Dear CIRI Colleague:
The mission of CIRI is to promote the economic and social well-being and Alaska Native heritage of our shareholders, now and into the future, through prudent stewardship of the company’s resources, while furthering self-sufficiency among CIRI shareholders and their families. Staying true to our values is key to this mission.

CIRI is founded on our commitment to the highest ethical principles and standards, particularly honesty and integrity. Upholding these commitments is essential to CIRI’s continued success.

The legal and ethical principles that comprise this Code of Business Ethics and Compliance must guide our behaviors and conduct. This Code is broadly stated and not intended to either replace CIRI’s more detailed policies and procedures or provide detailed instructions for every conceivable situation. Rather, it has been developed to provide a common understanding of CIRI’s values and the legal and ethical ideals to which we aspire in the conduct of CIRI’s business activities.

Understanding and living by this Code is essential. I have personally taken the time to study it carefully and I ask you to do the same.

Ultimately, CIRI’s most valuable asset is our reputation. Complying with the highest ethical and legal principles contained in this Code is the starting point for protecting and enhancing CIRI’s reputation. Thank you for your commitment!

Sophie Minich
President and Chief Executive Officer

Introduction: Purpose and Scope

CIRI created this Code to ensure that CIRI employees’ and directors’ business decisions follow CIRI’s commitment to the highest ethical standards and the law. Adherence to the values and principals set out in this Code is essential to maintaining and furthering CIRI’s reputation for fair and ethical practices among CIRI customers, shareholders, staff and community.

As a corporation, CIRI typically acts through individuals; therefore, this Code applies to all directors, officers, employees and agents of CIRI and CIRI subsidiaries. These groups are collectively referred to as “CIRI” throughout this Code. In fact, many of the values state that “CIRI will…” This is to emphasize not only that the values apply to all directors, officers, employees and agents of CIRI and CIRI subsidiaries, but that the actions of every individual are reflective of, and representative of, CIRI as a whole.

How to Request Guidance and Report Concerns

Every employee is responsible to report concerns if that person has reason to believe he or she has witnessed or been the victim of a violation of CIRI’s code of business ethics and compliance. If you do not understand a provision of this Code, are confused as to what actions you should take in a given situation, or wish to report a violation of the law or this Code or CIRI’s standards generally, immediately contact your manager, any member of CIRI management, the Compliance Officer, the Compliance Manager, call the Business Ethics and Compliance “hotline” at (888) 228-7798 or make an online report at

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.


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.

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.


The value of integrity is essential to CIRI’s reputation and to building an organization based upon trust. CIRI is truthful and honest in all interactions. With trust, CIRI can build long-term, sustainable and successful relationships with CIRI shareholders, suppliers, partners and each other.

Fair dealing

CIRI will act honestly, fairly and with integrity in all situations. CIRI prohibits knowingly submitting an inflated claim, falsified document, statement, record or certification. CIRI ensures that all costs and pricing under a government contract are current, accurate and complete in accordance with the Truth in Negotiations Act.

Fraud, waste and abuse

CIRI prohibits fraud, waste and abuse. Fraud, waste and abuse can include, but is not limited to, illegal or fraudulent conduct, waste of funds, abuse of property or resources, gross mismanagement or misappropriation of funds. CIRI will report evidence of fraud, waste or abuse to the proper authorities in a timely and accurate manner.

Financial integrity

Honest and accurate recording and reporting of financial information is critical to making responsible business decisions. Each employee is responsible for ensuring costs, labor, material and other expenses are recorded truthfully and accurately. CIRI prohibits the improper mischarging of work time, charging an unauthorized account or cost objective, or approving such mischarging or shifting of costs to improper accounts. CIRI will maintain its financial integrity and take all necessary steps to properly account for CIRI assets.

Documents and records

CIRI will effectively manage and systematically control its documents and records, including strict adherence to applicable document requirements.

Safeguarding corporate assets

CIRI will protect all corporate assets, including but not limited to: physical property (desks, files, equipment, supplies and facilities), technical resources (computers, telephones, voice and electronic mail, internet and copy and fax machines) and non-physical assets (confidential information, business strategies, intellectual property and technology).

Confidential information

In the course of conducting CIRI business, individuals may have access to information concerning employees, customers, proposed business partners, proposed corporate investments or other activities and information. CIRI may also have contractual obligations to third parties to keep certain information confidential. Such confidential information is critical to CIRI’s success and must not be disclosed to anyone other than those who have a legal right, a legitimate business need, or as the Company’s legal advisors deem appropriate. Confidential information must be safeguarded physically and disposed of properly in order to avoid inadvertent, improper disclosure. When a person accepts a position with CIRI, he or she accepts the legal and ethical obligation to protect this information and must sign a Confidentiality Agreement acknowledging such obligation.

Classified information

Government information that is national-security classified, procurement-sensitive or proprietary shall not be solicited, accepted from or provided to any source under any circumstances unless the release is authorized to the appropriate security clearance personnel. All classified information in CIRI’s possession shall be treated in strict compliance with U.S. Government mandated procedures for such classified information.

Conflicts of interest

CIRI directors and employees will act in the best interest of CIRI and not be unduly influenced by external relationships nor avail themselves of CIRI’s corporate opportunities unless properly disclosed and allowed. Conflicts of interest may arise when private interests interferes in any way or competes with CIRI’s interests. A conflict of interest exists if a decision may personally benefit you, a relative or a significant other. Investments, interests or associations that interfere or might interfere with the independent exercise of judgment in CIRI’s best interests also create conflicts of interest. Even the appearance of a conflict of interest can be harmful to CIRI. Accordingly, CIRI requires every individual at CIRI to promptly disclose potential conflicts of interest and to take reasonable steps to either eliminate or mitigate them where possible.

Gifts and favors

CIRI acknowledges that giving and receiving gifts, including entertainment, in a business setting is often a part of ordinary business practice and may be used to strengthen business relationships. Offering anything of value to a Government employee or official is always prohibited. However, gifts may be given or accepted when there is no intent to influence, or appear to influence, business decisions. CIRI does not impose rigid dollar limitations on gifts and favors, but instead relies on the use of good judgment and discretion in connection with the giving and accepting of gifts, including the observation of all policies and regulations applicable to such gifts.

Bribery and anti-corruption

CIRI prohibits the payment of bribes or kickbacks to government officials or other businesses whether as an attempt to influence or solicit proprietary or source selection sensitive information from a Government or other public official or for any other reason.

Partner selection

CIRI will establish relationships with business partners whose business conduct, interests and activities are in concert with CIRI’s, to reinforce and strengthen CIRI’s future success and continued viability as an organization.

Vendor selection management

CIRI will select vendors based on objective criteria including, but not limited to: product/service quality, cost/price, flexibility, technical excellence and the vendors’ ability to meet schedules and delivery commitments. Purchasing decisions are made solely on the ability of the vendor to meet CIRI’s business needs and not on personal relationships or other non-business-related criteria. CIRI’s business transactions with others will always adhere to the highest standards of ethical behavior and legal compliance.

Protecting the environment

CIRI has a firm commitment to care for and protect its natural resources. Without compromising CIRI’s obligations to responsibly develop and manage CIRI’s resources, CIRI will conduct business activities in a lawful manner that respects and preserves the quality of the environment.

Media relations

CIRI will make public information about CIRI and matters that affect CIRI with discretion and through channels CIRI deems appropriate. In order to prevent the inadvertent disclosure of confidential information, assure the consistency and accuracy of information and allow for the continuation of CIRI’s favorable public image and reputation, CIRI requests all media inquiries be directed to CIRI’s Corporate Communications Department.

Respect for Shareholders and Descendants

CIRI is committed to treat CIRI shareholders and descendants with dignity, honesty and respect both as agroup and as individuals. Respecting CIRI shareholders and descendants means honoring their diversity and understanding their unique needs.

Shareholder relations

CIRI’s relationship with its shareholders is built on a solid foundation of integrity, respect and forthrightness. CIRI is committed to managing its business for the benefit of CIRI shareholders and takes pride in enhancing the quality of life for CIRI shareholders and generations to come.

Shareholder communications

CIRI is accessible to its shareholders and responsive to their questions and concerns. CIRI will strive to provide shareholders with timely and accurate information about CIRI business matters, subject to confidentiality requirements and legal restraints. To assure that shareholders receive timely, regular and accurate information, inquiries from shareholders should be referred to the Shareholder Relations Department.

Corporate Citizenship

The value of corporate citizenship illustrates CIRI’s dedication to have a genuine concern for the welfare and long-term sustainability of the community in which CIRI conducts business.

Social responsibility

CIRI believes that organizations have a responsibility beyond being an economic force. Companies, like CIRI, also carry an obligation to support the viability and vitality of those communities in which it conducts business. CIRI is committed to being socially responsible and to improving the community. CIRI encourages officers, directors and employees to share their time and expertise with charitable organizations through volunteerism, personal giving and sharing.

Corporate giving

CIRI takes a leadership role in charitable giving within the greater Alaska community, which in turn benefits CIRI shareholders and employees. CIRI regards its corporate support – monetary and inkind contributions as well as volunteer activities – as an investment in the future of the local and state community and a demonstration of CIRI’s commitment to social responsibility and corporate citizenship.

Health and social services

CIRI works closely with and supports nonprofit organizations, both Alaska Native and non-Alaska Native, which collectively provide a set of enduring health, education, employment, social services, housing and cultural preservation/advancement programs and services. These programs and services, many of which have received national recognition, help to establish and build a strong community for current and future generations and improve the quality of life for CIRI shareholders and other Alaska Native and American Indian people in Southcentral Alaska.

Cultural Heritage

CIRI values the diverse cultural heritage of CIRI shareholders and Alaska Native people. CIRI is proud of Alaska Native history and traditions, and strives to preserve Alaska Native cultural heritage.


CIRI believes that the wealth of a community lies not only in the financial resources that it has, but also in the richness of its treasured traditions and history. CIRI strengthens the dynamic and growing cultural heritage of Alaska Natives by supporting organizations and individuals who improve Alaska Native cultural awareness and advance Alaska Native cultural traditions. CIRI records Alaska Native history, promotes public knowledge of Alaska Native success stories, and supports efforts to safeguard cultural resources.


CIRI invests in cultural and social institutions and activities since they benefit the entire Alaska Native community. CIRI also supports individual artists and talent through art collections and supports cultural organizations.

Employee and Board Excellence

The value of employee and Board excellence embodies CIRI’s commitment to the highest level of legal, ethical and moral standards in the conduct of business based on a fundamental belief in honesty, fair dealing and open competition.


CIRI achieves the greatest success when individual efforts support and pursue the goals of the organization. CIRI strives for excellence in all that CIRI does, emphasizing teamwork and establishing an atmosphere of trust, integrity and respect. CIRI believes in the fundamental dignity, worth and opinion of each individual.


CIRI values dedication, undivided loyalty, creativity, diversity and best efforts from CIRI employees.


Effective Board governance is the key to building long-term shareholder satisfaction. CIRI Board members work together for the common good of the organization and exercise all required duties and obligations in good faith.

CIRI’s Business Ethics and Compliance Program

Program administration

CIRI’s Business Ethics and Compliance Program communicates CIRI’s commitment to its values, ethical business conduct and strict compliance with all applicable laws, rules and regulations. This program is administered by CIRI’s Compliance Officer.