IMA Code of Ethics

Code of Business Conduct for Members of the Incentive Marketing Association and Procedures for Review of Member Conduct


IMA, the Incentive Marketing Association (Association), is a not-for-profit 501(c)(6) trade association formed to promote, develop, educate, and otherwise further the field of incentive marketing. IMA’s membership consists of organizations and individuals engaged in providing goods and services for incentive buyers and suppliers.

The business and affairs of the Incentive Marketing Association are managed under the direction of the IMA Board of Directors (Board). The Board is responsible for furthering IMA’s Mission to promote "high standards of professionalism in the incentive field.” To accomplish this objective, the Board has identified and endorsed a "Code of Business Conduct” for Members of the Incentive Marketing Association” (Code).

IMA acknowledges that each Member may have formal policies that serve as a mandatory code of conduct for their organizations. The IMA Code is not designed to supersede any Member organizations’ code of ethics or business conduct guidelines.

IMA also acknowledges that in today’s business climate, organizations face conflict of interest and ethical dilemmas on a regular basis. To this point, IMA ‘s Code will serve as a barometer to help Association Members resolve these challenges.

The following IMA Code sets forth and advocates best practices in dealing with customers, business associates, and competitors.

Code of Conduct for Members of the Incentive Marketing Association

Applicants for IMA Membership and Members of IMA recognize that IMA provides a platform for education, corporate outreach, professionalism, and new business opportunities. Members of IMA, acknowledge that IMA does not deal with competition among its members and within the scope of their authority, accept this code and agree to abide by it.

  1. IMA members shall support the purpose and goals of IMA. 
  2. IMA members will promote the incentive marketplace and the Association in a credible manner. 
  3. IMA members will not discriminate due to race, color, religion, national origin, gender, sexual orientation, or marital status. 
  4. IMA members will conduct business in a fashion which does not purposely create conflict between attention to profit and attention to ethics. 
  5. IMA members will maintain and provide accurate representation of products and services and shall not intentionally misinform or mislead a client or business associates relative to their ability to deliver a product, program or service. 
  6. IMA members will not discredit or disparage products, programs, or services of competitors by providing inaccurate or confidential information or by making derogatory remarks about fellow suppliers or their products.
  7. IMA members will uphold business commitments in a timely fashion.

Procedures for Review of Member Conduct


  1. IMA’s Code of Conduct serves as a recommended model of business conduct for Members of the Association.
  2. Members affirm their knowledge and endorsement of the Code and acknowledge their commitment to uphold its principles by accepting and retaining membership in the Incentive Marketing Association.
  3. By providing this "Code of Conduct” and serving as a facilitator in instances when the Code is violated, IMA promotes "high standards of professionalism in the incentive field.”

Development and Administration of Procedures

  1. The Board is responsible for the development and administration of these procedures; the IMA Business Conduct Review Committee is delegated to administer these procedures on behalf of the Board.
  2. The Business Conduct Review Committee will consist of the IMA Executive Committee, the Executive Director, and the Association attorney.
  3. The Executive Vice President will serve as the Chair of the Business Conduct Review Committee.
  4. The Committee is specifically responsible for ensuring these procedures are implemented and followed consistently and objectively.
  5. All Committee members, Association staff, and other individuals engaged in investigations or decisions on behalf of IMA with respect to any complaint under these procedures are indemnified and shall be held harmless and defended by IMA against any liability arising from such activities to the extent permitted by law, provided such individuals act in good faith and with reasonable care, without gross negligence or willful misconduct, and do not breach and fiduciary duty owed to IMA.
  6. No individual who (directly or through his or her family or business) has any personal or private business involvement in or connection to the alleged misconduct or any other conflict of interest shall be permitted participate in the matter to be reviewed. The affected individual shall immediately disclose any such involvement or connection to the Committee and to the Board.
  7. All investigations and deliberations of the Committee are to be conducted in the strictest confidence, except that the Committee shall be permitted to disclose any relevant information when compelled by law.


  1. Complaints may be made and transmitted by any person to the Committee, the IMA staff, or any member of the Board. All complaints will be submitted to the Committee Chair.
  2. Complaints should be in writing and the complaining individual should be identified. The individual submitting the complaint must agree in writing to maintain in confidence information regarding the review and disposition of the complaint.
  3. Direct or indirect retaliation of any kind by IMA or its Board, Members, Staff or agents against any individual that makes, initiates or is involved in the making of a complaint is strictly prohibited.
  4. Complaints made with knowledge of their falsity, in whole or on part, are strictly prohibited. This prohibition on the making of knowingly false complaints shall be strictly enforced by the Board. Upon receipt and preliminary review of each complaint, the Committee may conclude that the complaint: 1) contains unreliable or insufficient information; or 2) is patently frivolous or trivial. In such cases, the Committee may determine that the complaint does not constitute a potentially actionable complaint that would justify further action for determination of whether there has been a material violation of the Code. If so, such complaint shall be dismissed without prejudice by the Committee, and notice of such action shall be provided in writing to the submitter. Any such complaint may be re-initiated at any subsequent time pursuant to these Procedures.
  5. If a complaint is deemed by the Committee on a preliminary basis to be a potentially actionable complaint, the Committee shall see that written notice is provided the Member whose conduct has been called into question, advising the Member that a formal review of the matter is being initiated. The Committee also shall provide written notice to the individual who submitted the complaint that the complaint is being reviewed by the Committee.
  6. Individuals bringing complaints are not entitled to any relief or damages by virtue of this process, although they will receive notice of the actions taken.

Review of Complaint

  1. For each complaint involving an alleged violation of the Code that the Committee believes is a potentially actionable complaint, the Chair shall authorize an investigation into the specific facts or circumstances of the matter to whatever extent is necessary in order to clarify, expand or corroborate the information provided in the original complaint.
  2. Both the individual submitting the complaint and the Member who is the subject of the complaint may be contacted by the Committee for additional information with respect to the complaint.
  3. The Member shall be advised that she or he may submit information or arguments contesting the complaint in writing, via a teleconference, or in person.
  4. The Committee shall determine whether the complaint warrants bringing charges under these procedures against the Member who is subject of the complaint. If the Committee concludes that charges should be brought, it shall prepare written charges and a written report explaining the alleged aggrieved conduct and why such conduct violates the Code. If the Committee determines that no charges should be brought, it shall dismiss the complaint without prejudice and so notify the Member and the individual submitting the complaint in writing.
  5. If the Committee recommends charges be brought, the Committee shall notify the Member to be charged and provide the member a copy of the charges and the Committee’s report. The Committee will advise the Member that a hearing will be held for the purpose of discussing the matter with the Member and the individual who submitted the complaint. 
  6. The hearing may be held in person, or by telephone, electronic or video conference if the Member does not request the opportunity to appear in person. In-person hearings may be scheduled to coincide with industry events. The IMA attorney must be present. The Member may be accompanied and  represented by legal counsel at all times, at the Member’s sole discretion and expense. The Member may submit written statements as evidence. The Committee Chair will preside over the hearing.

Determination of Violation

  1. Upon completion of review and the hearing, the Committee shall determine by majority vote, upon preponderance of the evidence, whether or not there has been a violation of the Code. When the Committee finds that there has been a violation of the Code, the IMA Board and the Member charged with the violation will be advised in writing.
  2. The Board may consider a recommendation from the Committee that the Member in violation of the Code should be offered the opportunity to submit a written assurance that the conduct in question has been terminated and will not recur. The decision of the Committee to make such a recommendation and the Board to accept it are within their respective discretionary powers. If such an offer is extended, the Member must promptly submit the requested written assurance to the Board. If the Board accepts the assurance, then written notice thereof shall be provided to the Member, as well as to the individual who submitted the complaint. Complaints handled in this manner shall be deemed to have been disposed of without prejudice. The Board may also consider a recommendation from the Committee to take one or more of the following actions when it has been determined that a Member has violated the Code and the Board has not requested or upon request, has not been provided with written assurance that the conduct in question has been terminated and will not recur.

The action applied must reasonably relate to the nature and severity of the violation, focusing on reformation of the conduct of the Member and deterrence of the same or similar conduct by others.

  1. Member may receive a written reprimand from the Board.
  2. Member may be suspended or removed from one or more Association committees and/or task forces.
  3. Member may be prohibited from holding office in the Association, participating as an Association sponsor, or representing IMA in any way for a specific period of time or indefinitely. Unused and/or pro-rated sponsorship fees will be returned to the Member.
  4. At the discretion of the Board, the IMA Membership may be advised of the Code violation and the actions taken by the Board relating to the violation.

Once one or more of the above actions has been taken, the complaint shall be deemed to have been disposed of with prejudice.


If a Member who is the subject of a complaint voluntarily resigns (in writing) from the Association at any time during the pendency of a complaint under these Procedures, the complaint will be dismissed without prejudice. If the Member chooses to rejoin the Association later, they will be subject to all conditions of membership at that time including new member fees. In the event of such resignation, the individual who submitted the complaint shall be notified in writing of the fact and date of the resignation and that the Board has dismissed the complaint without prejudice as a consequence.