We want to be proud not only of what we achieve but how we achieve it.


How to Use Our Code of Conduct

Our Code is your resource.

Situations involving ethics and compliance can be complicated, and sometimes it’s difficult to know what to do. We want you to have the information you need to do the right things right on the job every day. Our Code of Conduct (“Code”) is designed to point you to policies and people who can help you.

We comply with all laws that apply to our business, and we take steps to ensure customer needs and regulatory requirements are met. We also know that we are held to a higher standard by the marketplace because of the work we do, so our values play an important role in determining our actions.

Because we conduct business around the world, our policies may differ sometimes from local laws, rules, cultural norms and regulations. Where there appears to be a conflict, you should typically follow the more restrictive requirement. However, if a cultural norm violates our values or if you’re ever unsure about the right course of action, contact your manager, human resources, legal or compliance for guidance.

What if ...

I’m facing a situation that is not covered in our Code of Conduct. What should I do?

Our Code can’t address all the issues that may arise at work. Check our policies first. If the answer is still unclear, it’s always appropriate – in any situation – to ask for help. Start with your manager or any of the resources identified in our Code.

Who Must Follow Our Code

Our Code applies to every team member and our board of directors.

Business partners and third parties are an extension of our organization, and their behavior can have a direct impact on our reputation. That’s why we work with those that share our commitment to ethics and compliance. We expect our partners and their employees to act in a way that’s consistent with our Code, and we will consider terminating contracts where we believe our partners have not met our high standards or their contractual obligations.

Our Responsibilities

Every team member has a responsibility to maintain our reputation for high ethical standards.

To meet this responsibility:

  • Be professional, honest and ethical in everything you do on behalf of NAVEX, and treat everyone with fairness and respect
  • Know our Code and the laws and policies that relate to your job
  • Complete all required training and apply it to the work you do every day
  • Ask questions anytime you’re unsure about the right way forward
  • Report concerns about possible violations of laws, regulations, our Code and policies
  • Cooperate and tell the truth when responding to an investigation or audit
  • Be accountable for your actions – violating our Code, policies or the law is grounds for corrective action, up to and including separation from NAVEX

If you manage people, you have an even greater responsibility:

  • Uphold our values by leading with integrity and compassion
  • Promote an inclusive experience that enables people to be all of who they are
  • Serve and support people to help them thrive in life
  • Create a safe space for people to raise questions and share concerns
  • Consistently coach people with transparency and clarity to ensure they know what is expected
  • Act on your obligation to report behavior that is illegal or violates our Code, our policies or the law
  • Never retaliate, or allow others to retaliate, against team members who raise concerns

Asking Questions and Raising Concerns

Part of doing the right things right means voicing what matters.

We understand the importance of speaking up, asking questions and raising concerns – after all, promoting a speak-up culture is our business. It’s not only important for our customers, but for us, too.

Speak up if you have a question or wish to report a possible violation of our Code, policies or the law.

You have several options:

  • Talk to your manager, compliance, human resources, legal or any executive team member
  • Use our online reporting system

Any report you make will be kept confidential to the fullest extent possible, consistent with the law and good business practices. You may report anonymously unless prohibited by law.

Regardless of the method you use to report, or whether you choose to be anonymous, we will investigate your concerns and follow up as necessary.

If you do choose to report anonymously, please provide as much detailed information as possible and check back to see if we have posted any requests for additional information. When you share your concerns, we have the opportunity to address and resolve issues before they become more serious.

It’s important to report a suspected violation of our Code, but it’s just as important to do so honestly. Never file a report to:
  • Retaliate against another
  • Gain an advantage in a personal conflict or disagreement
  • Harass another team member

Filing a dishonest report is, in itself, a violation of our Code.

Protection From Retaliation

If you ask a question, report possible misconduct or take part in an investigation, you are following our Code and doing the right thing.

NAVEX will not tolerate retaliation against you under any circumstances. Retaliation can take many forms, from being unfairly dismissed, to being the target of bullying or derogatory comments, including in social media, by managers or peers.

We take all claims of retaliation seriously, investigating each one thoroughly and taking appropriate action. We consider acts of retaliation to be acts of misconduct which, if substantiated, could result in disciplinary action up to and including separation from NAVEX.

Making the Right Choice

If you’re faced with a dilemma and you’re not sure what to do, ask yourself:

If your answer to any of these questions is “No,” stop and seek further guidance.