Code of Business Ethics and Compliance
Ethical conduct
Insider trading/nonpublic information
CIRI will comply with all laws that prohibit trading in securities by persons who have material information not generally known or available to the public. Although CIRI is not a publicly traded company, CIRI is subject to insider trading laws. Insider trading laws apply to material, nonpublic information about publicly traded companies with whom CIRI conducts business or is considering conducting business with. In the course of conducting CIRI business, we may hear material, nonpublic information such as a current or potential business partner’s or vendor’s plans for expansion, new products or services, management changes, mergers, acquisitions or other significant business information. In these cases, we cannot trade or “tip” others (such as friends, co-workers or family members) to trade in the stock of that company. Violation of insider trading laws can result in severe penalties, both for individuals and for CIRI.
Intellectual property
CIRI will protect its intellectual property and the intellectual property rights of others. CIRI’s logo, work products, patents, trademarks, copyrights and trade secrets are all CIRI’s intellectual property.
International business
CIRI will respect and comply with the laws of foreign countries with whom CIRI conducts business. This includes understanding and complying with the United States Foreign Corrupt Practices Act (“FCPA”), which prohibits payments either directly, indirectly or through a third party to foreign government officials, parties or candidates for the purposes of influencing favorable government action or obtaining/ retaining business.
Political participation
CIRI will avoid any impropriety, or even the appearance of impropriety, in corporate dealings with political officials and will adhere to all local, state and federal laws applicable to corporate and individual contributions to political campaigns, gifts to public officials and certain lobbying activities.
Regulatory investigations, inspections, reports and requests for information
CIRI will promptly and properly respond to all requests from government agencies in connection with audits, inspections or investigations, including regular reporting in connection with CIRI’s government contracting activities. All such inquiries should be referred to CIRI’s Legal Department. CIRI will report all violations of law in connection with government contracting to the Government in a timely and accurate manner.
