Code of Business Ethics and Compliance
Ethical Conduct
CIRI values ethical conduct recognizing that actions have consequences for ourselves, each other, and CIRI; and actions must be guided by a commitment to do what is right. CIRI conducts business in full compliance with the laws, rules, and regulations that govern CIRI’s business activities and interests.
Commitment to compliance
CIRI is committed to emphasizing each individual’s responsibility to understand and strictly comply with the laws, policies, procedures and practices that govern his or her job activities. CIRI’s policies include, without limitation, this Code, CIRI’s Employee Handbook and all other directives of CIRI’s Board of Directors or its management.
Equal opportunity/antiharassment
The diversity of CIRI’s employees is a tremendous asset. CIRI is firmly committed to providing equal opportunity in all aspects of employment and will not tolerate unlawful discrimination or harassment. CIRI reserves its legal right to give certain employment preferences to CIRI shareholders.
Non-retaliation
CIRI strictly prohibits retaliation including the discharge, demotion, or discrimination against an employee for reporting a potential act of wrongdoing or seeking guidance regarding any situation of concern relating to compliance issues.
Fair competition and antitrust laws
CIRI will comply with all federal and state antitrust laws. Antitrust and competition laws generally prohibit agreements between competitors to fix prices, collusive bids, market or customer allocations or refusals to do business with others.



