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Code of Business Ethics and Compliance

Employee and Board Excellence

Anti-Harassment

Every person at CIRI will work and conduct business in an environment free of harassment. Harassment, including sexual harassment, on the basis of gender, sexual preference, pregnancy, ethnicity, religion, age, marital or family status, national origin, citizenship, veteran status, disability, or other protected status will not be tolerated. CIRI will not tolerate any form of harassment, verbal or non-verbal, directed at or committed by any person at CIRI or any individual with whom we conduct business.

Health and Safety

People at CIRI are committed to the health and safety of our employees and strive to keep our workplace as free from physical risk as reasonably possible. In helping CIRI achieve that goal, each person is responsible for following safe work practices, taking the necessary safety precautions to protect himself or herself, and immediately reporting unsafe working conditions or accidents to his or her supervisor so that timely corrective action may be taken to remedy the situation.

Drug Free Workplace

People at CIRI come to work and conduct CIRI business free from the effects of alcohol or drugs. Unless it is part of a CIRI-sponsored event, CIRI does not condone the use of alcohol on our premises. The use, possession, distribution, purchase, or sale of any controlled substance, and any related paraphernalia, or negotiation or attempt to do so by any person while on CIRI premises, engaged in CIRI business or operating CIRI equipment is prohibited. CIRI may use drug and alcohol testing as a means of enforcing this policy.

Privacy

CIRI collects and maintains employee information that is necessary for business, legal, or contractual reasons. Access to this information is limited to those who have a business need to know this information or are required by law to access it. In addition, CIRI's policies are fully in compliance with the HIPAA requirements to protect employee health information.

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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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