Conflicts of Interest

Every person at CIRI must make business decisions in the best interest of CIRI and not be unduly influenced by any circumstances or individual(s) that may compromise the interests of our organization. Conflicts of interest may occur if a person at CIRI or his or her relative has an outside business interest with or a significant financial investment in a CIRI supplier, business partner, or competitor; or if a person at CIRI accepts outside employment that adversely affects his or her work performance for CIRI, uses CIRI assets for personal or outside business gain, and/or is influenced by personal relationships or considerations when making decisions on behalf of CIRI.

Even the appearance of a conflict of interest can be harmful to CIRI. Accordingly, it is the responsibility of each person at CIRI to disclose potential conflicts of interest and to take reasonable steps to minimize or eliminate them where possible. If you have any question about whether or not you are involved in an activity or relationship which may be a conflict of interest, or you are currently involved in a situation or circumstance that reasonably could appear to be a conflict of interest, talk to the Legal Department so that a determination can be made about the situation and appropriate action can be taken to resolve any potential conflict of interest in a manner that is in your and CIRI's best interest.

Corporate Opportunities

Every person at CIRI is responsible for advancing the legitimate interests of CIRI when the opportunity arises. In this regard, people at CIRI are prohibited from competing with CIRI, or taking for themselves personal opportunities that are discovered through the use of CIRI property, information, or position.

Gifts and Favors

The giving and receiving of gifts (including entertainment) and favors in a business setting is often a part of ordinary business practice. Generally, business gifts are used to build goodwill and strengthen business relationships. However, great care must be taken to avoid even the appearance of impropriety or any attempt to compromise the judgment of the receiver. A gift or favor must never be given or accepted with the intent to influence, or appear to influence, business decisions or obligate the recipient. People at CIRI may give and accept gifts if the gift complies with both the giver and receiver's policies, is legal, and was not solicited. CIRI encourages the use of good judgment and discretion when accepting and giving gifts, based on these principles. If you have questions regarding a gift or favor, consult with the Legal Department.

Partner Selection Management

In our selection of business partners, CIRI seeks to establish relationships with business partners whose business conduct, interests, and activities will strengthen our future success and add to our continued viability as an organization. We manage these relationships with integrity and in full compliance with all applicable laws, rules, and regulations. Anyone establishing a business relationship should consult with the Legal Department to ensure that partners meet these expectations.

Vendor Selection Management

CIRI selects its vendors on the basis of objective criteria including, but not limited to, product/service quality, cost/price, ability to meet schedules and deliver commitments, flexibility, and technical excellence. Purchasing decisions are made solely on the ability of the vendor to meet CIRI's business needs and not on personal friendships or other non-business-related criteria. In outsourcing, contract negotiation, and business relationship management, we will always adhere to the highest standards of ethical behavior and legal compliance and seek to establish mutually beneficial business relationships. We never accept incentives such as bribes or kickbacks in return for a vendor's business.

Protecting the Environment

CIRI has a firm commitment to care for and protect its natural resources. Without compromising its obligations to responsibly develop and manage CIRI's resources, CIRI conducts its business activities in a manner which respects, preserves, and enhances the quality of the environment. CIRI operates its business activities in full compliance with federal, state, and local environmental laws, rules, and regulations.

Media Relations

It is important that the public receive factual information about CIRI and the matters that affect our organization. In order to prevent the inadvertent disclosure of confidential information, assure the consistency and accuracy of information, and allow for the continuation of CIRI's favorable public image and reputation, all inquiries from the media should be directed to CIRI's Public Relations Department for a response.

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