Compliance Procedures
Ratified by the ANS Board of Trustees June 16, 2012.
American Numismatic Society
Compliance Procedures
The American Numismatic Society (“ANS” or the “Society”) does not knowingly or willfully acquire, purchase, or exhibit numismatic materials in contravention of any applicable state, foreign, or federal law or regulation. The Society recognizes its responsibilities as a non-profit institution dedicated to the service of the public to maintain the highest ethical standards. The Society has adopted a code of ethics and is in compliance with it and all applicable laws and regulations. The acquisition of stolen, illegally imported, or illegally exported numismatic materials is in direct opposition to the mission and purpose of the ANS. The Society shall periodically review its collections for any numismatic materials whose provenance is incomplete or uncertain. The Society shall make serious efforts to allocate adequate funding to conduct provenance research on such items.
The Society expects its Trustees, the Executive Director, professional staff, employees, and volunteers to abide by principles set forth in the Collections Management Policy (the “Policy”) in furtherance of the Society’s mission. The Society shall distribute written copies of the Policy and Compliance Procedures to Trustees, the Executive Director, professional staff, employees, and volunteers, who shall certify in writing that they received and reviewed the documents. They shall also annually certify in writing that they will adhere to the Policy and Compliance Procedures and acknowledge that failure to abide by the Policy and Compliance Procedures may result in disciplinary action including possible termination from ANS. The Society shall train its Trustees, the Executive Director, professional staff, employees, and volunteers on the Policy, Compliance Procedures, and any new and current applicable laws on an annual basis, and shall obtain from each individual a signed, written acknowledgment that such training occurred.
The Society seeks to discourage, prevent, and detect any wrongdoing. Any Trustee, professional staff member, employee, or volunteer shall report any suspicions of wrongdoing, related but not limited to the acquisition, purchase, possession, or transfer of stolen, illegally imported, or illegally exported numismatic materials, to the Executive Director or the Board of Trustees. The Society shall take such claims seriously and shall vigorously investigate and research the alleged wrongdoing. Such investigations shall be conducted by impartial, responsible actors, and shall not be conducted by any individual involved in the alleged wrongful acts. If the allegations warrant additional action, the Board of Trustees may employ outsiders to investigate. The Board of Trustees or a subcommittee designated by the Board of Trustees shall oversee such investigations. If the claim is substantiated, the Society shall pursue an appropriate course of action congruent with the mission and best interests of the Society, including restitution when warranted. Any wrongdoing is a negative reflection on the ANS, its mission, and its reputation, and with this principle in mind, in the absence of any mitigating circumstances, the Society shall voluntarily report such wrongdoing to the proper enforcement authorities. The Society may also voluntarily submit any and all materials relating to such wrongdoing to the proper authorities, if doing so would be in the best interests of the Society.