We honor the letter and the spirit of the law everywhere we do business.

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Corporate Responsibility

We are proud of the role we play in shaping the global movement toward greater corporate integrity and social responsibility.

We recognize that our collective future is tied to the everyday actions taken to honor human rights, protect the planet and be a good neighbor.

We are committed to:

  • We ensure that our team members work of their own free will
  • We do not accept corporal punishment, forced or involuntary labor, or other forms of mental and physical coercion, and we do not use or permit the use of child labor
  • We strive to work with business partners that share our standards and commitment to human rights, and we work with our customers to assist them in meeting their corporate social responsibility goals

  • We are working to reduce greenhouse gas emissions at our global offices and data centers
  • We strive to reduce waste to landfills and to recycle, reuse and repurpose across our operations
  • We house our global headquarters in a LEED gold certified building

  • We participate in, and support, local and global initiatives in the communities where we operate
  • We offer team members 16 hours of paid Days of Service to support organizations and causes that matter most to them

See the NAVEX ESG Report for more information about our environmental, social and governance outreach.

Anti-bribery and Corruption

NAVEX is committed to doing the right things right in every aspect of our business operations.

We do not offer, pay or accept bribes, kickbacks or improper payments at any time for any reason, nor will we offer facilitation or “grease” payments. We work with our customers and business partners to actively support efforts to eliminate bribery and corruption worldwide.

  • Exercise caution when selecting third parties that work on our behalf, and monitor their compliance with contractual obligations and our standards – be sure to follow our procurement processes
  • Keep accurate books and records to ensure that payments are not inadvertently used for unlawful purposes
  • If you are offered or asked for a bribe, no matter how small, you must refuse it and immediately report the incident to legal or compliance

For further guidance, see our Anti-bribery and Corruption Policy or contact legal for guidance.

What if ...

Company executives at one of our customer’s locations expect us to pay special fees to do business in the country where I operate. What should I do?

Special payments made directly or indirectly to a customer, even if considered OK given local custom, could violate anti-bribery laws or regulations. Before making a payment of this kind, contact legal or compliance for guidance.

Free and Fair Competition

We believe in free, fair and open competition.

We compete vigorously to be an industry leader and maintain high standards of fairness and honesty when engaged in marketing, promotional and advertising activities. We gain our competitive advantage through superior performance, price and quality, not through unethical or illegal business practices. We will not enter into any arrangement that is unlawful or could harm our reputation.

Competition laws are complex, and compliance requirements can vary depending on the circumstances. But in general, the following activities are “red flags” – you should avoid them and report them to legal or compliance:

  • Entering into anti-competitive agreements with competitors, including price fixing, bid rigging, and market allocation or segmentation
  • Exchanging competitively sensitive information with competitors. Be particularly careful at conferences and trade shows where we often spend time with our competitors in exhibit halls
  • Abusing a position of market dominance
  • Meeting with competitors where a questionable discussion begins. Make it clear that you believe the discussion is inappropriate, noticeably break away from the discussion, and promptly inform legal or compliance

Insider Trading

While NAVEX is privately held, we conduct business with many publicly traded companies that trust us with their protected information.

In the course of business, you may become aware of information about customers, business partners or other companies that is not publicly available to ordinary investors. Using this “inside information” for personal gain or sharing it with others is contrary to our values and illegal.

  • Never buy or sell securities of a company about which you have inside information
  • Never provide “tips” or encourage others to trade based on inside information
  • Remember: These rules continue to apply even when you are no longer a NAVEX team member
  • If you have questions or believe that inside information has been disclosed, contact legal or compliance

Know the kinds of information considered inside information. Examples include nonpublic information about:

  • Mergers or acquisitions
  • Potential reductions in workforce
  • Sales or earnings results
  • Financial forecasts
  • Changes to the executive management team
  • Pending lawsuits
  • Major wins or losses

Political Activity

NAVEX supports lawful political contributions and involvement by its team members.

Conduct any related activities in compliance with the law. You have the right to voluntarily participate in the political process, including making personal political contributions, but make it clear that your personal views and actions are not those of NAVEX.

Under federal and most state statutes, it is unlawful for NAVEX or any team member to use company funds to make direct or indirect political contributions to parties or candidates. This prohibition includes the use of company equipment (such as a phone or copy machine) or facilities to support the political process or a specific candidate.

  • Do not use our funds, assets or resources to support any political candidate or party or to engage in lobbying activities
  • Since political activities can sometimes create a conflict of interest, discuss any potential conflict with your manager and compliance if you plan to accept or seek a public office
  • Regardless of your job at NAVEX, take care not to exert pressure on others to accept or support your political point of view

Global Trade

In conducting business internationally, we need to be aware of – and comply with – laws governing global trade.

Many governments restrict to varying degrees the import and export of goods and services. We honor the trade, import and export laws that apply to our products and services.

We also must carefully evaluate business opportunities within countries that are subject to U.S. trade embargoes or economic sanctions and abide by the regulations governing these markets.

  • Be aware that some countries impose trade restrictions covering specific countries, entities and individuals. Consult with legal immediately if you have questions about whether or not a specific entity or individual may be on a restricted list
  • Be especially careful and ask legal for guidance when transferring software, software code, technical data, customer data or technology across borders or to individuals from sanctioned countries
  • Don’t participate in or promote boycotts that the United States does not support – if you receive a request to do so, forward it to legal or compliance
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