance of confidentiality,
say the authors. However, unlike many relationships that have limited
privileges, for instance attorney-client or doctor-patient, no law
covers the relationship between ethics or compliance officers and
employees. They cite recent ERC survey findings that many employees
who observe misconduct decide not to report it -- and that their
reasons include fear of retribution or retaliation, lack of trust
that the organization will keep the report confidential, and concerns
about being labeled whistleblowers. The authors advance the idea
of organizational ombudsman programs as a solution, and discuss
a number of situations in which it can be employed successfully.
- ERC Board Member Frank Vogl was also published in the July 2003 issue of "Across the Board". In his opinion piece, entitled "The Return of the Ugly American", he discusses the impact of the recent U.S. corporate scandals on the rise in anti-Americanism, with consequences for the U.S. economy, international trade, investment and the position of U.S. business in the world. The resulting damage includes foreign investors avoiding U.S. stock markets because they doubt the honest of corporate balance sheets, overseas holders of U.S. dollars losing confidence and selling the currency in exchange for euros, antitrust regulators at the European Union's Commission deciding against U.S. corporations, and foreign governments resisting U.S. demands for more free trade and investment liberalization. To turn the tide, says Mr. Vogl, "CEO's ... need to condemn the compensation greed, the tax-evasion habits, and the 'business as usual' approaches to audit committees". They must then build coalitions of business leaders "dedicated to placing integrity back at the core of corporate culture." (This article is not available online.)
-- ERC President Stuart Gilman is quoted extensively in an August 10 Courtland Milloy column in the Washington Post on the ethical condition of the District of Columbia government. In "The District Must Redefine Its Morality", Stuart emphasizes that, by and large, the people in the DC government are "decent and hardworking and want to do the right thing." They are trapped, he says, "in an antiquated system that encourages them and their staffs to do the wrong thing because it's so hard to get things done and hire the highest quality people and provide them with the best training." It is not the obvious areas of unethical behavior -- such as using a government credit card to buy personal items -- that indicate the real problem, according to Stuart, who also teaches ethics at the Center for Excellence in Municipal Management at George Washington University. Rather, the problem is "believing it's okay because 'I'm going to pay it back'. It's still a conflict of interest." Once you lose the trust of the citizens, he says, it becomes nearly impossible to govern. Read the column at: http://www.washingtonpost.com/wp-dyn/articles/A39492-2003Aug9.html
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ ** News from the ERC -- ERC President Stuart Gilman participated
in a BNA-sponsored audio conference along with Jacqueline B. Gates,
President and CEO of SOARing, LLC, and former ethics officer for
the World Bank Group. "Trends in Workplace Ethics", which
took place live on July 17, considered questions in three major
areas:
Stuart has been asked to present the
NBES 2003 findings in a number of different formats and arenas.
One fairly comprehensive version of his presentation is available
through the Placeware archive at:
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ ** Offering Our Thanks As a non-profit organization, the Ethics Resource Center depends on contributions from many generous donors. Without their dedication and trust, many of the programs and projects highlighted in this newsletter would not be possible. The ERC thanks the following for their contributions of general support:
We invite you to join our loyal contributors
in lending your support. To find out how to contribute or to donate
online, go to: ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ The Ethics Resource Center (ERC) is a non-profit, non-partisan educational organization exempt from taxation under the Section 501(c)(3) of the Internal Revenue Code. All gifts are tax-deductible to the fullest extent of the law. ======================================================= Copyright (c) 2003 Ethics Resource
Center. All rights reserved. Please contact ethics@ethics.org for information about reproducing any of the information contained within this newsletter or on our web site. Back issues of Ethics Today are available online at: /today/et_archives.html The Ethics Resource Center, 1747 Pennsylvania
Ave., NW, Suite 400
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