2 Message from the chairman Dear Colleagues: The Hay Group Global Code of Business Conduct and Ethics (the Code ) is our company s statement of commitment to the highest standards of integrity and ethical behavior. Acting with integrity in all we do will serve all stakeholders of the company, including our employees, owners, clients, vendors and communities. The scope of the Code is global. It applies to all Hay Group employees, associates, independent contractors and directors. Although the Code covers many subjects, it is intended to provide general guidance. Compliance has been a part of Hay Group s over 65 years of existence. Compliance is a very important company policy and one that is directly related to our future success. By establishing a culture of compliance, we may avoid undue risk and potential liability, and maintain and increase the value of the company. Monitoring compliance helps us to improve quality of our service and our relationships with clients and colleagues. Hay Group is dedicated to not only achieving compliance with the laws affecting our business, but exceeding legal standards. If you have any questions after reading this Code, you may direct them to the Chief Compliance Officer, the General Counsel of Hay Group. Chris R. Matthews Chairman 2
3 Introduction Always act with integrity This Code of Business Conduct and Ethics (the "Code" or Code of Conduct ) 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. The Hay Group Whistleblower Policy is part of 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 nor every possible ethical issue that you may face. The Code 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. Each employee should read and become familiar with the Policy Guide, which is not part of the Code. Our managers must be the models of ethical behavior. The Hay Group Whistleblower Policy is part of the Code. If you have questions about this Code or are unsure whether it applies in a specific situation, please ask your manager or the Chief Compliance Officer. 3
4 Compliance with laws, rules, and regulations It is Hay Group s policy to comply with all applicable laws, rules and regulations. 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. The Policy Guide provides guidance as to certain of the laws, rules and regulations that apply to Hay Group's activities. 4
5 Insider trading Hay Group does not use confidential information for personal gain. Insider trading is both illegal and against our policy. We do not buy or sell shares or help others to buy or sell shares of companies, based on important secret information before such information is made available to the public. Material inside information may include mergers, acquisitions, financial results, or management changes. Anyone who is uncertain about the rules involving insider trading must consult with the Chief Compliance Officer before making any purchase or sale of shares or debt. 5
6 Insider trading sample situations 6
7 Intellectual property The single most valuable asset of Hay Group is our brand. We have established the goodwill of the Hay Group brand over our 65 years of acting with integrity as trusted advisors to clients. We protect our copyrights, trademarks and trade secrets zealously. Hay Group respects the property rights of others, including their copyrights, trademarks, trade secrets, patents and know-how. Our employees understand that unauthorized copying of copyright protected works is not permitted, and may subject Hay Group and the individual employees to legal liability. We recognize that permission is required to use another person s intellectual property. 7
8 Intellectual property sample situations 8
9 Confidentiality and privacy Hay Group employees often learn confidential, proprietary or private information about the firm, its clients, prospective clients and other third parties. Employees must maintain the confidentiality and privacy of all information so entrusted to them, except when disclosure is authorized or legally mandated. Confidential or proprietary information includes, among other things, any non-public information concerning the firm, including its businesses, financial performance, results or prospects. It also 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. Employees must protect the privacy of other employees and clients. Hay Group employees understand that we should not expect privacy when using the Hay Group computer systems, telecommunications, Internet access, and other equipment and services on the job. We acknowledge Hay Group reserves the right to inspect its facilities and property. Employees should refer to the policies set forth in the Policy Guide under Confidential or Proprietary Information. 9
10 Confidentiality and privacy sample situations 10
11 Personal conflicts of interest A personal conflict of interest occurs when an individual's private interest interferes with the interests of Hay Group. An employee must never use or attempt to use his or her position at the firm to obtain any improper personal benefit for himself or herself, for his or her family members, or for any other person, from any person or entity. 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. Any employee who is aware of a transaction or relationship that might give rise to a conflict of interest should discuss the matter promptly with the appropriate Human Resources Department or the Chief Compliance Officer. 11
12 Personal conflicts of interest sample situations 12
13 Corporate opportunities Employees owe a duty to Hay Group to advance Hay Group's legitimate business interests when the opportunity to do so arises. Employees are prohibited from taking for themselves or for a third party any business opportunity that arises through the use of corporate property, information or position, unless Hay Group has already been offered the opportunity and rejected it. Employees are prohibited from using Hay Group property, information or position for personal gain or competing with Hay Group for business. SAMPLE 13
14 Integrity and fair dealing Hay Group acts with integrity at all times by being honest, by following the law, and by treating others fairly and respectfully. Our reputation and success depend on fair dealing. Hay Group does not seek competitive advantage through illegal or unethical business practices, such as antitrust or unfair competition law violations. Each employee must deal fairly with all of our stakeholders, including Hay Group s clients, employees, and service providers, as well as our competitors. We do not offer or give money or gifts to any government official or political party or candidate for an illegal purpose. We do not violate our clients policies that do not permit the giving of gifts. No employee should take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or any unfair dealing practice. Hay Group recognizes that information about competitors, customers and suppliers is a valuable asset. We obtain such information legally. We do not seek such competitive information from the current or former employees of our competitors. 14
15 Integrity and fair dealing sample situations 15
16 Equal employment opportunity and harassment Hay Group has concern for the personal dignity and individual worth of every employee. Harassment is not tolerated. SAMPLE Hay Group treats all applicants and employees 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. Please refer to the Policy Guide. 16
17 Protection and proper use of company assets All employees must protect Hay Group's assets and ensure their efficient use. All Hay Group 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. Hay Group has 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. Please refer to the Policy Guide. SAMPLE SITUATION 17
18 Environment, safety, and health SAMPLE SITUATION Hay Group is committed to providing a healthy and safe place to work. We are committed to promoting practices that protect the environment. We believe in being good stewards of the world in which we work and live. 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. 18
19 Compliance and reporting Employees must try to identify and raise potential issues before they lead to problems. Any employee who becomes aware of any existing or potential violation of this Code must promptly notify the Chief Compliance Officer. Employees may report suspected violations of law or this Code anonymously. Hay Group will take appropriate disciplinary or preventive action to address any reported existing or potential violation of this Code. Hay Group will not retaliate against any person who reports suspected violations of law or this Code. It is a violation of this Code to submit a report that is known to be false. Any questions relating to how this Code or the policies in the Policy Guide work should be addressed to the Chief Compliance Officer. Refer to the Policy on Reporting Suspected Violations of Law or Company Policy. SAMPLE SITUATION 19
20 Audit function organizational chart 20
21 Violations template If you are aware of any conduct that may be in violation of the Code, please see the Whistleblower Policy attached below We will keep all information as confidential as possible during the course of our investigation Retaliation is not tolerated 1
22 Reporting Suspected Violations of Law or Company Policy (Whistleblower Policy) Procedure The Company has developed these procedures to fulfill its responsibilities and to ensure that any complaints concerning suspected violations of law or Company policy, including our Code of Conduct, are promptly and effectively addressed. The term Hay Group or the Company as used in this Policy shall mean HG (Bermuda) Limited and its global subsidiaries and affiliates. Definitions 1. Accounting Matters includes, without limitation, (i) fraud, deliberate error or misrepresentation in the preparation, evaluation, review or audit of any financial statement of the Company, (ii) fraud, deliberate error or misrepresentation in the recording and maintaining of financial records of the Company, (iii) deficiencies in or noncompliance with the Company s internal accounting controls, (iv) misrepresentations or false statements to or by a senior officer or accountant regarding a matter contained in the Company s financial records, financial reports or audit reports, (v) deviation from full and fair reporting of the Company s financial condition. 2. Complaints include any adverse information provided to the Company, whether in the form of a concern, a demand for remedial action, or a report of a suspected violation of any law or Company policy, including but not limited to, Accounting Matters. 3. Violation means any act or omission by an employee that is against the law or Company policy. Submission of Complaints 1. An employee who has a good faith belief that a violation of law or Company policy may occur, is occurring or has occurred, has a duty to report it under this Policy, except in those countries whose laws prohibit the placement of such a duty on employees. 2. An employee may submit a Complaint to the General Counsel or through the customary internal channels, namely, to the persons identified for that purpose in the applicable Company policies, or to the employee s manager or the country General Manager, except where such individuals are the subject of the Complaint, then to the General Counsel. For clarity, all suspected Violations of U.S. criminal laws must be reported to the General Counsel.
23 3. Complaints, including Complaints by non-employees, may be submitted to the General Counsel of Hay Group in any of the following ways: - Telephone: a U.S. toll-free number ( ) is available at all times (the Compliance Hotline ), or directly to the General Counsel at ; - Complaints may be forwarded to the General Counsel of Hay Group and - Mail: Complaints may be mailed directly to the General Counsel at the address below or submitted to any Hay Group office in a sealed envelope, which envelope shall be forwarded unopened to the General Counsel, by interoffice mail, regular mail or other means of delivery, addressed as follows: Private and Strictly Confidential Attention: General Counsel Hay Group, Inc. 100 Penn Square East Philadelphia, Pennsylvania , USA Complaints should contain as much specific information as possible. Anonymous Complaints are permitted. Treatment of Complaints 1. Upon receipt of a Complaint by the General Counsel, the General Counsel will (i) determine whether the complaint pertains to Accounting Matters, and (ii) when possible, acknowledge receipt of the Complaint to the sender. 2. Assessment, investigation and evaluation of Complaints shall be conducted by, or at the direction of the General Counsel or the Audit Committee. 3. Complaints relating to Accounting Matters will be reviewed under Audit Committee direction and oversight by the General Counsel, Internal Audit or such other persons as the Audit Committee determines to be appropriate. Confidentiality will be maintained to the extent possible, consistent with the need to conduct an adequate review. 4. The General Counsel shall inform the Audit Committee of all Complaints received by the General Counsel, with an initial assessment concerning each Complaint. The General Counsel shall have the ability to consult with any member of management who is not the subject of the alleged Violation and who may have appropriate expertise or 2/4
24 knowledge to assist with the investigation. 5. All Complaints and all related data shall be collected and managed in accordance with all applicable data protection and privacy laws. 6. The General Counsel shall report to the Audit Committee periodically about the process for receiving Complaints, so that the Committee can ensure that the process is satisfactory in its efficiency, accuracy, and timeliness, protection of confidentiality, and effectiveness. Legal or other requirements may not allow for complete anonymity. 7. Prompt and appropriate corrective action will be taken when and as warranted in the judgment of the Audit Committee. 8. The Company will not discharge, demote, suspend, threaten, harass, retaliate or in any manner discriminate against any employee based upon any lawful actions taken by such employee with respect to any good faith reporting of Complaints. 9. The Company may take disciplinary action against any employee who violates this Policy, acts in bad faith or misuses this Policy. Compliance with local laws Where required by the applicable local law: 1. Scope: Complaints from employees shall be limited to Accounting Matters and other substantial misconduct that affect the vital interests of the Company, and must describe all facts as alleged. 2. Notice: The person to whom the Complaint is made shall provide prompt written notice to the person alleged to have violated this Policy, unless doing so would pose a substantial risk to the evidence gathering process or for other legitimate interests of the Company. 3. Deletion: Complaints determined to be unfounded shall be promptly closed and related data deleted permanently. Personal data must be deleted two months after the close of a Complaint, unless the investigation remains open or disciplinary action has been taken against an unfounded Complaint. 4. Translation: Translations shall be made of this Policy and related communications to the employees. 5. Notification: The local data protection authority or other authority shall be notified of this Policy and the Company shall notify and coordinate with the applicable works council concerning this Policy. 3/4
Code of Business Conduct and Ethics Table of Contents Purpose... 1 Scope... 1 Policy... 2 Responsibilities... 8 Enforcement... 8 Review and Revision... 8 PURPOSE Pursuant to the Sarbanes-Oxley Act of 2002
ASSOCIATED BANC-CORP CODE OF BUSINESS CONDUCT AND ETHICS Introduction This Code of Business Conduct and Ethics covers a wide range of business practices and procedures. It does not cover every issue that
2018 CODE OF BUSINESS CONDUCT AND ETHICS REPORT A VIOLATION To report a violation of conduct or ethics, please call the EthicsPoint Hotline: 1 (866) 294-5534 CENTRAL HUDSON 284 South Ave. Poughkeepsie,
(as of January 28, 2013) Introduction This sets forth the guiding principles by which we operate Computer Programs and Systems, Inc. (the Company ) and conduct our daily business with our stockholders,
Robert W. Best Chairman, President and CEO Message to All Directors, Officers and Employees of Atmos Energy Corporation The Atmos Energy Corporation Code of Conduct begins with our deep commitment to fairness,
1. Introduction CODE OF BUSINESS CONDUCT AND ETHICS FRONTIER AIRLINES, INC. Adopted May 27, 2004 The Board of Directors adopted this Code of Business Conduct ( Code ) to establish basic legal and ethical
R1 RCM Inc. (hereafter, R1 or the Company ) is committed to the conduct of its business in an ethical, legal, and transparent manner. In turn, the Company expects that all employees, contractors and vendors
September 2003 BIG LOTS, INC. CODE OF BUSINESS CONDUCT AND ETHICS Introduction This Code of Business Conduct and Ethics covers a wide range of business principles to guide all directors, officers and associates
1. Policy Statement CRC HEALTH GROUP, INC. CRC HEALTH CORPORATION CODE OF BUSINESS CONDUCT AND ETHICS It is the policy of CRC Health Group to conduct its business affairs honestly and in an ethical manner.
Atlas Financial Holdings, Inc. Code of Business Conduct & Ethics TABLE OF CONTENTS 1. INTRODUCTION... 3 2. WHO IS COVERED... 3 3. DIRECTOR, OFFICER AND EMPLOYEE OBLIGATIONS... 4 4. CONFLICTS OF INTEREST...
FOUNDATION BUILDING MATERIALS, INC. EMPLOYEE CODE OF CONDUCT Foundation Building Materials, Inc. (the Company ) conducts its business in accordance with the highest ethical standards of corporate leadership
Southwest Airlines Co. Code of Ethics Introduction Southwest Airlines Co. is committed to maintaining the highest standards of ethical business practices and legal and regulatory compliance. We place a
1 ST FRANKLIN FINANCIAL CORPORATION CODE OF BUSINESS CONDUCT AND ETHICS Introduction This Code of Business Conduct and Ethics ( Code ) describes the basic principles of conduct that we share as officers
LIVING OUR CORE VALUES Supplier Code of Conduct Introduction to Our Supplier Code of Conduct Chesapeake Energy is committed to living our core values of integrity and trust, respect, transparency and open
1. Policy Statement ROOT9B HOLDINGS, INC. CODE OF BUSINESS CONDUCT AND ETHICS The Nasdaq listing standards require that the Company provide a code of conduct for all of its directors, officers and employees.
FANUC AMERICA CORPORATION Code of Business Conduct A Message from the President & CEO: Responsibility, trust, respect, and integrity these values represent the history and foundation of FANUC America Corporation.
November 2012 DHT HOLDINGS, INC. CODE OF BUSINESS CONDUCT AND ETHICS Introduction This Code of Business Conduct and Ethics (the Code ) summarizes the values, principles and the business practices which
AMETEK, Inc. Code of Ethics and Business Conduct Code of Ethics and Business Conduct A Message from the Chairman of the Board and Chief Executive Officer Dear AMETEK Colleague: AMETEK has been in business
Straumann Code of Conduct PREFACE As a global leader in implant dentistry and dental tissue regeneration, Straumann respects laws and regulations. Apart from these obligations, there are numerous voluntary
Code of Business Conduct Our reputation as a company is one of our most important assets. Our reputation needs to be managed and developed with the same care we extend to our products. This means all of
CODE OF BUSINESS CONDUCT AND ETHICS The Board of directors (the Board ) of The Rubicon Project, Inc. (the Company ) has adopted the following Code of Business Conduct and Ethics (the Code ) for directors,
CODE OF ETHICS AND BUSINESS CONDUCT 1.0 SCOPE This Code of Ethics and Business Conduct (the Code of Conduct ) is implemented by the Board of Directors (the Board ) of Dominion Diamond Corporation and applies
Morgan Stanley Code of Ethics and Business Conduct A bout This Code Updated as of July 2017 This Code of Ethics and Business Conduct (Code of Ethics) is a statement of Morgan Stanley s commitment to integrity
URAC Code of Conduct December 10, 2015 Table of Contents I. Introduction... 3 II. URAC Values and Business Ethics... 3 Values... 3 Business Ethics... 3 III. Compliance with Laws and Regulations... 4 IV.
DOUBLE-TAKE SOFTWARE, INC. CODE OF BUSINESS CONDUCT AND ETHICS This Code of Business Conduct and Ethics covers a wide range of business practices and procedures and serves as a guide to ethical decision-making.
QOGNIFY LIMITED CODE OF ETHICS AND BUSINESS CONDUCT Adopted and Approved by the Board of Directors on November 8, 2016 Code of Ethics and Business Conduct I. ETHICS AND BASIC PRINCIPLES... 1 II. CONFIDENTIALITY...
Hershey Entertainment & Resorts Company Proudly Committed to our Legacy of Excellence Code of Conduct & Ethics October 22, 2009 Revised September 20, 2017 Hershey Entertainment & Resorts Company Code of
TDC WHISTLEBLOWER POLICY May 1 2016 St. Kitts Nevis Anguilla T rading and Development Company Limited (T DC Ltd and Subsidiaries- hereinafter referred to as the Com pany ) Table of Contents A. Introduction..
1. Purpose This Code is intended to govern the conduct of Clean Harbors, Inc. and all of its subsidiaries Vendors when doing business with or on behalf of Clean Harbors, Inc. For the purpose of this Code,
AdvancePierre Foods, Inc. CODE OF CONDUCT AdvancePierre Foods, Inc. and its subsidiaries (collectively, the Company ) is committed to its employees, key stakeholders, brokers, customers and the communities
Revised and Reissued August 2015 TAP AUTOMOTIVE HOLDINGS, LLC TAP WORLDWIDE, LLC / TAP MANUFACTURING, LLC Code of Conduct and Business Ethics THIS POLICY DOES NOT CREATE AN EXPRESS OR IMPLIED EMPLOYMENT
Samsung Telecommunications America, LLC Supplier Code of Conduct - Partners in Integrity STA Strategic SRM 10/1/2013 Rev. C Samsung Telecommunications America, LLC ( STA or Samsung Telecommunications America
Code of Conduct & Ethics Interfor Code of Conduct & Ethics Contents Page 1 CEO Message A Message from our CEO 2 Our Code of 2 Conduct & Ethics Our Code of Conduct & Ethics 3 3 Guiding Principles Guiding
Code of Business Conduct and Ethics Table of Contents The O Reilly Culture... 1 Introduction... 2 Administration... 3 Compliance Procedures... 3 Reporting of Illegal or Unethical Behavior... 3 Report Misconduct...
Ethics SouthernStyle CODE OF ETHICS E t h i c a l B e h a v i o r i s o u r S t a n d a r d Our Code of Ethics advises us on proper business conduct. It links our values Southern Style to the company s
September 2015 CUSHMAN & WAKEFIELD GLOBAL CODE OF BUSINESS CONDUCT Letter from the Chairman and Chief Executive Officer Dear Colleagues: Cushman & Wakefield and all of the firms that come together under
SCOPE Conduent Business Services, LLC and its subsidiaries provide this policy as a guide for employees. This policy applies to all employees of Conduent Business Services, LLC and its subsidiaries and
CEO Message Embedded in Eversource s mission to safely deliver reliable energy and superior customer service is our commitment to conduct ourselves ethically, respectfully and honestly. Eversource s Code
WELLTOK, INC. CODE OF BUSINESS CONDUCT AND ETHICS As Adopted by the Board of Directors and Audit Committee on May 3, 2016 I. INTRODUCTION Welltok, Inc. ( Welltok and together with its subsidiaries, the
CODE OF ETHICS AND CONDUCT PREFACE Green Mountain Power s Code of Ethics and Conduct is about doing the right thing acting honorably, treating each other with respect, and following the law. It s built
KIMBELL ROYALTY PARTNERS, LP CODE OF BUSINESS CONDUCT AND ETHICS (Adopted on January 24, 2017) Introduction This Code of Business Conduct and Ethics and all the policies and procedures adopted by Kimbell
THE YANKEE CANDLE COMPANY, INC. Code Of Business Conduct And Ethics This Code of Business Conduct and Ethics (the Code ) is designed to provide guidance and ethical standards of conduct for all directors,
Version Status (Draft or Approved) Scope of Application (Who Does This Apply To) CRONOS GROUP INC. CODE OF BUSINESS CONDUCT AND ETHICS 2018A Approved All employees of Cronos Group Inc. ( Cronos Group or
CODE OF CONDUCT DESCRIPTION Schneider has adopted the following Code of Conduct ( Code ) to apply to Schneider s directors, officers, managers and associates. While no code or policy can anticipate every
MARICOPA INTEGRATED HEALTH SYSTEM Code of Conduct and Ethics Date: November 12, 2015 11.12.2015 Page 1 Code of Conduct and Ethics Revised and Effective November 12, 2015 I. PURPOSE This Code of Conduct
The Molina Healthcare Code of Business Conduct and Ethics The Board of Directors of Molina Healthcare, Inc. has adopted this Code with respect to the business conduct and practices governing the affairs
CODE OF ETHICS & CONDUCT 1 INTRODUCTION Integrity, responsibility and honest, ethical business conduct are core values of the Carlsberg Group. This Code of Ethics and Conduct (the Code ) supports our strategy
MiMedx Group, Inc. Code of Business Conduct and Ethics 1. Introduction. 1.1 The Board of Directors of MiMedx Group, Inc. (together with its subsidiaries, the "Company") has adopted this Code of Business
MODA HEALTH CODE OF CONDUCT I. Introduction Moda Health has a longstanding tradition of caring for our members, communities, and employees. We strive to act with absolute integrity in the way we do our
Intuit Supplier Code of Conduct At Intuit we simplify the business of life. We invent solutions to important problems. We innovate. This is what we strive for every day, and we truly value the role our
Business Conduct Requirements for Representatives and Channel Partners www.qorvo.com Qorvo, Inc. and its affiliates ( Qorvo ) are committed to the highest standards of business conduct and ethics and expect
CyberOptics is committed to the highest standards of legal and ethical business conduct. This Code of Business Conduct and Ethics summarizes the legal, ethical and regulatory standards that CyberOptics
VOYA Financial CODE OF BUSINESS CONDUCT AND ETHICS Version 2.0 April 2014 Information Sheet ISSUED BY Voya Financial Compliance TARGET AUDIENCE All Voya Financial Directors and Employees OWNED AND APPROVED
CODE OF CONDUCT FOR DOING BUSINESS WITH LINKEDIN TABLE OF CONTENTS INTRODUCTION 1 Expectations LINKEDIN VALUES 2 MAINTAINING BUSINESS INTEGRITY 3 Anti-Corruption Competition Laws PROMOTING TRANSPARENCY
CARNIVAL CORPORATION & PLC Business Partner Code of Conduct and Ethics A Letter from our CEO Building and maintaining trust in our business relationships and pursuing the highest standards of ethical behavior
ve Fun Through Work AES Values Guide From Words to Action OUR CODE OF CONDUCT EXCELLENCE FUN AGILITY INTEGRITY SAFETY Dear AES People, At AES, it s what brings us together that makes us unique as a company.
Securitas Values and Ethics Code 1. General Principles Abiding by laws, maintaining high ethical standards and upholding our shared values play a prominent role in all of Securitas operations and provide
Corporate Code of Business Conduct and Ethics A MESSAGE FROM OUR CHAIRMAN, PRESIDENT AND CHIEF EXECUTIVE Honesty and integrity are paramount values at TRC. Our commitment to strict ethical standards has
Code of Conduct Letter From Crown s President Crown s reputation for integrity is built not only on the quality of Crown s products and services but also on Crown s employees history of honest, ethical
THE CHARLES SCHWAB CORPORATION CODE OF BUSINESS CONDUCT AND ETHICS Table of Contents Page Introduction 1 Ethical Behavior and Legal Compliance 1 Ethical Behavior 1 Compliance with Laws, Rules, Regulations
INTERWORLD SRL FREIGHT FORWARDING CO. CODE OF CONDUCT INTERWORLD SRL INTERNAL CODE OF CONDUCT INDEX A. Letter From Simone Rovida, Managing Director Page 3 B. International Code of Conduct Page 4. MANAGING
FROM LANDING TO TAKE OFF: WE CARE! CODE OF CONDUCT ETHICAL BEHAVIOUR GUIDELINES FOR THE SWISSPORT GROUP INFORMATION FROM THE CEO Swissport International Ltd. and its subsidiaries (collectively, Swissport
Code of Business Conduct and Ethics Contents: 1. Introduction: Philosophy Underlying This Code 2. 10 Principles: principles that establish a framework and provide guidance to all employees on how to ensure
EXACT SCIENCES CORPORATION Code of Business Conduct and Ethics A MESSAGE FROM THE BOARD OF DIRECTORS At Exact Sciences Corporation (collectively with its subsidiaries, the Company ), we believe that conducting
HEALTH CARE REIT, INC. CODE OF BUSINESS CONDUCT & ETHICS Overview The following principles support and guide our leadership in establishing the strategic direction of Health Care REIT, Inc. ( HCN ). Our
Code of Conduct 1 INTRODUCTION 1.1 Purpose and scope of this document Finnair is an iconic national airline and a respected member of the international aviation community with a solid reputation in safety,
JANUARY 2017 GLOBAL CODE OF BUSINESS CONDUCT Letter from the Chairman and Chief Executive Officer Dear Colleagues: Cushman & Wakefield and all of the firms that come together under this iconic brand, have
Code of Conduct V. 2.0 - November 2017 A word from our CEO Marcos França CEO Lhoist Group Dear all, For more than 125 years, our family-owned business in lime, dolime and mineral products has been combining
PERION NETWORK LTD. CODE OF BUSINESS CONDUCT AND ETHICS February 2017 TABLE OF CONTENTS Page POLICY STATEMENT... 1 APPROVALS AND WAIVERS; AMENDMENTS; INTERPRETATION... 2 CONFLICTS OF INTEREST... 2 BUSINESS
ETHICS POLICY Contents 1. APPLICATION... 2 2. POLICY REQUIREMENTS... 2 Fundamental Principles... 2 Respectful Workplace... 2 Use of EPCOR Property and Resources... 2 Appropriate Use of Technology and Electronic
W.W. GRAINGER, INC. Business Conduct Guidelines May 2017 To All Employees: One of the core pillars of our Growth Map is to be responsible stewards of our business. This means that Grainger and all of our
MV Transportation, Inc. Code of Conduct This Code of Conduct ( Code ) has been adopted by the Board of Directors of MV Transportation, Inc. (the Company ) as the ethics and business code of conduct for
INTEGRITY AT TURTLE & HUGHES Business Ethics Code of Conduct TSI CORE VALUES These seven core values are our foundation. They define our culture and who we are as people and as a company. They set us apart
Securitas Values and Ethics 1 Message from the CEO Every day, everywhere where we operate, everyone at Securitas can help build our reputation and brand and promote long-term sustainability and growth.
Securitas Values and Ethics 1 2 Message from the CEO Every day, everywhere where we operate, everyone at Securitas can help build our reputation and brand and promote long-term sustainability and growth.
* SAKURA Rules * (Code of Conduct for the Terumo Group) Terumo Corporation TABLE OF CONTENTS Chapter1. Introduction...2 1.1 Objectives 1.2 Definitions 1.3 Scope of Application of the SAKURA Rules 1.4 Inquiries
Computershare Group Code of Conduct A Message from the President & CEO Underpinning everything we do as a business are our three core values: Certainty: to deliver our services and solutions right first
CODE OF CONDUCT Version 3 August 2016 Table of Contents 1. INTRODUCTION... 3 2. COMPLIANCE WITH LOCAL LAWS AND REGULATIONS... 3 3. FAIR COMPETITION... 4 4. ANTI BRIBERY AND ANTI CORRUPTION... 4 5. WORKING
CODE OF CONDUCT Document Management This document is available in multiple languages and may be updated from time to time. For the avoidance of doubt, it is therefore explicitly mentioned that the English
OPG Supplier Code of Conduct Safety Integrity Excellence People and Citizenship Ontario Power Generation is an Ontario-based electricity generation company whose principal business is the generation and
CONFLICT OF INTEREST STATEMENT AND DISCLOSURE This statement is a summary of the Boyd Gaming Code of Business Conduct and Ethics and the Boyd Gaming policy regarding fraternization. For a complete version
CODE OF ETHICS FOR CHIEF EXECUTIVE OFFICER AND SENIOR FINANCIAL OFFICERS OF UGI CORPORATION Introduction The reputation for integrity of UGI Corporation (the Company ) is a valuable asset that is vital
CODE OF BUSINESS CONDUCT OUR PRINCIPLES OF ACTION OUR PRINCIPLES OF ORGANIZATION OUR POLICIES Code of business conduct Code of business conduct Contents 01 Introduction 02 Compliance with laws and regulations
Supporting Otsuka Supplier Code of Ethics and Professional Conduct Otsuka America Pharmaceutical, Inc. (OAPI) Otsuka Pharmaceutical Development & Commercialization, Inc. (OPDC) Otsuka Maryland Medicinal