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Company Overview
Business Strategies
Minority Businesses
Board of Directors
Senior Management
Financial
Highlights
Ethics and Compliance
Key Projects

Code of Business Ethics and Compliance

Mission

The mission of CIRI is to promote the economic and social well-being and Alaska Native heritage of our shareholders, now and into the future, through prudent stewardship of the Company's resources, while furthering self-sufficiency among CIRI shareholders and their families. We will continue to achieve this mission by staying true to our values.

CIRI's Business Ethics and Compliance Program and our Code of Business Ethics and Compliance have been developed to provide a clear and common understanding of our values and the legal and ethical expectations that we have for the conduct of CIRI's business activities. The Code has been written to help us put those values into action. Although we know that no written document can ever guarantee anyone's individual behavior, acting ethically and with integrity is a decision all of us must make and demonstrate each day in every one of our activities and interactions.

While our Code cannot cover every situation we may encounter, it is a guide, along with our more detailed policies and procedures, for our daily conduct at CIRI. If you have questions about business ethics or a compliance concern, I encourage you to discuss the issue openly and candidly with your manager, any member of CIRI management, the Legal Compliance Manager, or by calling our Business Ethics and Compliance Assistance Line at (888) 228-7798.

I have great confidence that we will continue to conduct our business with the highest ethical and legal standards. This is a commitment we must continue to keep for ourselves, our business and, most importantly, for our shareholders.

Sincerely,

Margaret L. Brown

President and CEO

Table of Contents

Mission

Values into action

Ethical Conduct

Commitment to compliance
Fair competition and antitrust laws
Insider trading
Intellectual property
International business
Political participation
Regulatory investigations,
inspections and requests for
information

Integrity

Fair dealing
Financial integrity
Documents and records
Use, management and protection of assets and technical resources
Confidential information
Conflicts of interest
Corporate opportunities
Gifts and favors
Partner selection management
Vendor selection management
Protecting the environment
Media relations

Respect for shareholders and descendants

Shareholder relations
Shareholder communications

Corporate citizenship

Social responsibility
Corporate giving
Health and social services

Cultural heritage

Preservation
Contribution

Employee and Board excellence

Cooperation
Loyalty
Accountability
Equal employment opportunity
Anti-harassment
Health and safety
Drug free workplace
Privacy

CIRI's Business Ethics and Compliance program

Program administration
How to request guidance or report a concern
Enforcement of the Code of Business Ethics and Compliance
 
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