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Our Codeof ConductDoing the Right Things Right
Our Codeof ConductOUR CORE VALUESCONTENTSRESOURCESPREVIOUSPAGENEXTPAGELAST PAGEVIEWEDWe are passionate aboutdoing the right things right.Our CoreValuesWe own our experienceand results.We voicewhat matters.We explore allpossibilities.We deliverextraordinary value.2
Our Codeof ConductA MESSAGE FROM BOB CONLINCONTENTSRESOURCESPREVIOUSPAGENEXTPAGELAST PAGEVIEWEDAs NAVEX Global continues to grow, we are now the world’sforemost provider of ethics and compliance services. Our uniqueposition as the leader in the ethics and compliance field meanswe have additional responsibilities to not just meet, but exceedexpectations and follow best practices. In fact, we all share a uniqueopportunity to help evolve the programs of thousands of organizationsaround the globe, impacting literally millions of employees, while at thesame time building our own outstanding culture.As a company with clients worldwide, we must remain committed toexecute with excellence while navigating complex legal and regulatoryrequirements. And, as an innovative growth company with a globalworkforce that includes frequent travelers and virtual team members, weface many of the same challenges as our clients to sustain a culture thatsupports our core values while meeting our business goals.A Message fromBob ConlinOur Code of Conduct is intended to help us make good decisions on the jobevery day. Of course, no code can cover every possible topic or situation, which iswhy we count on everyone on our team to use good judgment and ask questionswhenever there is doubt about what to do.Our culture is built on good decisions made through discussion with others, so youshould never feel alone when facing an ethical dilemma and always feel encouraged toapproach your manager or an executive team member with a concern.Our continued success depends on each and every one of us consistently doing what’sright. As we grow, we want to be proud not only of our achievements but also of how weachieve success.This is Our Code of Conduct – Live It! – and be passionate about and committed to doing theright things right.Thank you from the entire Leadership Team!Bob ConlinPresident and CEO, NAVEX Global3
Our Codeof GELAST PAGEVIEWEDDoing the Right Things RightHow to Use Our Code of Conduct6Who Must Follow Our Code of Conduct7Our Responsibilities8Asking Questions & Raising Concerns10Zero Tolerance for Retaliation11Making the Right Choice12Our Commitment to One AnotherDiversity & Teamwork14Fairness & Equal Opportunity15Harassment-free WorkplaceContents16Safety & Physical Security17Protection of Systems & Resources18Privacy & Personal Information19Our Commitment to Our Clients & Business PartnersConfidential & Proprietary Information21Business Partners & Supplier Relations22Gathering Competitive Intelligence23Conflicts of Interest24Gifts & Entertainment25Accurate Records27Public Communications & Social Media28Our Commitment as a Responsible Corporate CitizenSocial Responsibility30Anti-corruption & Bribery31Free & Fair Competition33Insider Trading34Political Activity35Global Trade36AcknowledgementResourcesA Closing Message from Carrie Penman4
Our Codeof ConductDOING THE RIGHT THINGS RIGHTDoing the RightThings RightCONTENTSRESOURCESPREVIOUSPAGENEXTPAGELAST PAGEVIEWEDWE WANT TO BE PROUD NOTONLY OF OUR ACHIEVEMENTSBUT ALSO OF HOW WEACHIEVE SUCCESS» How to Use Our Code of Conduct» Who Must Follow Our Code of Conduct» Our Responsibilities» Asking Questions & Raising Concerns» Zero Tolerance for Retaliation» Making the Right Choice5
Our Codeof ConductDOING THE RIGHT THINGS RIGHTCONTENTSRESOURCESPREVIOUSPAGENEXTPAGELAST PAGEVIEWEDHow to Use Our Codeof ConductSITUATIONS INVOLVING ETHICS CAN BE COMPLICATED,AND SOMETIMES IT IS DIFFICULT TO KNOW WHAT TODO. WE WANT YOU TO HAVE THE RESOURCES YOU NEED TOMAKE GOOD CHOICES ON THE JOB EVERY DAY. OUR CODEOF CONDUCT IS DESIGNED TO POINT YOU TO NAVEX GLOBAL’SSTANDARDS AND EXPECTATIONS AS WELL AS THE PEOPLE WHO AREAVAILABLE TO HELP YOU.We comply with all laws that apply to our business. We also take steps toensure client needs and regulatory requirements are met, such as providingteam member training and evaluating our products and services.We conduct business around the world, so our policies may sometimes differfrom local laws, rules, cultural norms and regulations. Where there appears to be aconflict, you should typically comply with the more restrictive requirement. However,if a cultural norm violates our core values or if the right course of action is not clear,contact your manager, human resources, the legal department or the chief complianceofficer for guidance.6
Our Codeof ConductDOING THE RIGHT THINGS RIGHTQ&AQ: WHAT IF I’M FACING A SITUATION THAT IS NOTCOVERED IN OUR CODE OF CONDUCT?A: Our Code of Conduct can’t address all of theissues that may arise at work. If you’re ever unsureof the right course of action, check our policies. Ifthe answer is still unclear, it’s always appropriate– in any situation – to ask for help. Start with yourmanager or any of the resources identified inOur Code.CONTENTSRESOURCESPREVIOUSPAGENEXTPAGELAST PAGEVIEWEDWho Must FollowOur Code of ConductOUR CODE APPLIES TO EVERY NAVEX GLOBAL TEAMMEMBER. BUSINESS PARTNERS AND THIRD PARTIES ARE ANEXTENSION OF OUR ORGANIZATION, AND THEIR BEHAVIORCAN HAVE A DIRECT IMPACT ON OUR REPUTATION.For this reason, we work with business partners who share ourcommitment to ethics and compliance. We expect all of ourpartners and their employees to act in a way that is consistent withOur Code of Conduct, and we will consider terminating contractswhere we believe our partners have not met our high standards or theircontractual obligations.7
Our Codeof ConductDOING THE RIGHT THINGS RIGHTCONTENTSRESOURCESPREVIOUSPAGENEXTPAGELAST PAGEVIEWEDOur ResponsibilitiesEVERY NAVEX GLOBAL TEAM MEMBER HAS A RESPONSIBILITY TOMAINTAIN OUR REPUTATION FOR HIGH ETHICAL STANDARDS.TO MEET THIS RESPONSIBILITY, WE EXPECT YOU TO:»» Be professional, honest and ethical in everything you do on behalfof NAVEX Global»» Know Our Code of Conduct, and the laws and policies that pertainto your job»» Complete all required ethics and compliance training in atimely manner and apply it to your job every day. Ask questionsif you aren’t sure about the right action»» Report concerns about possible violations of laws, regulations,Our Code of Conduct and policies»» Cooperate fully and tell the whole truth when respondingto an investigation or audit»» Be accountable for your actions. Violating Our Code ofConduct, applicable laws or our company policies isgrounds for corrective action, up to andincluding dismissal8
Our Codeof ConductDOING THE RIGHT THINGS RIGHTCONTENTSRESOURCESPREVIOUSPAGENEXTPAGELAST PAGEVIEWEDOur Responsibilities(Continued)IF YOU MANAGE PEOPLE, YOU HAVE AN EVEN GREATERRESPONSIBILITY. WE EXPECT YOU TO:»» Be a role model. Lead with integrity and promote a culture of ethicsand respect»» Keep an open door and encourage your team to raise questionsor concerns»» Support your team and help them understand what isexpected of them»» Understand your obligation to report behavior that isillegal or violates Our Code of Conduct, our policies orthe law»» Never retaliate, or allow others to retaliate, againstteam members who raise concerns9
Our Codeof ConductDOING THE RIGHT THINGS RIGHTCONTENTSRESOURCESPREVIOUSPAGENEXTPAGELAST PAGEVIEWEDAsking Questions &Raising ConcernsOUR CORE VALUE “SAY IT!” MEANS THAT WE VOICE WHAT MATTERS. WEUNDERSTAND THE IMPORTANCE OF SPEAKING UP, ASKING QUESTIONSAND RAISING CONCERNS – AFTER ALL, PROMOTING A SPEAK-UP CULTUREIS OUR BUSINESS. IT’S NOT ONLY IMPORTANT FOR OUR CLIENTS, IT’SIMPORTANT FOR US, TOO.Speak up if you have a question or need to report a possible violation ofOur Code of Conduct, policies or the law. You have several options:When you “Say It!” we have the opportunity to addressand resolve issues before they become more serious.»» Talk to your manager, human resources, the legal departmentor any executive team member, including our chief complianceofficerReporting Violations of Our Code of Conduct»» Use NAVEX Global’s online reporting system atwww.NAVEX4NAVEX.comWhile it is important to report a suspected violation ofOur Code of Conduct, it is just as essential to do sohonestly and ethically. You should not file a dishonestreport or any report for the purpose of:Any report you make will be kept confidential to the fullestextent possible, consistent with the law and good businesspractices. You may report anonymously unless prohibitedby law.Regardless of the method you use to report, or whetheror not you choose to be anonymous, the same courseof action will be taken to investigate yourconcerns and follow up as necessary. If you dochoose to report anonymously, please provideas much detailed information as possible andplease check back to see if we have posted anyrequests for additional information.››Retaliating against another›› Gaining››an advantage in a personal conflictHarassing another employeeKnowingly filing a dishonest report, or a report for an improperpurpose, is, in itself, a violation of Our Code of Conduct.10
Our Codeof ConductDOING THE RIGHT THINGS RIGHTCONTENTSRESOURCESPREVIOUSPAGENEXTPAGELAST PAGEVIEWEDZero Tolerancefor RetaliationIF YOU ASK A QUESTION, REPORT POSSIBLEMISCONDUCT OR TAKE PART IN AN INVESTIGATIONOF AN ETHICS AND COMPLIANCE MATTER, YOU ARECOMPLYING WITH OUR CODE OF CONDUCT ANDDOING THE RIGHT THING. UNDER NO CIRCUMSTANCESWILL RETALIATION AGAINST YOU BE TOLERATED.Retaliation can take many forms, from being unfairly dismissed,to being the target of bullying or derogatory comments in socialmedia by managers or peers. We take all claims of retaliationseriously, investigating each one thoroughly and taking appropriateaction. We consider acts of retaliation to be acts of misconductwhich, if substantiated, could result in disciplinary action up to, andincluding, dismissal.11
Our Codeof ConductDOING THE RIGHT THINGS RIGHTCONTENTSRESOURCESPREVIOUSPAGENEXTPAGELAST PAGEVIEWEDIf you’re faced with an ethicaldilemma and you’re not surewhat to do, ask yourself:IS IT LEGAL?Making theRight ChoiceDOES ITCOMPLY WITHOUR POLICIES?IS IT CONSISTENTWITH OUR LONGTERM GOALSAND INTERESTS?IS ITCONSISTENTWITH OUR COREVALUES?WOULD I BECOMFORTABLE WITHMY DECISION IF ITWAS MADE PUBLIC?If your answer to any of thesequestions is “NO,“ don’t doit, or seek further guidance.12
Our Codeof ConductOUR COMMITMENT TO ONE ANOTHEROur Commitmentto One AnotherCONTENTSRESOURCESPREVIOUSPAGENEXTPAGELAST PAGEVIEWEDWE UNDERSTAND THAT THETRUE MEASURE OF HOW WEVIEW OUR WORK STARTS WITHHOW WE TREAT EACH OTHER» Diversity & Teamwork» Fairness & Equal Opportunity» Harassment-free Workplace» Safety & Physical Security» Protection of Systems & Resources» Privacy & Personal Information13
Our Codeof ConductOUR COMMITMENT TO ONE ANOTHERCONTENTSRESOURCESPREVIOUSPAGENEXTPAGELAST PAGEVIEWEDDiversity & TeamworkNAVEX GLOBAL STRIVES TO UNDERSTAND, VALUE ANDINCORPORATE THE DIFFERENCES EACH TEAM MEMBER BRINGSTO OUR ORGANIZATION. IT IS IMPORTANT FOR US TO ATTRACTINDIVIDUALS AND BUILD TEAMS THAT REPRESENT THE DIVERSITYOF THE CLIENTS WE SERVE.When our teams include people with different backgrounds, talentsand ideas, we are more dynamic and successful. That is why wevalue each and every employee as an important contributor to oneNAVEX Global team.»» Appreciate the uniqueness of every team member»» Treat others with respect. Each of us has the right toexpect a workplace in which the differences we bring arewelcomed and valued»» Keep an open mind to new ideas and points of view»» Expect the same level of commitment to a diverseworkforce from those with whom we do business»» Management team members have additionalresponsibilities when concerns are reportedto them14
Our Codeof ConductOUR COMMITMENT TO ONE ANOTHERCONTENTSRESOURCESPREVIOUSPAGENEXTPAGELAST PAGEVIEWEDFairness & Equal OpportunityWE BELIEVE THAT EVERYONE SHOULD BE TREATED WITH FAIRNESS,RESPECT AND DIGNITY. AS AN EQUAL EMPLOYMENT OPPORTUNITYEMPLOYER, WE COMPLY WITH ALL APPLICABLE LAWS AND REGULATIONSCONCERNING NONDISCRIMINATORY EMPLOYMENT PRACTICES.We are committed to providing reasonable accommodations for teammembers and job applicants with disabilities.»» Base employment decisions on qualifications, demonstratedskills and achievements – without regard to age, race, gender,nationality, sexual orientation, gender identity or expression,physical ability, thinking style, veteran status or any othercharacteristic protected by applicable laws»» Set the expectation with our business partners that webelieve they should act in a way that is consistent withour sense of fair treatment and equal opportunity15
Our Codeof ConductOUR COMMITMENT TO ONE ANOTHERCONTENTSRESOURCESPREVIOUSPAGENEXTPAGELAST PAGEVIEWEDHarassment-free WorkplaceHARASSMENT IN THE WORKPLACE CAN TAKE MANY FORMS AND BEEXPERIENCED DIFFERENTLY FROM ONE INDIVIDUAL TO ANOTHER.AT NAVEX GLOBAL, WE HAVE ZERO TOLERANCE FOR ANY FORM OFHARASSMENT, INCLUDING SEXUAL HARASSMENT AND BULLYING.Any type of harassment (physical, verbal, sexual or other) is strictlyprohibited and could result in immediate separation of employmentfrom NAVEX Global.»» Help create a professional work environment that is freeof all forms of harassment»» Remember that sexual harassment includes unwantedsexual advances, requests for sexual favors or physicalcontact, or any other sexually offensive behavior»» Maintain our high standards of professional conductat all times, including when working with clients andbusiness partners, during business hours and afterhours, and in all business settings – inside andoutside the officeBullying and intimidation ofothers directly contradicts ourvalues and will not be tolerated.Q&AQ: ONE OF MY COWORKERS EMAILED A SEXUALLYEXPLICIT JOKE TO OUR WHOLE TEAM, AND I FIND ITOFFENSIVE. SHOULD I SAY SOMETHING?A: Yes. Each of us has a responsibility to promote arespectful workplace. If you feel uncomfortable speakingwith your coworker directly about the email, contact yourmanager or another company resource.16
Our Codeof ConductOUR COMMITMENT TO ONE ANOTHERCONTENTSRESOURCESPREVIOUSPAGENEXTPAGELAST PAGEVIEWEDSafety & Physical SecurityWHEN WORKING, ALWAYS BE ALERT TO HEALTH AND SAFETY RISKS –EVEN IN OFFICE ENVIRONMENTS. BE SURE THAT YOUR PERFORMANCEIS NOT IMPAIRED BY ALCOHOL OR DRUGS, INCLUDING PRESCRIPTIONAND OVER-THE-COUNTER MEDICATION.This applies to team members on company premises or in any otherwork circumstance that may jeopardize NAVEX Global’s operations,safety or reputation.Weapons are not permitted at any time while on any propertyowned, leased or controlled by NAVEX Global, including anywherebusiness is conducted, such as customer locations, clientlocations, trade shows, restaurants, company event venues, etc.Weapons include, but are not limited to, guns, knives or swordswith blades over four inches in length, explosives, and anychemical which purpose is to cause harm to another person.»» Promptly report any accident, injury, illness or unsafeor unhealthy condition to human resources»» Promptly report any threats, intimidation or acts ofviolence to a member of leadership17
Our Codeof ConductOUR COMMITMENT TO ONE ANOTHERCONTENTSRESOURCESPREVIOUSPAGENEXTPAGELAST PAGEVIEWEDProtection of Systems & ResourcesWE TRUST THAT OUR TEAM MEMBERS WILL USE OUR COMPANY ASSETSAPPROPRIATELY AND PROTECT THEM FROM LOSS, DAMAGE, THEFT, WASTEAND IMPROPER USE. THESE RESOURCES ARE INTENDED TO ADVANCE THESUCCESS OF THE COMPANY AND INCLUDE FACILITIES, PROPERTY ANDEQUIPMENT, COMPUTERS AND INFORMATION SYSTEMS, PHONES,EMPLOYEE TIME, CONFIDENTIAL AND PROPRIETARY INFORMATION,CORPORATE OPPORTUNITIES AND COMPANY FUNDS.»» Protect company resources from loss or harm»» Don’t use, borrow or loan company assets without permission»» Be aware that our computer equipment, phones, email and internet accessare for business purposes, but some limited personal use is acceptableSee Workplace Practicesfor specific guidelineson appropriate use ofcompany assets.»» Use care when transferring confidential information onto a portablestorage device such as a memory stick. Note that NAVEX Globalcomputers are configured to only allow downloading to companyprovided encrypted external drives»» Keep computer equipment safe and secure at all times, andprotect your user IDs and passwords»» Keep confidential and proprietary information safe and secure»» Look after our intellectual property and respect theintellectual property rights of others18
Our Codeof ConductOUR COMMITMENT TO ONE ANOTHERCONTENTSRESOURCESPREVIOUSPAGENEXTPAGELAST PAGEVIEWEDPrivacy &Personal InformationALWAYS RESPECT THE PRIVACY OF OTHERS AND THECONFIDENTIALITY OF PERSONAL INFORMATION – BOTHTHE PERSONAL INFORMATION OF YOUR COWORKERSAND THE PERSONAL INFORMATION ENTRUSTED TO USBY OUR CLIENTS. KEEP PERSONAL INFORMATION SAFEAND SECURE.Due to their role, some team members may also have access to theconfidential health information of others (including our own employees,as well as within reports that we take on behalf of our clients).» Be sure to securely print, store and mark as confidential, any physicalcopies of materials that contain personal or health information»U se care when sharing personal information with anyone inside or outsidethe company, and limit access and the amount of information only to thosewho need to access that information in order to perform their duties» Use and retain personal information only for as long as necessary to accomplishthe legitimate purpose for which it was collected» Be aware of and respect local privacy laws, especially when transferring anypersonal information outside its country of origin19
Our Codeof ConductOUR COMMITMENT TO OUR CLIENTS & BUSINESS PARTNERSOur Commitmentto Our Clients &Business PartnersCONTENTSRESOURCESPREVIOUSPAGENEXTPAGELAST PAGEVIEWEDWORKING TOGETHER WITH OURCLIENTS AND BUSINESS PARTNERS,WE MAKE A POSITIVE DIFFERENCEIN THE LIVES OF OTHERS» Confidential & Proprietary Information» Business Partners & Supplier Relations» Gathering Competitive Intelligence» Conflicts of Interest» Gifts & Entertainment» Accurate Records» Public Communications & Social Media20
Our Codeof ConductOUR COMMITMENT TO OUR CLIENTS & BUSINESS PARTNERSCONTENTSRESOURCESPREVIOUSPAGENEXTPAGELAST PAGEVIEWEDConfidential &Proprietary InformationWE UNDERSTAND THAT THE NATURE OF OUR WORK REQUIRESTHAT WE TAKE THE UTMOST CARE WITH INFORMATION WE SEE,HEAR OR LEARN. WE MUST ALWAYS UPHOLD OUR PROMISE ANDCONTRACTUAL OBLIGATIONS TO KEEP THE PERSONAL ANDCONFIDENTIAL INFORMATION OF OUR COMPANY AS WELLAS THE CONFIDENTIAL INFORMATION OF OTHERS SAFEAND SECURE.» Be careful when communicating or using confidentialcompany or client information. Share it only with thosewho are authorized and need it in order to do their jobs» Comply with the confidentiality and nondisclosure provisions of the agreement yousigned when hired at NAVEX Global. Note that thisrequirement extends to third parties working onour behalf» In addition to respecting client confidentialinformation, respect the confidential and proprietaryinformation of other third parties, such as competitors,suppliers and others, including intellectual property likecopyrights and trademarks»O ur agreements require us to protect all confidential andproprietary company information even after our employmentwith NAVEX Global endsAs part of our commitment to protectingconfidential and proprietary information, werequire that team members in the ContactCenter sign monthly re-affirmation pledges.21
Our Codeof ConductOUR COMMITMENT TO OUR CLIENTS & BUSINESS PARTNERSCONTENTSRESOURCESPREVIOUSPAGENEXTPAGELAST PAGEVIEWEDBusiness Partners &Supplier RelationsWE SEEK BUSINESS PARTNERSHIPS THAT ALIGN WITH OURCORE VALUES AND FOLLOW THE HIGHEST STANDARDS OFBUSINESS CONDUCT. WE PERFORM DUE DILIGENCE AND KNOWOUR BUSINESS PARTNERS, CONSULTANTS, AGENTS AND ALL THOSETHROUGH WHOM WE CONDUCT OUR BUSINESS.All arrangements with our business partners require an agreement withNAVEX Global to ensure our standards of conduct and commitments to ourclients are upheld.» Follow our procurement and approval processes» Conduct due diligence on new suppliers and agents acting on our behalf» Help suppliers understand our ethics and compliance standards and theircontractual obligations» Be aware that additional rules apply when we bid for and conduct business withgovernments and their contractors, employees or representatives. Team membersworking with any government entity have an additional responsibility to know, understandand follow the laws and regulations pertaining to their work» Report to the legal department or the chief compliance officer any supplier or businesspartner that may not be meeting our standards22
Our Codeof ConductOUR COMMITMENT TO OUR CLIENTS & BUSINESS PARTNERSCONTENTSRESOURCESPREVIOUSPAGENEXTPAGELAST PAGEVIEWEDGathering CompetitiveIntelligenceINFORMATION ABOUT COMPETITORS CAN BE A VALUABLEASSET IN TODAY’S BUSINESS ENVIRONMENT. WHEN WE GATHERBUSINESS INTELLIGENCE, TEAM MEMBERS AND OTHERS WHO AREWORKING ON OUR BEHALF MUST ALWAYS ABIDE BY THE HIGHESTETHICAL STANDARDS.»» Never engage in fraud, misrepresentation or deceptionto obtain information or use invasive technology to spyon others»» Be careful when accepting information from third parties.Verify their sources and be sure that the informationthey provide is not protected by trade secret laws ornondisclosure or confidentiality agreements»» Do not use or disclose the confidential informationof your former employers23
Our Codeof ConductOUR COMMITMENT TO OUR CLIENTS & BUSINESS PARTNERSCONTENTSRESOURCESPREVIOUSPAGENEXTPAGELAST PAGEVIEWEDConflicts of InterestA CONFLICT OF INTEREST MAY OCCUR WHEN OUR PERSONALCIRCUMSTANCES IMPACT OUR ABILITY TO MAKE OBJECTIVEBUSINESS DECISIONS. THE BEST APPROACH IS TO AVOIDPOTENTIAL CONFLICTS WHENEVER POSSIBLE AND DISCLOSESITUATIONS TO MANAGEMENT THAT MIGHT CREATE ACONFLICT, OR EVEN THE APPEARANCE OF A CONFLICT.Once disclosed, the situation can usually be managedand resolved.Be aware of the different ways conflicts of interest canarise. For example:Q&AQ: I WAS JUST ASSIGNED A CLIENT, AND IT’S ACOMPANY IN WHICH I OWN STOCK. IS THAT ACONFLICT OF INTEREST?A: Possibly – if you own more than 5 percent of thatcompany. The best course of action would be to disclose thisinformation to your manager or other company resource sothat the situation can be reviewed and a determination can bemade about appropriate next steps.»» Outside jobs and affiliations, especially withcompetitors, clients or business partners»» Working with close relatives, especially ifthey report to you»» Serving as a board member of anotherorganization»» Investments that might influence – orappear to influence – your judgment24
Our Codeof ConductOUR COMMITMENT TO OUR CLIENTS & BUSINESS PARTNERSCONTENTSRESOURCESPREVIOUSPAGENEXTPAGELAST PAGEVIEWEDGifts & EntertainmentIN THE RIGHT CIRCUMSTANCES, A MODEST HOLIDAY GIFT MAYBE A THOUGHTFUL “THANK YOU,” OR A MEAL MIGHT HELPSTRENGTHEN A BUSINESS RELATIONSHIP. HOWEVER, IFNOT HANDLED CAREFULLY, THE EXCHANGE OF GIFTSAND ENTERTAINMENT CAN DAMAGE OUR REPUTATION,ESPECIALLY IF IT HAPPENS FREQUENTLY OR IF THE VALUEIS LARGE ENOUGH THAT SOMEONE COULD THINK IT ISINFLUENCING A BUSINESS DECISION.To sustain the health of our key business relationships, do notaccept or ask for any gift that might influence, or appear toinfluence, your ability to make objective business decisions inthe best interest of NAVEX Global, unless refusing such a giftwould be considered culturally offensive. If you believe itwould be truly insulting to a client or business partner todecline a gift, accept the gift but immediately report it toyour manager, human resources or the chief complianceofficer who will help you decide how the situationshould be best handled.You may accept an occasional meal andentertainment from a client, vendor or partner aslong as they are attending the event, and thecosts involved are in line with local customs forbusiness-related meals and entertainment.25
Our Codeof ConductOUR COMMITMENT TO OUR CLIENTS & BUSINESS PARTNERSCONTENTSRESOURCESPREVIOUSPAGENEXTPAGELAST PAGEVIEWEDGifts & Entertainment(Continued)If you receive such an offer, inform your manager, human resources or thechief compliance officer. If you are offered a gift, meal or entertainmentthat would compromise our commitment to this practice, please extendappreciation for the offer, gracefully decline, and notify your manager,human resources or the chief compliance officer.When it comes to offers of gifts and entertainment, make sure toobserve the following:» We win business based on quality of our products andservices. Never promise, offer or provide anything of valuein exchange for an improper action or favorable decision» In some situations, provision of gifts or entertainmentmay violate the law, such as when dealing withgovernment officials. Do not offer anything of valueto a government official without receiving approvalin advance from the legal department or the chiefcompliance officer» Some gifts and entertainment are neveracceptable, for example cash or cashequivalents, or any gift or entertainment thatwould harm our reputation, such as thosethat are indecent or improper» Be aware of the organizational rules andstandards of those to whom you intend toprovide a gift or entertainment. If there isa conflict between their standards and ours,always follow the more stringent standardQ&AQ: DURING THE HOLIDAYS, ONE OF OUR VENDORSSENT ME A GIFT CARD TO A LOCAL RESTAURANT.MAY I ACCEPT IT?A: No. A gift card is a cash equivalent and it would violateour policies to accept it. After notifying your manager, youshould politely thank the vendor but return the gift card and lether know about our company’s gifts and entertainment policy.26
Our Codeof ConductOUR COMMITMENT TO OUR CLIENTS & BUSINESS PARTNERSCONTENTSRESOURCESPREVIOUSPAGENEXTPAGELAST PAGEVIEWEDAccurate RecordsACCURATE RECORDS ARE ESSENTIAL FOR US TO MAKE GOODBUSINESS DECISIONS. IN ADDITION, OTHERS, INCLUDING BUSINESSPARTNERS AND GOVERNMENT OFFICIALS, RELY ON OUR DISCLOSURESAND BUSINESS RECORDS.Some team members have special responsibilities in this area, butall of us contribute to the process of recording financial and nonfinancial information.» Be accurate and complete with our business records» Understand and follow applicable laws and our policieswhen creating, retaining or destroying documents»N ever destroy documents in response to or inanticipation of an investigation or auditEveryone needs to be aware ofthe importance of being honest,forthright and objective in all of ourcompany records.27
Our Codeof ConductOUR COMMITMENT TO OUR CLIENTS & BUSINESS PARTNERSCONTENTSRESOURCESPREVIOUSPAGENEXTPAGELAST PAGEVIEWEDPublic Communications& Social MediaWE NEED A CLEAR, CONSISTENT VOICE WHEN PROVIDINGINFORMATION TO THE PUBLIC – INCLUDING THE MEDIA – ABOUTNAVEX GLOBAL, OUR OPERATIONS OR OUR BUSINESS PLANS.FOR THIS REASON, REQUESTS FOR INFORMATION ABOUTNAVEX GLOBAL FROM ANY MEMBER OF THE MEDIA SHOULDBE REFERRED TO THE CORPORATE MARKETING DEPARTMENT.When you participate in social networks, the following are someguidelines to follow:»» Never share the confidential or proprietary informationof NAVEX Global, our clients or business partners. Knowand follow the terms of your confidentiality agreement»R espect intellectual property and financialdisclosure laws. No unlawful use may be made ofNAVEX Global’s trademarks» Think before you hit the “send” button – onlinecommunications live foreverIf you see comments or posts on social media that youbelieve are inaccurate or unfairly represent NAVEX Global orour clients, do not respond. Instead, report the information tothe corporate marketing department, the legal department orthe chief compliance officer who will help you determine the bestcourse of action.»» Identify yourself. If you are commenting orpublishing on topics related to your job, identifyyourself as an employee of NAVEX Global»» Before providing a recommendation for acolleague (current or past), seek guidance fromhuman resources28
Our Codeof ConductOUR COMMITMENT AS A RESPONSIBLE CORPORATE CITIZENOur Commitmentas a ResponsibleCorporate CitizenCONTENTSRESOURCESPREVIOUSPAGENEXTPAGELAST PAGEVIEWEDWE HONOR THE LETTER AND THESPIRIT OF THE LAW EVERYWHEREWE DO BUSINESS» Social Responsibility» Anti-corruption & Bribery» Free & Fair Competition» Insider Trading» Political Activity» Global Trade29
Our Codeof ConductOUR COMMITMENT AS A RESPONSIBLE CORPORATE CITIZENCONTENTSRESOURCESPREVIOUSPAGENEXTPAGELAST PAGEVIEWEDSocial ResponsibilityWE ARE PROUD OF THE ROLE WE PLAY IN SHAPING THE GLOBALMOVEMENT TOWARD GREATER CORPORATE INTEGRITY ANDSOCIAL RESPONSIBILITY. AS AN ORGANIZATION, WE SUPPORTAND RESPECT EFFORTS TO PROTECT HUMAN RIGHTS ANDADVANCE ENVIRONMENTAL SUSTAINABILITY.»» We ensure that all our employees work out of their ownfree will»» We do not accept corporal punishment, forced orinvoluntary labor, or other forms of mental and physicalcoercion. We do not use or permit the use of child laborIn addition to our global support of human rightsand environmental sustainability, we also understandthat social responsibility has a local component andmeans being a good neighbor in the communities inwhich we operate.While each of us is encouraged to become involved inthe life of our local communities by supporting causesand events, it is important to remember that we should notpressure others to contribute to or participate in our preferredcharitable organizations.»» We strive to work with business partners who shareour standards and commitment to human rights, andwe work with our clients to assist them in meetingtheir corporate social responsibility goals»» We strive to look for ways t
We comply with all laws that apply to our business. We also take steps to ensure client needs and regulatory requirements are met, such as providing team member training and evaluating our products and services. We conduct business around the world, so our policies may sometimes differ from local laws, rules, cultural norms and regulations.
