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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.

 

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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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