Code of Conduct Awareness

Our company developed a Code of Conduct (the Code) for several reasons. First of all, we knew it was important to communicate about the ways in which our organization is legally required to adhere to certain laws and regulations. The Code is designed to prevent lawsuits and investigations due to ethical breaches by anyone in our company, as well as by third parties with whom we do business.

When employees do not follow the Code, the consequences can be severe — even fatal — to our company. These include legal action, fines, imprisonment of individuals, and the loss of the trust and reputation of our company.

But beyond meeting the legal requirements that prompted the creation of this document, the Code helps us develop and strengthen a corporate culture that embodies and reinforces our key values. It allows us to keep up with our competitors and operate in a more efficient and cohesive way.

We also provide public access to the Code, to share with the community at large the standards by which we operate and the responsibilities of our organization and its employees to follow those standards.

What the Code Covers

The Code of Conduct consists of principles, values and rules of behavior that guide the decisions, procedures and actions of our company as we work collectively to contribute to the welfare of stakeholders and respect the rights of all constituents affected by our operations.

Code topics range from disclosing conflicts of interest that might appear to compromise our ability to treat all clients, vendors and employees equally… to fighting corruption in our global operations… to preventing harassment and discrimination in the workplace… to maintaining the accuracy and timeliness of financial and other company records.

Some examples of specific situations explored in the Code include:

• A client gives an employee a free product in exchange for a favorable review or a contract to use that company’s product.
• An employee entertains a foreign prospect beyond legally acceptable limits.
• Someone spreads malicious and false information about a competitor on social media in order to gain business or recruit the competitor’s employees.
• A representative of our company trades information about a work bid with a competitor in order to profit jointly.
• Our company fails to release negative financial information, creating a false impression of how the company is doing.
• An employee discovers inaccurate information in our website or marketing materials and does not correct the information.
• Someone pays customers to promote our product without disclosing the financial relationship.
• A new hire discloses confidential information from a previous job.
• An employee fails to disclose a strong financial interest in a competitor organization.
• An employee covers up safety violations.
• Employees collude to hide information during an audit.

The Code also clearly spells out the process and protocol for reporting violations such as the ones listed above.

What Is Not Covered

Despite its thoroughness, the Code is not exhaustive. In other words, it does not address every possible situation that might generate an ethical dilemma. Instead, it provides a broad set of behavioral and philosophical guidelines for how we, as an organization, agree to operate.

In addition, the Code does not provide a single answer to every question it raises. This is because ethical issues are not always black or white. “Gray areas” can occur when values are in conflict. In instances of complexity, or where there is a difficult tradeoff to consider, our Code is designed to provide a framework for deciding on the best course of action.

Bear in mind that, depending on the situation, further investigation or consultation might be required. Our Code is backed up by other available resources, such as your manager or another manager, the human resources department or our compliance department, which is always on hand to answer questions or help you think through ethical issues.

Acting Ethically

While having an up-to-date Code that all employees know about and that the community can scan meets our legal obligation as a corporation, the most important part of having a code in place comes in the form of taking action. All of us must “walk the talk,” or behave every day according to the principles embodied in the document.

Each of us has an ongoing responsibility to do the following:

• Know the Code. Read it and understand its contents.
• As you go about your daily work, be attentive to potential threats to our organization’s ethical integrity in the form of both blatant wrongdoing and subtle “bending of the rules.”
• Keep the Code current. To that end it’s important that all of us bring up questions and topics that may not be addressed in the code, or that may not be adequately covered there. Together we can make our Code be both a living document and a useful daily reference guide.

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