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  • Make a Report
  • Get Started
    • A Message From Leadership
    • Our Purpose, Vision and Values
  • Code of Conduct
    • Table of Contents
    • Doing the Right Things Right
      • How to Use Our Code of Conduct
      • Who Must Follow Our Code
      • Our Responsibilities
      • Asking Questions and Raising Concerns
      • Protection From Retaliation
      • Making the Right Choice
    • Our Commitment to One Another
      • Diversity, Equity and Inclusion
      • Fairness and Equal Opportunity
      • Harassment-free Workplace
      • Safety and Physical Security
      • Protection of Systems and Resources
      • Privacy and Personal Data
    • Our Commitment to Our Customers and Business Partners
      • Confidential and Proprietary Information
      • Business Partners and Supplier Relations
      • Gathering Competitive Intelligence
      • Conflicts of Interest
      • Gifts and Entertainment
      • Accurate Records
      • Public Communications and Social Media
    • Our Commitment as a Responsible Corporate Citizen
      • Corporate Responsibility
      • Anti-bribery and Corruption
      • Free and Fair Competition
      • Insider Trading
      • Political Activity
      • Global Trade
    • A Closing Message From Our
      Chief Risk and Compliance Officer
  • Resources
    • Have Questions?
    • Download Code of Conduct PDF
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Our Commitment to Our Customers and Business Partners

  • Confidential and Proprietary Information
  • Business Partners and Supplier Relations
  • Gathering Competitive Intelligence
  • Conflicts of Interest
  • Gifts and Entertainment
  • Accurate Records
  • Public Communications and Social Media

Working together with our customers and business partners, we make a positive difference in the lives of others.

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Confidential and Proprietary Information

We understand that the nature of our work requires that we take the utmost care with information we see, hear or learn.

We uphold our promise and contractual obligations to keep the confidential information of our company and others safe and secure.

As part of our commitment to protecting confidential and proprietary information, we require that team members in the Contact Center sign monthly re-affirmation pledges.
  • Be careful when communicating or using confidential company or customer information. Share it only with those who are authorized and need it to do their jobs
  • Protect our intellectual property like copyrights and trademarks
  • Respect the confidential and proprietary information (including intellectual property) of third parties, such as competitors, suppliers and others
  • Follow the confidentiality and nondisclosure provisions of the agreement you signed when you were hired, and note that this requirement extends to third parties working on our behalf
  • Be aware that our agreements require us to protect confidential and proprietary company information even after our employment with NAVEX ends
As part of our commitment to protecting confidential and proprietary information, we require that team members in the Contact Center sign monthly re-affirmation pledges.

Business Partners and Supplier Relations

We seek business partnerships that align with our values and follow the highest standards of business conduct.

All arrangements with our business partners require an agreement with NAVEX to ensure we meet our commitments to our customers.

  • Follow our procurement and approval processes
  • Conduct due diligence on new suppliers and agents acting on our behalf
  • Help suppliers understand our risk and compliance standards and their contractual obligations
  • Be aware that additional rules apply when we bid for and conduct business with governments and their contractors – team members working with any government entity have an additional responsibility to know, understand and follow the laws and regulations pertaining to that work
  • Report to legal or compliance any supplier or business partner that may not be meeting our standards

Gathering Competitive Intelligence

Information about competitors is valuable in today’s business environment.

When we gather business intelligence, team members and others working on our behalf must always abide by the highest ethical standards.

  • Never engage in fraud, misrepresentation or deception to obtain information or use invasive technology to spy on others
  • Be careful when accepting information from third parties. Verify their sources and seek to ensure that the information they provide is not protected by nondisclosure or confidentiality agreements
  • Do not use or disclose the confidential information of your former employers or violate active non-solicitation agreements you may have signed

Conflicts of Interest

We avoid potential conflicts of interest.

We put NAVEX first and avoid potential conflicts of interest A conflict of interest may occur when our personal activities or relationships impact our ability to make objective business decisions. . The best way to avoid potential conflicts is to know and avoid the kinds of situations where conflicts may arise. Any situation that makes others question our objectivity can erode the trust that others place in us. So, be proactive in disclosing both potential and actual conflicts. Once disclosed, the situation can usually be managed and resolved. So, be proactive …

Be aware of the different ways conflicts of interest can arise. For example:

  • Outside jobs and affiliations, especially with competitors, customers or business partners
  • Working with or hiring close relatives, partners or friends, especially if they report to you
  • Serving as a board member of another organization
  • Investments that might influence – or appear to influence – your judgment
A: Probably not, unless you own more than 5% of that company. The best course of action would be to disclose this information to your manager or another company resource so that the situation can be reviewed, and a determination can be made about appropriate next steps.

Gifts and Entertainment

Under the right circumstances, a modest gift or meal may strengthen a business relationship, but an offer that is lavish or extended too frequently could cause others to question our objectivity.

We win business based on the quality of our products and services. Do not give, accept or ask for any gift or entertainment of any value if the intent is to influence – or could appear to influence – your ability to make objective business decisions. For additional information, see our Anti-bribery and Corruption Policy.

Other rules to keep in mind:

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A: No. A gift card is a cash equivalent, and it would violate our policies to accept it. After notifying your manager, you should politely thank the vendor but return the gift card and let them know about our policy.

Accurate Records

Accurate records are essential for good business decisions and for preserving the trust of business partners and government officials.

Some team members have special responsibilities in this area, but all of us contribute to the process of recording financial and nonfinancial information.

  • Be accurate and complete with our business records, including timekeeping records for payroll processing
  • Understand and follow the law and our policies when creating, retaining or destroying documents
  • Never destroy documents in response to or in anticipation of an investigation or audit

Each of us is responsible for maintaining some kind of “record.” A record could be:

  • A purchase order
  • A benefit claim
  • An invoice
  • An expense report
  • A financial forecast
  • A proposal
  • A technical specification

Public Communications and Social Media

Every communication regarding our company affects our reputation and brand. That’s why we ensure that information spoken, written or released into cyberspace is clear, accurate and consistent.

Refer questions and requests for information (including our business plans and operations) to those who are authorized to speak for NAVEX. Unless you’re designated as a spokesperson, direct inquiries from the media, regulatory authorities and others to the proper resource:

  • Refer media inquiries and invitations to speak or present on behalf of NAVEX to marketing
  • Refer inquiries from the government or regulatory officials, or questions about financial matters, to legal

Our commitment to communicating responsibly extends to our social media activity, too. When engaging on social media:

  • Think before you post – online communications live forever
  • Do not disclose the confidential or proprietary information (like product roadmaps or customer data) of NAVEX, our customers or business partners
  • Respect intellectual property – no unlawful use may be made of our trademarks, copyrighted works and trade secrets
  • Seek guidance from human resources before providing an employment recommendation for a colleague (current or past)
  • Don’t post anything that would be considered harassing, bullying or discriminatory
  • If you see comments or posts on social media that you believe are inaccurate or unfairly represent NAVEX or our customers, do not respond – instead, report the information to marketing, legal or compliance who will help you determine the best course of action
View Table of Contents
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Our Code of Conduct is intended to help us make good decisions on the job every day. Of course, no code can cover every possible topic, scenario or situation, which is why we count on everyone on our team to use good judgment and ask questions whenever there is doubt about what to do.

  • View Table of Contents
  • A Message From Leadership
  • Resources
  • A Closing Message From Our Chief Risk and Compliance Officer
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