Code of Ethics Overview

With the understanding that how does business and treats others will define to the rest of the world, has always sought to hire and employ professional, competent people who will make the right decisions in difficult situations. associates are expected to behave honestly and with integrity in all of their business practices. associates share a responsibility to fulfill their commitments to each other, clients, vendors, and and to do so with integrity. By doing so, associates can help shape’s reputation in a favorable way.’s commitment to doing the right things for the right reasons remains constant. It is the cornerstone of an associate’s success as an individual and as part of the Company. It is’s policy to comply with all laws and regulations applicable to its business around the world, and beyond this, to act in an honest and ethical manner at all times.

Although no document could possibly describe every problem or ethical challenge associates may encounter in their work, these Guidelines, combined with’s core values, additional policies contained in our office manuals, and guidance from Leaders and Human Resource associates, will help associates find the right course.


To fully achieve an ethical environment, every associate must fulfill certain roles and responsibilities. is responsible for:

  • Developing policies and guidance that explain’s position on business ethics and an associate’s related obligations.
  • Answering questions and providing advice to associates on ethical issues as they arise.
  • Taking appropriate action to prevent future ethical violations. will achieve this by restricting the discretion of associates who have failed to follow these Guidelines in the past and/or taking disciplinary action against such associates.
  • Maintaining working conditions supportive of associates’ ethical responsibilities.
  • Investigating alleged violations of these Guidelines.
  • Maintaining confidentiality to the extent consistent with’s fulfillment of its legal and ethical obligations of reported ethics violations.
  • Protecting associates who, in good faith, report actual or reasonably suspected ethics violations.

Leaders have a special responsibility for:

  • Demonstrating ethical behavior by example.
  • Ensuring that all associates understand these Guidelines.
  • Stressing the need for commitment to these Guidelines.
  • Maintaining a workplace environment that encourages the discussion of ethical issues without fear of reprisal.
  • Supporting any ethics investigations when called upon.
  • Communicating the expectation that’s contractors, vendors and agents comply with these Guidelines.

All associates are responsible for:

  • Knowing, understanding, and complying with these Guidelines.
  • Contributing to a workplace environment that is conducive to upholding these Guidelines.
  • Seeking help from Human Resources when the proper course of action is unclear or unknown to them.
  • Being sensitive to behavior by other associates, vendors, contractors or agents that is illegal or unethical.
  • Reporting violations of these Guidelines.
  • Learning the basic legal and regulatory requirements that pertain to their jobs.

Equal Employment Opportunity and Anti-Harassment

As part of’s commitment to a quality workplace, it is’s policy and practice to make all employment decisions, including recruiting, hiring, training, promotions or other employment of associates or the awarding of subcontracts without regard to race, color, religion, national origin, sex, age, physical or mental disability, military service, sexual orientation, genetics or any other protected status. believes that a work environment that reflects diversity and is free of discrimination, harassment, intimidation, and retaliation will result in a productive and efficient work force. In carrying out this commitment to equal opportunity, prohibits harassment or discrimination on the basis of any of these protected statuses. Associates who feel they are the victims of unlawful harassment or discrimination must contact their Leader or Human Resources immediately. All complaints or allegations of discrimination will be investigated. Confidentiality will be maintained to the maximum extent practical, and retaliation against individuals who report complaints will not be tolerated.

Client Relationships associates are expected to always deal with clients in a straightforward, trustworthy and honest manner. Clients should know that they can depend not only on services, but on’s word and corporate character.

Proprietary Information

Information is a key corporate asset. A critical factor in’s success is the maintenance of strict security and confidentiality with regard to, client and prospect data and proprietary information. The importance of maintaining the confidentiality of client information and of’s proprietary technology and trade secrets cannot be overstated. Associates who have access to proprietary and confidential information must take precautions to keep it confidential. Associates are expected to be very cautious in discussing Company business in public and must use extra care in transmitting confidential materials whether by email, phone, fax or other mode of communication. Remember that an associate’s obligation to protect’s confidential information continues even after he/she leaves the Company. Also, associates should review their obligations outlined in the Privacy Education and Certification, the completion of which is required of associates, nationwide, annually.

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Employment outside recognizes and respects an associate’s right to engage in activities outside of employment with that are private in nature and do not conflict with or reflect poorly on However, certain employment situations outside may result in a conflict of interest. It is the associate’s responsibility to ensure that this activity does not conflict with’s interests by not:

  • Doing work for another company or for himself/herself on time;
  • Performing services for an competitor at any time;
  • Using equipment and supplies, or the time of any associate, for outside employment;
  • Promoting products or services from an outside business to other associates during working hours; or
  • Capitalizing on business relationships with clients or vendors to promote an outside business interest.

Associates have a duty to disclose to any activity in which they are engaged outside of their employment that conflicts with the interests of, including its economic interests.