Working together with our customers and business partners, we make a positive difference in the lives of others.
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.
- 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
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
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.
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
What if ...
I was just assigned a customer, and it’s a company in which I own stock. Is that a conflict of interest?
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.
What if ...
During the holidays, one of our vendors sent me a gift card to a local restaurant. May I accept it?
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.
Keep in mind:
- You may accept an occasional gift from a customer, vendor or partner if it’s modest in value (less than US $100), appropriate for the occasion and intended to foster a business relationship
- You may accept an occasional meal and entertainment from a customer, vendor or partner if they attend the event with you, the costs are in line with local business customs (less than US $100) and you inform your manager, human resources or compliance
- If you are offered a gift, meal or entertainment that exceeds the $100 threshold, thank the offeror, politely decline and notify your manager, human resources or compliance. But if refusing the offer would be considered culturally offensive or insulting, accept it and immediately consult with your manager, human resources or compliance
- In some situations, offering or accepting gifts, meals or entertainment may violate the law. Don’t offer anything of value to a government official or health care provider without receiving prior approval from legal or compliance
- Some gifts and entertainment are never acceptable to give or receive, for example cash or cash equivalents (such as gift cards), or any gift or entertainment that would harm our reputation (e.g., something that is indecent or improper)
- Understand that someone to whom you offer a gift, meal or entertainment may not be permitted to accept it under their company’s policies and consider asking them in advance if they are allowed to receive it
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