Program Administration

CIRI's Business Ethics and Compliance Program has been developed and implemented to communicate CIRI's commitment to its values, ethical business conduct, and strict compliance with all applicable laws, rules, and regulations. The Legal Department is responsible for the Program's administration and the Senior Vice President, Land & Legal Affairs serves as CIRI's Compliance Officer. In this capacity, the Compliance Officer reports directly to the President and CEO or, in the event of a conflict, the Chairman of the Board and the Board's Executive Committee. CIRI's Legal Compliance Manager has the responsibility of managing the day-to-day activities of the program. The Program and Code of Business Ethics and Compliance have the enthusiastic support of the Board of Directors.

How to Request Guidance or Report a Concern

It is the right and responsibility of every CIRI employee to seek guidance about business ethics and compliance issues when he or she is uncertain about what action to take and to immediately report actual, planned, or suspected violations of the Code, regulatory requirements, and CIRI's policies, procedures, and practices.

If you have a question, concern, or wish to report a possible violation of CIRI's standards, you may speak about the situation with your supervisor, any member of CIRI management, the Legal Compliance Manager, or call the Business Ethics and Compliance Assistance Line at (888) 228-7798. You may also write to the Legal Compliance Manager at 2525 C Street, Suite 500, Anchorage, Alaska 99503-2633.

The Business Ethics and Compliance Assistance Line is a toll-free telephone service that is answered by a third party who is trained to take calls and write summary reports. The report will be sent to the Legal Compliance Manager who, in consultation with the Compliance Officer, will decide on the proper follow-up. Although people are encouraged to identify themselves so that the concern can be most effectively addressed, calls to this line may be made anonymously. There are no caller ID's, recorders, or other identification and/or tracking devices attached to this phone service.

The Business Ethics and Compliance Line is not meant to replace CIRI's longstanding open door policy. It is provided as another resource for a person when they believe that a concern cannot be addressed with someone internally.

All requests for information and reports will be taken seriously and addressed appropriately. CIRI strictly prohibits retaliation against any person who in good faith requests guidance or reports a business ethics and/or compliance concern. However, if a person at CIRI knowingly makes a false allegation for the purpose of harming another individual, that person may be subject to disciplinary action, up to and including termination from employment. Every person at CIRI is expected to fully cooperate in any company investigation.

Enforcement of the Code of Business Conduct and Compliance

Each person at CIRI is responsible for his or her own ethical behavior and compliance with the Code of Business Ethics and Compliance and is required to sign an annual statement acknowledging his or her responsibility to adhere to the Code. CIRI is committed to enforcing compliance with its Code regardless of the level of individual who may be involved in a possible violation. Those individuals who have been found in violation of CIRI's Code may be subject to appropriate disciplinary action, up to and including termination from employment. Any person at CIRI who violates laws and government regulations may also be exposed to criminal fines, prison terms, and civil damages.

Any changes to the provisions of this Code must be approved in advance by the CIRI Board of Directors.