for internal use only august 2015 we are hay group our code of business conduct and ethics

Transcription

1 for internal use only august 2015 we are hay group our code of business conduct and ethics

2 table of contents part i: what it is 01 Message from steve 02 our Values in action 03 Ethical Decision Making Model 06 Know the code part ii: what it includes 08 Integrity and compliance with law 10 equal opportunity and Harassment 12 Insider trading 14 Export controls 16 confidentiality and data privacy 18 intellectual property 20 use of company resources 22 Conflict of interest 24 Compliance and Reporting 26 Social Media and communication 28 safety, environment and well-being part iii: ask/report/share

3 ceo message Dear colleagues, I m proud of Hay Group s rich culture, values, and our commitment as individuals and an organization to do the right thing. I hold myself and all of our leaders, shareholders, managers, and colleagues to a high standard of business and professional conduct. That s why I m introducing We are Hay Group, our Code of Business Conduct and Ethics. Our client value proposition we help organizations achieve their strategic goals and highest aspirations by releasing the full power and potential of their people expresses the value we bring to clients. And it will be fully linked with our employee value proposition, the value we bring to employees and candidates. To deliver on our promise to clients, there can be no gap between who we say we are and who we really are. Our brand values are also core to who we are and who we aspire to be today, tomorrow, and every day. Our Code of Business Conduct and Ethics reinforces our values and inform our daily actions and interactions. It s our guide, and supports us in our decisions and obligations for the company and towards each other. Acting with integrity serves all stakeholders of the company, including our employees, shareholders, clients, vendors and communities. Monitoring, reporting, and compliance is an obligation, and one that is directly related to our future success. Personal accountability helps us avoid undue risk and potential liability. It allows us to improve the quality of our services and our relationships with clients and colleagues. And it increases the value of our company by enhancing our reputation and brand. The scope of our Code is global. It applies to all Hay Group employees, shareholders, associates, and independent contractors. It covers many subjects, and is intended as a resource for reference, as needed, at any time. If you are ever in question about the right thing to do, or believe that our Code of Business Conduct and Ethics is being violated, please speak up. Talk with your manager, your manager s manager, or contact ethics@haygroup.com. This is our shared privilege, accountability and obligation. Together, we are Hay Group. Thank you, 1

4 our values in action Living our brand values is how we ll earn a reputation for doing the right things with the right people. At the heart of our work is the belief that ultimately, the success of an organization lies in its people. The same is true for Hay Group. In the end, our ability to fulfill our potential lies in what we do and what we say. How we behave influences the way people think about us. Our brand behaviors are the ways we live our brand values. They re unique to Hay Group and relevant to all of us. Insightful We re perceptive and curious, often discovering what others don t. Committed We care about our clients organizations and are dedicated to making them stronger. Courageous We make clear and candid recommendations with a confident voice, not just observations. Helpful We re practical, we understand our clients objectives and work with them to get the job done. Empathetic We never forget that we re people dealing with people. We think about who they are and what drives them, as well as the needs of owners and shareholders. We see all these behaviors in action already, which is really good news because we know that they are what will help us add value to our clients and make Hay Group a great place to work. We need you to engage with these behaviors and embed them all into your daily life. Changing behavior is never easy, and we know that you re faced with difficult situations in your day-to-day work. But we also know that these behaviors are vital to our transformation journey and achieving our v.2020 goals. insightful committed courageous helpful empathetic 2 OUR CODE OF BUSINESS CONDUCT AND ETHICS

5 ethical decision making model Each of us has a responsibility to take action when faced with an ethical dilemma. It s important to remember we re serving a greater purpose. Often, it can seem easier to say nothing, do nothing, or look the other way and to not take action. But not taking action can have significant consequences. Our values should guide us to make decisions every day that are consistent and aligned with who we are and who we aspire to be. Regardless of the situation, we must always act with honesty and integrity in everything we do. Your individual commitment to doing the right thing contributes to our success and brand. It allows us to become trusted advisors to our clients and all the people we serve. Violating our Code of Business Conduct and Ethics is subject to disciplinary action, including termination of employment. So, please, understand the importance of this and always use ethical decision making to determine the best course of action. Here s a simple model you can use to help you in this process: Is it legal? Does it comply with Hay Group policy? Does it reflect Hay Group brand behaviors and culture? Could it harm Hay Group stakeholders? If the media reported this, would you be concerned? Could Hay Group be harmed if all employees did this? 3

6 "ask yourself" ethics decision tree Uncertain? Contact the legal department. Uncertain? Check Hay Group policy. Talk to your manager or your HR representative for guidance. Uncertain? Think about Hay Group's brand values. for guidance. Is it legal? Yes Does it comply with Hay Group policy? Yes Does it reflect Hay Group brand behaviors and culture? Yes NO NO NO Serious Risk. Must not do it. Potential Risk. Do not do it. Potential Risk. Do not do it. 4 OUR CODE OF BUSINESS CONDUCT AND ETHICS

7 Uncertain? Contact the legal department or Uncertain? Talk with your manager, contact the legal department, or Uncertain? Contact the legal department, or Could it harm Hay Group stakeholders? No If the media reported this, would you be concerned? No Could Hay Group be harmed if all employees did this? No The course of action appears proper and ethical. YES YES YES Potential Risk. Do not do it. Serious Potential Risk. Do not do it. Potential Risk. Do not do it. 5

8 know the code Our Code is designed to be a resource for decision making that helps you navigate difficult situations. It s extensive, but it s not exhaustive. There are many possible scenarios you might need help with use the decision making model, exercise good judgment, and if in doubt ask for help. This Code is maintained and monitored for compliance by our Legal and Internal Audit Department. It applies to everyone: Our employees Our leaders Our partners Our customers Our shareholders Our Hay Group Code of Business Conduct and Ethics (the Code") expresses the commitment of HG (Bermuda) Limited and its worldwide affiliates (collectively, Hay Group ) to conduct business in accordance with all applicable laws, rules and regulations and the highest ethical standards. All employees, associates, independent contractors and directors are expected to follow the Code. Hay Group also expects our suppliers and vendors to abide by this Code. This Code is not intended to cover all laws or policies globally, or every possible ethical issue that you may face. It should be read and treated as a supplement to: (i) the Hay Group Code of Ethics for Financial Professionals (September 2006); (ii) local company policies in effect from time to time; and (iii) various applicable professional codes of ethics that have the force of law in particular countries in which Hay Group operates. When you are faced with an ethical dilemma, you have a responsibility to take action. Taking no action, in itself, can have serious consequences. Our continued success depends on your ability to make decisions that are consistent with our core values. Exercise honesty and integrity in everything you do, and know the Code. 6 OUR CODE OF BUSINESS CONDUCT AND ETHICS

9 what the code includes 7

10 are you committed to integrity and complying with law? Hay Group acts with integrity at all times by being honest, by following the law, and by treating others fairly and respectfully. our code We must deal fairly with all of our stakeholders, including our clients, employees, and service providers, as well as our competitors. We don t seek competitive advantage through illegal or unethical business practices, such as antitrust or unfair competition law violations. We don t offer or give money or gifts to any government official or political party or candidate for an illegal purpose. We don t violate our clients policies that do not permit the giving of gifts. your conduct Each of us must be dedicated to complying fully with the letter and spirit of the laws, rules, and regulations that apply to our business and countries in which we operate. No employee should take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or any unfair dealing practice. 8 OUR CODE OF BUSINESS CONDUCT AND ETHICS

11 every DAY ethics A company finance manager paid $50 to an employee of a government agency to ensure the timely processing of immigration papers for her new regional manager. She recorded the payment as a facilitating payment on the books of the company. The Code has been violated. Any official payment including de minimis payments to a government official, designed to exert influence over the official's duties are a code violation. A client asked a Hay Group consultant, as part of a project, to recommend a supplier of a service which is not offered by Hay Group. Some of the potential suppliers offered to pay a commission to Hay Group or to the consultant personally, if they were awarded the business. The consultant recommended one of the suppliers that offered a commission and asked for the commission to be paid to Hay Group. The Code has been violated. It was not fair dealing to recommend a supplier to a client based on the payment of a commission. The best approach would have been to disclose the commission to the client and pass the commission amount on to the client as a fee reduction. Hay Group employees may not personally accept commissions from suppliers under any circumstances, as the practice would be a conflict of interest. A Hay Group IT manager was offered an all-expense trip to attend a software vendor s user conference in exchange for the IT manager s participation on a panel discussing how Hay Group implemented the vendor s software. The Code will be violated if the Hay Group IT manager accepts the offer. Hay Group employees may not accept gifts or offers of entertainment from any suppliers as the practice would be a conflict of interest. do the right thing Our reputation and success depend on fair dealing. If you suspect anyone of not following the law it must be reported immediately. 9

12 are you for equal opportunity and against harrassment? We want to create a positive and rewarding environment, and have concern for the personal dignity and individual worth of every employee. our code We treat all employees and applicants by their qualifications, achievements and demonstrated skills, without regard to age, race, color, gender, religion, disability, national origin, veteran status, marital status or sexual orientation. We afford equal opportunity in regard to each individual's terms and conditions of employment, and in regard to any other matter that affects the working environment of the employee. We promote diversity in our employment practices. your conduct As part of the Hay Group team, it s all of our responsibility to treat others with respect and dignity and act responsibly. Harassment can take many forms and no type is tolerated. 10 OUR CODE OF BUSINESS CONDUCT AND ETHICS

13 every DAY ethics A 35-year old manager hired or promoted only younger employees in the belief that they were more computer savvy than older workers. The manager violated the Code. By making decisions about hiring or promoting employees based on their age instead of their actual qualifications, the manager acted improperly and illegally. The manager would be disciplined. As a joke, an employee hides a co-worker's desk keys, stationery, stapler, etc., once or twice a week. The employee gives them back at the end of the day, but the co-worker is often unable to complete essential tasks for the people he supports. The employee also poured the water in her drink bottle onto the co-worker's chair while he was at lunch one day. The employee is bullying the co-worker and has violated the Code. Bullying is unlawful in some countries and is not tolerated at Hay Group. A manager sent an inappropriate sexual joke to his team at work for a laugh. A few team members took exception to it. The manager violated the Code by forwarding the inappropriate material. Regardless of his intentions, this can constitute sexual harassment. do the right thing If you re aware of someone who is discriminating or has been discriminated against, reach out for help. 11

14 do you understand the significance of insider trading? Hay Group doesn t use confidential information for personal gain. our code Insider trading is both illegal and against our policy. We don t buy or sell shares or help others to buy or sell shares of companies, based on important confidential information, before such information is made available to the public. Material inside information may include mergers, acquisitions, financial results, or management changes. your conduct If you have material nonpublic information that you obtained by virtue of your position with Hay Group it s our policy that you may not take advantage of, or pass on to others, that information. You should also avoid discussion of sensitive information anywhere that others may hear it. Anyone who is uncertain about the rules involving insider trading must seek legal advice before making any purchase. 12 OUR CODE OF BUSINESS CONDUCT AND ETHICS

15 every DAY ethics A Hay Group consultant learns that her pharmaceutical client ABC is about to merge with its largest competitor. She buys shares in ABC before the news of the merger is made public. The consultant has violated both the Code and the securities laws on insider trading. The better result would have been to check with the Chief Compliance Officer before buying the shares, so she could have been advised against such violations. Supplemental The same Hay Group employee meets an old acquaintance who mentions that he is looking for good stock market investments and asks her views about companies in the pharmaceutical sector. She says that she works with ABC and thinks that it would be a good buy. She has violated confidentiality by disclosing the identity of one of Hay Group's clients. She has also violated the Code and the securities laws on insider trading, if she gave the stock tip before the merger was announced publicly. do the right thing Illicit trading is a serious offense and we cooperate fully with government investigations. If you become aware of any potential insider trading or tipping, you must report it immediately. 13

16 are you abiding by export controls? All Hay Group employees and offices are subject to export control regulations and embargo compliance laws. our code Our services are subject to export control regulations, including international embargo laws, even though we don t sell products as such. We can export our services to most clients in all countries, except those countries and persons in embargoed countries or in various designated terrorist support lists. A license may be required to sell our services in some cases. your conduct We all must abide by these laws. Adhering to appropriate regulations, policies, and procedures is the responsibility of the individual. You can take preventive measures by being educated, checking end users and uses, and asking for legal assistance and guidance when needed. 14 OUR CODE OF BUSINESS CONDUCT AND ETHICS

17 every DAY ethics A sales team recognizes an opportunity for the sale of services to Cuba. Knowing that Cuba is on the U.S. no trade list, the team leader reaches out to her colleague in Brazil and identifies the opportunity. This is a violation of the Code. Given the Hay Group corporate structure, all global offices must abide not only with U.S. trade regulations, but also with those of the UK, EU and other regions. A Hay Group employee discovers that an export violation may have occurred. She has a responsibility to always check and verify if she discovers a violation may have occurred. She does not report it because she is not sure of the regulation and they are no longer working with the client. The Code has been violated. Any potential export control regulation must be fully investigated. Disregard for compliance responsibilities or deliberate effort to hide or conceal violations can have serious consequences. do the right thing Please contact the legal department for additional information and support. 15

18 do you maintain confidentiality and privacy with all information trusted to you? Our employees often learn confidential, proprietary or private information about the firm, its clients, prospective clients, and other third parties. our code We must protect the privacy of employees and clients, maintaining the confidentiality and privacy of all information so entrusted to us, except when disclosure is authorized or legally mandated. Hay Group respects privacy rights and interests and provides safeguards for the protection of personal information that is collected, held and used. your conduct Confidential or proprietary information includes, among other things, any non-public information concerning the firm, including its businesses, financial performance, results and clients or prospects. It s very important to not share our client data. This data includes any non-public information provided by a third party with the expectation that the information will be kept confidential and used solely for the business purpose for which it was disclosed. 16 OUR CODE OF BUSINESS CONDUCT AND ETHICS

19 every DAY ethics A self-employed direct marketer had a friend who works at Hay Group and asked the employee to send him a list of all company addresses for use in his business. The Hay Group employee refused. The Hay Group employee did the right thing. The employee knew that the list of Hay Group employee addresses was confidential and it would have been a misuse of company assets to disclose them to help the friend. Supplemental The direct marketer convinced the Hay Group employee that the service offered could be of interest to a number of Hay Group employees. He sent the employee/friend an which the Hay Group employee forwarded to 20 senior colleagues. Convinced or not, this employee would have violated the Code. Even though the list of employee addresses was not disclosed, the Code violation was to use Company for personal not Company business. A Hay Group employee in Germany needed to send the results of interviews of a German client s employees to the Hay Group Boston office for assessment and processing. The interviews included some personal information, such as name, job title, salary and office address. The Hay Group employee knew the client signed a written agreement on privacy allowing the information to be shared internally at Hay Group for assessment and processing. The employee sent the information to Boston. No Code violation occurred. do the right thing If you re aware of a breach in confidentiality, please report the matter promptly. 17

20 can you be trusted with intellectual property? The most valuable assets of Hay Group are our brand and intellectual property (IP). our code We protect our copyrights, trademarks and trade secrets zealously. We respect the property rights of others, including their copyrights, trademarks, trade secrets, patents and know-how. your conduct We take every measure necessary to protect our IP. We also recognize that permission is required to use another person s intellectual property. Unauthorized copying of copyright protected works isn t permitted, and may subject us and the individual employees to legal liability. Every day, Hay Group employees create copyright-protected materials and make use of the copyright materials of others. Therefore, we must understand and adhere to basic principles of protection, including use of nondisclosure agreements, copyright registration, and compliance with laws. 18 OUR CODE OF BUSINESS CONDUCT AND ETHICS

21 every DAY ethics In his first week of work for Hay Group, an employee brought in a box containing a number of Hay Group s competitors salary surveys and copied some data from them and used them in writing a report for a Hay Group client. The employee violated the Code by using the intellectual property of another firm without permission. The employee would have been disciplined and the competitors copyrighted works would have been returned or destroyed. Supplemental The same employee left the competitors survey reports at his home and only referred to them in order to include in his report to the client a comment to the effect that although the Hay Group survey does not include data for this position, our knowledge of this market suggests the median salary is in the range of $45,000. The employee violated the Code by using another firm's intellectual property without authorization. It would not have been a copyright violation because no copies were made. If the employee was lawfully in possession of the reports, by purchase or otherwise, then there would have been no Code violation. A Hay Group employee was asked by a former Hay Group employee who started her own consulting firm to send her copies of the Hay Guide Charts for use in the former employee s new business. The Hay Group employee refused and reported the request to her supervisor and the Legal Department. No Code violation occurred. The Hay Group employee did the right thing. do the right thing If you suspect anyone of not treating our data or intellectual property with confidence, or the confidential or proprietary information of our clients, prospective clients, or third parties, it is your responsibility to report them. 19

22 do you use company resources responsibly? Company assets are provided for business use and should be first and foremost used to advance our business and strategic objectives. our code We understand that, where permitted by law, there is no expectation of privacy in our personal use of Hay Group assets including computer systems, telecommunications, Internet access, and any other Hay Group provided equipment and services. Hay Group reserves the right to inspect its facilities, property and company assets, both physical and nonphysical resources. your conduct We all must protect Hay Group's assets and ensure their efficient use. All our assets should be used for legitimate business purposes only. Any personal use of Hay Group assets must be incidental and insignificant in cost and time. We have a records management policy with which all employees must comply. We must preserve, and not change, hide or destroy any records that are subject to an investigation or which may be used in any official proceeding. 20 OUR CODE OF BUSINESS CONDUCT AND ETHICS

23 every DAY ethics A Hay Group employee used her less-busy work time and her lunchtime every day to surf the Internet on personal matters from her desk. Company records available to her IT Department revealed that she spent over 300 hours last year surfing the Internet. The employee misused company assets, namely the computer system. Excessive nonbusiness use of the company computer system was a Code violation. As part of personal political activities for a campaign, a Hay Group employee produces flyers and mails them using Hay Group equipment while at work. Use of Hay Group assets for political purposes is a violation of the Code. Participation must be on an individual basis using one's own money and time. do the right thing We must be vigilant against misuse or waste of company assets. Avoid improper behavior, and report anyone you suspect of acting improperly. 21

24 do you avoid conflicts of interest? A personal conflict of interest occurs when an individual s private interest interferes with the interests of Hay Group. our code Hay Group s interest must come before the personal gain of our employees. We seek to avoid even the appearance of a conflict of interest. Conflict of interest, in fact or appearance, can expose Hay Group to legal and/or reputational liability. your conduct We must never use or attempt to use our position at the firm to obtain any improper personal benefit for ourselves, our family members or any other person or entity. The best way to avoid a conflict of interest is to ask whose interests are served by a particular course of action. If the answer is that one's own interests are served over another stakeholder's, then you should avoid this in advance. 22 OUR CODE OF BUSINESS CONDUCT AND ETHICS

25 every DAY ethics A Hay Group consultant s spouse works for the local bank where Hay Group maintains a business account. The Hay Group consultant has no business dealings with the bank. The spouse has no business dealings with Hay Group. Must the consultant disclose the relationship? No. It is not a Code violation because no business relationship is affected by the spousal relationship. Supplemental A Hay Group consultant s spouse is the Vice President of Human Resources for a client of Hay Group. Neither spouse has any business dealings with each other. The supervisors of both spouses are aware of the situation. No Code violation, because there was no actual conflict of interest and the appearance of a conflict of interest was addressed by full disclosure to the respective supervisors. A Hay Group employee resigned effective at the end of the month. Prior to her final day of work, she held a training session on the subject of Emotional Intelligence for a company and received and kept the fee. The employee violated the Code by placing her personal interest above Hay Group s interest. She was still a Hay Group employee and the fee should have been paid to Hay Group. do the right thing If you re aware of a transaction or relationship that might cause a conflict of interest, please discuss the matter promptly. 23

26 are you accurate and ethical with compliance and reporting? We must try to identify and raise potential issues before they lead to problems. our code We have an obligation to the timely, accurate handling and reporting of information, and it is core to our commitment to doing business honestly and responsibly. All Hay Group employees are personally responsible for accurately managing any company-related funds that they control. Expenses must be categorized and submitted in a timely manner, and all sales transactions must be recorded. It is a violation of the Code to hide, falsify, or misrepresent data pertaining to the use of Hay Group funds. your conduct We have an obligation to provide information that is accurate, complete and objective. Every employee must ensure we receive good value and maintain accurate and timely records. 24 OUR CODE OF BUSINESS CONDUCT AND ETHICS

27 every DAY ethics An employee had reason to believe that his supervisor had submitted falsified time and expense reports. The employee reported the supervisor by using the Compliance Hotline. An investigation concluded that no falsification of time and expense reports had occurred. The supervisor suspected a particular person had reported him and later gave that employee a poor performance review. The supervisor violated the Code by retaliating against the employee whom the supervisor suspected of reporting him. The employee who reported the suspected violation did not violate the Code, because he had a reasonable belief that the supervisor had violated the Code provisions on Integrity and Fair Dealing by filing false time and expense reports, even if an investigation concluded otherwise. An employee is feeling pressured to alter the reporting of Hay Group's monthly financial results to "make the numbers work." He contacts his manager for guidance. The Hay Group employee did the right thing. It is a violation of the Code to provide financial information that is known to be false. Hay Group will take appropriate disciplinary action and will not retaliate against any person who reports suspected violations. do the right thing Anyone who becomes aware of an existing or potential violation of this code must promptly submit notification. Suspected violations of law or this code may be submitted anonymously. 25

28 do you think about how the information you share online might affect your colleagues or clients, and the hay group brand, reputation and confidentiality? Hay Group places a significant amount of value on connections and collaboration, and we expect everyone to strike the proper balance between personal freedom of expression and our legitimate interest in protecting our brand, reputation and computer systems. our code We are representatives of Hay Group on the web, and our actions on the web may reflect the company and the Hay Group brand, as well as those of our clients. The increasing use of social media to promote corporate products and services by all levels of employees raises a number of risks, and individuals who post messages on social media sites can be held liable for invasion of privacy or for making defamatory statements. your conduct The web is not anonymous. Assume that everything you write or post can be traced back to the company, if not you personally. On the web, there is no longer a clear boundary between your personal life and your work life. Do not lie or withhold the truth. The web contains a permanent record of mistakes. If you make a mistake, acknowledge it, correct it and move on. Client confidentiality is always paramount. Be honest, straightforward and respectful. 26 OUR CODE OF BUSINESS CONDUCT AND ETHICS

29 every DAY ethics Recent evidence of social media usage by some Hay Group employees, particularly the social network LinkedIn, indicates that Hay Group employees have given professional references to other current or former Hay Group employees. Certain employees have violated the Code because our Human Resources policy in some countries explicitly prohibits Hay Group employees from giving references to current or former Hay Group employees. A colleague tells you that she has read derogatory and offensive comments about her on Facebook that was posted by another colleague The colleague who posted the comments violated the Code. Harassment can take many forms including social media. Team members should exercise considerable care in using social media sites to make comments or conduct conversations about their managers or fellow colleagues. do the right thing We ought to be able to make our own decisions about what we should or should not say on the web, but social media should be used prudently and responsibly, without violating other Hay Group policies. 27

30 are you respectful of our office norms, behaviors, and well being? We re committed to providing a safe, healthy, and positive place to work. our code The safety and security of our employees comes first. Any unsafe conditions and acts or threats of violence will be acted on immediately. We recognize our duty to protect and respect our workplace and the environment. We treat our office spaces with dignity and are committed to practices that create a collaborative culture, protecting and promoting the well being of our colleagues and the environment. your conduct You preserve Hay Group s positive culture by treating people, property and our environment with courtesy and professionalism at all times. It is your duty to act responsibly and respectfully. Your commitment to health and wellness improves our places of work and productivity. We expect our employees to report to work free from the influence of any substance that could impair them from the safe and effective performance of their jobs. 28 OUR CODE OF BUSINESS CONDUCT AND ETHICS

31 every DAY ethics Hay Group leaders were planning an important meeting. Some wanted to meet in person and some felt that a virtual meeting was preferable. A personal meeting would have required multiple international airline flights and surface transport by cars or taxis. The majority decided that a virtual meeting was more in line with the Code. Although meetings requiring international travel for many persons are not a Code violation, the majority decision was more consistent with the Code objectives concerning being prudent and judicious with company resources. A team of colleagues convenes for a meeting at the last minute using a large conference room that they have not reserved but is not occupied. Thirty minutes into their meeting, they see the same colleague appear outside the door every few minutes but ignore him. After fifteen minutes, he knocks on the door and says he has the room reserved to set up for a client meeting that is starting in fifteen minutes. The team says they will finish up shortly. The team is violating the Code by being disrespectful of office norms and their colleague. They should have followed local procedure for reserving conference room space, and shown more consideration for the co-worker's meeting needs. do the right thing Concerns for the safety and security of our workplace should be reported immediately. If you or someone you know is being negatively impacted because of our office environment or the behavior of a colleague please reach out for support. 29

32 ask/report/share 30 OUR CODE OF BUSINESS CONDUCT AND ETHICS

33 raising a potential code violation When faced with a situation that may pose a violation of the Code, there are a few ways you can escalate the concern. You can always reach out to your manager, the Global Head of Legal or Global Head of Internal Audit. You can also any questions you have about the Code or report a potential Code violation by ing ethics@haygroup.com, or phone or write anonymously using the contact information below. You should never fear retaliation as we prohibit retaliation against anyone escalating a potential Code violation. We ll take reasonable measures to secure any data relating to an investigation of a Code violation and will also take reasonable measures to keep your identity private. This means that when you escalate a potential Code violation, you too will be expected to maintain the confidentiality of the investigation. Similarly, if you re part of an investigation, you ll need to keep the investigation confidential. code of conduct global contact information Phone: Mail: Hay Group Code of Conduct 1650 Arch Street Suite 2300 Philadelphia, PA USA ethics@haygroup.com 31

34 what situations or decisions have you faced? Share your experience to promote awareness and obligation with others to make the right choice. with your story and how you handled the situation. Help us build personal accountability and obligation with real examples of the everyday decisions our employees face. 32 OUR CODE OF BUSINESS CONDUCT AND ETHICS

35 notes: 33

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