Townhouse requires the highest standard of conduct from each of its employees. The Company’s reputation for integrity is a key element of its success. That reputation is built one employee at a time, every day. It is mandatory that every employee demonstrate ethical conduct at all times. There is no other way to do business at Townhouse.
The Code of Conduct articulates rules governing situations that may arise in the course of the Company’s business covering the following key areas of conduct:
The Code of Conduct also addresses: 1) the responsibilities of managers and all employees to conduct business in an ethical manner and 2) the process of administering such guidelines, including how to get assistance.
The Code of Conduct is designed to give employees needed guidance in dealing with working situations that may present ethical issues. It cannot, however, create integrity. Personal integrity can result only from a vigilant sensitivity to the consequences of every act and a commitment to avoid any impropriety or even the appearance of one. Such integrity must be our constant, guiding principle.
Every employee must strictly adhere to the policies in the Code of Conduct in all aspects of activity. Violations will not be tolerated and will result in appropriate disciplinary action, which may include termination of employment, civil suits for damages or criminal prosecution.
The Company has a responsibility to its clients, its employees, and the business community in general to conduct business in an ethical manner and to protect the interests of its clients. All employees are responsible for being aware of and understanding this Code of Conduct.
Managers are responsible for:
All employees including managers are responsible for:
Acceptance of employment carries an obligation of loyalty to the Company. Each employee has the obligation to carry on his or her personal affairs in such a way as to avoid creating the possibility of a conflict between responsibility to the Company and the employee’s self-interest. A conflict of interest arises when an employee becomes involved in any business or other activity which may conflict with the best interests of the Company or in any way interfere with that employee’s ability to carry out completely his or her responsibilities for the Company.
Situations that could create conflicts of interest are of special relevance to a communications agency since a communications agency, unlike most other businesses, generally acts in a representative and fiduciary capacity on behalf of its clients and not on its own behalf.
Whether a situation creates a conflict of interest between your personal activities or relationships and your responsibility to the Company depends upon the circumstances. However, it is your obligation to report to your manager every possible conflict situation between you and the Company. Your manager will then determine whether the situation warrants further attention.
Our Code of Conduct in no way diminishes the long-standing Company tradition of encouraging all employees to volunteer their personal time, after business hours and away from the office, in outside activities of a civic, religious, political, or charitable nature or in other activities where their professional skills can be used for the benefit of the community. However, in this context, note that the Company is prohibited from taking political parties or candidates for public office as clients.
The following guidelines are intended to be useful in making decisions regarding potential conflicts, but they do not include all possible situations that might create conflicts of interest.
A conflict of interest arises if an employee accepts employment with, or has other substantial business interests in, a competitor. It also arises if the employee accepts employment or consultancy with, or has other substantial business interests in, a supplier to the company or to a client. Moreover, a conflict of interest arises if an employee engages in any activity, whether or not for compensation that infringes upon the employee’s ability to devote his or her entire business time to activities on behalf of the Company and its clients.
Examples of such conflicts of interest include the following:
Employees are sometimes asked to serve on the board of directors of a client or other business, or a charitable organization or an educational institution. In order to accept an invitation to join a board of directors, an employee must obtain the prior written approval of the appropriate official of the Company, which shall be made upon written application. The CEO shall approve all applications to join the board of directors or other governing body of any business enterprise, charitable organization or educational institution.
The application must include the name and address of the entity and a description of its business or other activities (such as a recent annual report or press clippings). All compensation payable by the entity for service is to be paid to the employee not the Company. The application must also disclose the director’s fees and any other financial benefits to be received by the employee for service on the board, as well as the names of all other boards of directors of which the employee is already a member.
The criteria for approval will include, among other factors, whether the directorship would present a conflict of interest, whether the goals or activities of the entity would conflict with those of the Company or a client, whether the time required of the employee to so serve would conflict with the duties of the employee to the Company and whether the employee is covered by directors’ liability insurance
Procurement of services or supplies must be based solely upon price, quality, service and need. Employees involved in the selection of and purchase from vendors and suppliers should avoid situations which could interfere, or appear to interfere, with their ability to make free and independent decisions regarding such matters.
Conflicts of interest include the following:
Employees should not place themselves under an actual or apparent obligation to anyone by borrowing money or accepting gifts, entertainment or other personal favors, which are offered or which might appear to have been offered for the purpose of influencing a business judgment. The Company recognizes that the offering or receipt of promotional materials or gifts of nominal value is not unusual, nor is the practice of infrequent and modest entertainment arising in the ordinary course of business. Precisely what is “nominal,” “infrequent” or “modest” in a particular situation may vary by the situation or the culture. The Company believes, however, that employees will recognize those situations that cross the line and use good judgment in this regard. In addition, whether gifts or gratuities are permitted, and what are their permissible monetary limits, may be restricted by the policies of a client or by applicable law. It is the responsibility of the manager of each account for which he or she is aware that the client has such restrictions to inform each employee working on the account of those restrictions and annually to circulate a memorandum to such employees disclosing them. If you have any question in this regard, please consult with your manager or the Human Resources. Some guidelines follow:
The same policy applies with respect to giving such gratuities. Employees should not offer gifts, entertainment or other personal favors, which might appear to have been intended to influence a business judgment. While the cultivation of cordial relationships with clients and prospects is a necessary part of good business, we cannot take any action that could be perceived as an attempt to buy their business. Many clients have policies governing the receipt by their employees of gratuities and entertainment. It is the responsibility of the manager of each account for which the client has such restrictions to inform each employee working on the account of those restrictions.
Offering promotional materials or gifts of nominal value is not unusual, nor is the practice of infrequent and modest entertainment arising in the ordinary course of business. Employees must use good judgment in this regard. Gifts of nominal value may be offered to private business persons if they are of a type and value commonly offered to others with a similar relationship, unless expressly prohibited by the client. Gifts of other than nominal value may be offered to private business persons only if there is a valid business reason, and written approval is obtained in advance from the CFO or the CEO. No gifts or entertainment may be offered to any official or employee of any government or political party unless the employee has obtained written approval in advance from the CFO or the CEO.
Before entering into any substantial contract, other than one governed by a form of contract produced by the Company (e.g., a purchase order, insertion order or production contract, etc.), it must be reviewed and approved by the responsible personnel of the office. Such personnel will vary with the staffing of the office. Among them will almost always be a senior representative from the Company’s Finance Department. Real estate leases and other contracts relating to real property must be approved by the Company’s CFO. Any contract with a client that applies to more than one market or more than one line of business and any contract including exclusive dealing arrangements or conflicts provisions which may restrict the ability of the Company to do business must be approved by the Company’s CEO.
Compliance with all provisions in client contracts is essential to appropriately, fairly and honestly serve our clients and compensate the Company. The business affairs department of each office must assure that all agreements with clients are carefully followed. Whenever a client contract governs more than one office or line of business, the business affairs department of the headquarters office of each line of business is required to assure that all of its offices working on the account have possession of the contract and adhere to its terms. Media, production and research departments in each office are responsible for knowing and following the terms of the agreements with their respective vendors.
The Company is committed to competing vigorously, but fairly, for its business. We will not engage in or support unfair business practices, such as disparaging competitors and their services or misrepresenting the facts.
The Company owes a moral, ethical and often a legal obligation to the public to create advertising and other business communications which are truthful and informative and are not misleading, deceptive or unfair. The principles below represent summaries of advertising law. As principles, however, they are equally applicable to each of the disciplines practiced by the Company.
All communications should refrain from making any statement or omission which may mislead the intended audience as to the attributes of the products or services being promoted. The Company must have a reasonable basis for making any direct or implied claims about the client’s products or services and those about its competition and industry. Prior to disseminating a communication, the Company must be in possession of documentation, in the form of reliable tests, studies, testimonials or other data, substantiating all claims made in a communication which are or purport to be matters of objective fact. This is particularly true for claims pertaining to efficiency, performance, quality or safety, and to comparative statements. If a claim is subject to multiple interpretations, each of them must be separately substantiated or the claim must be revised.
In countries where comparative advertising is practiced, care must also be taken to avoid disparagement of competitors’ products and services, even if the express claims made can be substantiated, if the implied claims would present them in a false light.
All testimonials, demonstrations and visual representations of products must be made in such a way as to avoid potentially misleading the public. All endorsements must reflect the honest beliefs of the endorser, should not be taken out of context and must be substantiated. An endorser cannot make a statement in an advertisement about a product or service unless the claims made by the endorser are typical of customer reactions generally and are substantiated.
While it may vary as a matter of contract, it is typically the obligation of the client to provide the Company with substantiation to support claims made in communications regarding its products, services, competition and industry prior to the date when any communication containing such claims is first disseminated. Similarly, it typically is the obligation of the Company to obtain all releases, testimonials, acknowledgments or other contracts necessary in the production of published communications, including, to the extent required by applicable law, the prior written consent of any person whose name, likeness, voice, signature or other personal attribute is used in advertising.
All necessary rights must be obtained, via purchase or license, for all copyrighted works produced by third parties which are incorporated into communications, such as music and artwork. If requested by the client, and subject to the Company’s contract with the client, copyrights for finished communications are to be registered in the client’s name.
Use of trademarks other than those owned by a client pursuant to its direction, use in a way which may infringe the rights of any third party, or use in a way which tends to dilute their distinctiveness, and thus their value, is to be avoided. Where a new product name or advertising headline or tag line to be used as a trademark is under consideration, subject to the Company’s contract with the client, trademark searches are required to avoid inadvertent infringement or dilution.
In any matter relating to intellectual property (e.g. trademarks, service marks, copyrights, or licenses to use music or artwork or the likeness of an individual) or trade regulation, employees are required to obtain legal advice before disseminating communications which may be subject to legal constraints. Advice regarding such matters should be obtained from lawyers practicing in the relevant market. Employees are required to confirm with the Company’s CFO which lawyers or law firms are approved by the Company to give legal advice to employees in the relevant market. Legal advice sometimes includes the presentation of alternatives, the choice among which may be a business judgment. The choice among such alternatives cannot be left to inexperienced personnel. Any such judgment must be made by senior members of account management, and usually must be made in direct consultation with the client, after careful disclosure of the legal advice, the risk evaluation and the alternatives.
Anti-competition or antitrust laws prohibit any agreement or understanding made with competitors to fix or control prices; to allocate services, markets, or territories; to boycott certain customers or suppliers; or to refrain from or limit the sale of any goods or services.
The same prohibitions apply to anti-competitive behavior with vendors and suppliers.
The provisions of the antitrust laws also apply to both formal and informal communications. Employees involved in trade association activities or in other situations allowing for less formal communication among competitors, customers or suppliers must be especially sensitive to the requirements of the law.
The Company’s services are to be sold on the basis of quality, service, price and other legitimate marketing attributes. In conducting the Company’s business, no bribes, kickbacks or other illegal remuneration are to be given or offered to any individual or organization for any reason at all. These activities are impermissible regardless of whether the payments are made, directly or indirectly, to a government official, a political party or a private person. Employees should not offer gifts, entertainment or personal favors, which are intended to influence a business judgment. It is also impermissible to use overbillings or other artificial methods of billing or payment to assist a customer, an agent or a distributor to evade the tax or exchange control laws of any country or to violate the policies of the customer, agent, or distributor.
The Foreign Corrupt Practices Act (“FCPA”) and other U.S. laws prohibit the payment of any money or thing of value to an official of a non-U.S. government or political party or a candidate for office of a non-U.S. country (collectively referred to under the FCPA as “Foreign Officials”) to obtain or retain business or otherwise to induce such official to act in an official capacity. For purposes of the FCPA, any country other than the U.S. is considered “foreign.” The FCPA applies to the Company and its employees everywhere throughout the world and any violation, anywhere, is a crime and may have extremely adverse consequences for the Company and the employees involved. Employees must strictly abide by these laws.
In order to minimize the possibility of violations, whenever employees seek or are offered business of a non-U.S. government, political party or political campaign, are involved in any procurement process in which any person involved in the selection of a contracting party may be a Foreign Official, or are considering any involvement with any “finder,” consultant or intermediary who claims access, or offers introduction, to any Foreign Official, management of the business unit(s) involved are required to contact the CFO to consult on the best course before taking any action. Until a conclusive determination to the contrary has been made by such counsel, employees are required to assume that any person as to whom the employee has any evidence that he or she may have some official status, may be closely related to a person with official status, or may act on behalf of someone else who does, is a Foreign Official, to whom the FCPA applies.
The Company strictly prohibits employees, contractors and any person or entity that performs services for, or on its behalf, from bribing or accepting bribes from private individuals and corporations and any and all public officials, whether foreign or domestic. Such conduct is unlawful under both U.S. and foreign laws, including, to the extent applicable, the UK Bribery Act of 2010, and could subject the Company and involved employees to severe penalties, including significant monetary sanctions and imprisonment.
The Company regularly assesses bribery risks and provides training and guidance to ensure that senior management, employees, agents, and contractors of the Company understand their legal and ethical obligations under applicable laws. You should immediately contact the CFO if you have any questions about these obligations, if you believe that you are being asked to perform services for or on behalf of the Company that may be in violation of any applicable foreign or domestic anti-bribery laws, or if you believe that you have been asked to request, receive or accept a financial or other advantage in violation of any applicable foreign or domestic anti-bribery laws.
Employees are required to contact their immediate supervisor if they have their Company-entrusted device lost or stolen (e.g., laptop computer, mobile devices etc.). All personal computers and mobile devices used within Townhouse must be approved and registered with IT.
The Company is responsible to its clients to ensure that client assets within the Company’s custody and control are properly safeguarded and are not lost, stolen or misused.
The term “Assets” refers to physical property, intellectual property (copyrights, trademarks, service marks, etc.) and confidential and proprietary information belonging to the Company or its affiliates, or entrusted to the Company or its affiliates, or their employees, in connection with their jobs.
Use of the Company’s facilities, supplies or work time to carry on any business activity other than that of the Company is prohibited unless such activity is specifically approved by the CEO of the Company. Also see the policies on Outside Business Interests and Employee Political Activity later in this Policy.
Company or client Assets are to be used only for the purposes for which they were provided.
The Company’s (or its affiliates’) or its client’s ownership of Assets created by the Company’s employees, including intellectual property created in the course of employment, continues after the employee has left the Company.
Employees must assume that all information they receive in the course of their employment is confidential or proprietary, to one of or both a client or the Company, unless they learned the information outside of their employment responsibilities from a public or other source apparently free from an obligation to keep such information confidential or have specific knowledge that such information is available from the public. Employees may become aware of proprietary information (for example, personnel records, financial projections, corporate transaction information, business plans, new business initiatives, advertising ideas or creative materials not yet adopted by a client for use) or client confidential information (for example, a client’s marketing plans, product development plans, product prices, competitive information, or advertising ideas or creative materials developed by the Company and accepted by a client for use) that could be used by the employee or others such as the Company’s or a client’s competitors for gain or advantage. Client confidential information is to be used only in connection with Company business with that client. Employees must not divulge such information, except as required to perform services for the Company, its affiliates, or its clients, or utilize it in any manner for their own benefit or for others such as the Company’s or a client’s competitors. Employees are expected to act scrupulously to avoid even the appearance of impropriety.
If the Company receives information subject to restrictions on its use to protect the confidentiality of the information, the restrictions must be strictly adhered to and all employees who have access to the information must be made aware of the restrictions. The contract between the Company and a client often contains a confidentiality provision. The senior manager on each account in each office is required annually to circulate to all personnel working on the account a memorandum summarizing the confidentiality provisions of the contract. When an account is governed by a client contract covering multiple offices, it is the responsibility of the senior manager of the account annually to prepare and distribute such a memorandum to the manager of each office, for distribution to local staff.
Clients or prospects sometimes require the Company to sign a confidentiality agreement protecting information to be provided to the Company, and sometimes require individual employees to do so as well. Before any such confidentiality agreement is signed, it should be reviewed by the people responsible for review of the important contracts of the office. Thereafter, it is essential that the manager of the account, or if the owner of the information is a prospect, the manager of the new business team, restrict access to such information carefully to those who must have it to perform their job responsibilities. The manager should provide each such person with a copy of the confidentiality agreement or a memorandum summarizing its terms, and, if employees with access are required to sign the agreement, the manager should assure that all of them do so and copies of the agreements are collected and filed.
Even in those situations where the Company has not entered into a contract with a client protecting the confidentiality of information, as noted above, it is the policy of the Company to protect such confidential information, as well as the Company’s proprietary information. Each employee is obliged to ensure that confidential information imparted to the Company or contained in the Company’s files is protected adequately and not disclosed to unauthorized personnel within the Company or persons not employed by the Company. To do so, it is important that every employee make a conscientious effort to protect such information. Accordingly, all documents should be handled carefully and not left in open areas. Visitors should be escorted directly to their destination and not be permitted access to any employee’s office or conference rooms where documents are displayed. Employees should be discreet in discussing client matters in hallways, elevators or away from the Company’s premises, particularly in circumstances where they could be overheard. Extreme care should be taken whenever sensitive materials are transmitted to persons outside of the Company and appropriate labels and/or covering memorandum should accompany deliveries of such materials.
Particular care should be taken of documents created by the Company for its clients that are stored on computer disks, hard-drives or other portable storage devices. Because such methods increase the potential for improper copying, all computer disks and other portable storage devices should be kept in a secure location. Sensitive data should not be left on hard-drives unless access to it can be blocked. In addition, employees should be sensitive to possible access by unauthorized persons to information conveyed by electronic mail, or voice message services or via cellular phones.
All employees should exercise diligence in ensuring that temporary personnel retained by the Company are advised about their obligation to maintain the confidentiality of any information learned about the Company or its clients. In addition, all Company employees who have managerial responsibility should take reasonable steps to ensure that Company employees (and temporary help) are familiar and in compliance with this Code of Conduct.
Upon leaving employment with the Company, no employee shall use or disclose proprietary or confidential information of the Company or any of its clients obtained while working at the Company.
There are increasing global regulatory requirements restricting the collection, processing and transmitting of personally identifiable information (PII). Laws differ from state to state and country to country and failing to comply with these laws exposes the Company, the client and you personally to severe penalties. If you are asked to participate in an activity where consumer PII, or any PII, is collected please contact the legal department or Information Security to ensure that such collection is in compliance with laws and Company policy.
All communications with the press must be carefully controlled. Only those designated to communicate with the press are authorized to do so. All other employees are strictly required to decline to respond to any inquiry they may receive from the press, no matter how innocuous it may appear, and to refer the inquiry to those personnel authorized to respond to it. Some information may be of global or regional importance, or may require dissemination across disparate audiences or co-ordination among different countries or lines of business.
This Policy is not intended to apply to communications to the press done by lines of business in the perception management or public relations areas in the ordinary course of their business for clients.
All records and books of account must be maintained timely, accurately, completely and honestly and must be retained pursuant to the Company’s document retention policy.
Before an expense is incurred for the benefit of a client, it is essential to ascertain that the expense is properly reimbursable by the client and is incurred and accounted for pursuant to the client’s contract with the Company or its expense reimbursement guidelines. If incurring such an expense requires the performance of certain procedures, such as obtaining competitive bids or prior client approval of an estimate, these procedures must be performed and documented in the manner required by the client contract or office procedure. If an expense is incurred for the account of the Company, it must be for a valid business purpose and incurred within the Company’s expense reimbursement guidelines. Expenses will be reimbursed only against legible receipts therefore which clearly identify the nature and purpose of the expense. Local expense reimbursement policies may have additional requirements. Employees should direct all questions regarding the guidelines for client reimbursement of expenses to the business affairs manager of their office, and all questions regarding the Company’s expense reimbursement guidelines to the cashier of their office. Any expense incurred by an employee, which is not properly reimbursable by the Company or a client, or is not properly incurred and accounted for, is a personal expense for the account of the employee and will not be reimbursed.
Any false or artificial entries or failure to make an entry where required in charges to client, or in the books or records of the Company for any reason is strictly prohibited, including:
The foundation for the Company’s prestige is its strong loyalty to clients and deep commitment to conducting its activities in a trusted and professional manner. To maintain that trust, each employee must strive to place the interests of our clients above all else. Ethics, Company policy and the law prohibit any employee from trading securities, either personally or on behalf of another, while in possession of material non-public information, or from communicating material non-public information to others. This conduct is frequently referred to as “insider trading.”
Although the law enforcement efforts of government authorities in the United States have received the most publicity, and the civil and criminal penalties they can have imposed are very severe, several other countries in which the Company does business impose similar penalties for such violations. Moreover, the U.S. Securities and Exchange Commission is very aggressive in asserting its authority to prosecute insider trading violations that arise outside of the U.S. if it concludes that there is an adverse impact on U.S. investors or companies whose securities trade in the U.S.
As a matter of policy, the Company will not tolerate insider trading (or tipping) by any of its employees, regardless of the marketplace in which the securities trade or country in which the employee resides. While these prohibitions cover information obtained as a result of employment at the Company, the prohibitions also apply to information which may have been learned elsewhere, if the employee knows or has reason to know that it came from a source who had an obligation to maintain its confidence. At times, an employee’s knowledge about a client’s affairs may adversely affect his or her freedom to buy or sell a particular security, until the confidential information becomes public. Employees who violate these principles will be subject to discipline for violations of Company policy and also may be subject to severe civil and criminal penalties.
While we have set forth below some discussion of the kinds of activity which are prohibited under the term insider trading, it is not all-inclusive. The penalties for violations in this area are severe. In order to protect the integrity of the Company and preserve the confidence of our clients, any doubts about the propriety of a particular transaction should be resolved by not doing it.
Any questions regarding the Company’s policies in this area should be referred to Human Resources or the Company’s CFO.
The concept of who is an “insider” is broad. It includes officers, directors and employees of a company. In addition, a person can be a “temporary insider” if he or she enters into a special confidential relationship in the conduct of a company’s affairs and as a result is given access to information solely for the company’s purposes. A temporary insider can include, among others, a company’s investment bankers, attorneys, accountants, consultants, public relations firms, and the employees of such organizations. In addition, the Company may become a temporary insider of a company it advises or for which it performs other services under circumstances where the entity anticipates that the Company will treat information imparted to it confidentially.
Trading while in possession of inside information is not a basis for liability unless the information is material. “Material information” generally is defined as information for which there is a substantial likelihood that a reasonable investor would consider it important in making his or her investment decisions, or information that is reasonably certain to have a substantial effect on the price of a company’s securities. It may have a negative or positive impact on a company’s share price. The kinds of information that our Company could have about a client that should be considered material include, but are not limited to:
Information is non-public until it has been effectively communicated to the market place. A person must be able to point to some fact to show that the information is generally public. For example, information is public if it can be found in a report filed with the SEC, appears in The Wall Street Journal or Bloomberg, is included in televised business or financial programs, or is contained in other publications or media which have a general circulation such that they could be considered public.
A person in receipt of material non-public information may be under a duty not to disclose it or otherwise use it in any way. If such a duty exists, the law prohibits that person (and any other person who understands the manner and obligations under which the information was learned) from trading or communicating the information to others who may trade. For such a duty to arise there must be fiduciary or other relationship of trust and confidence. That is, there must be a relationship between the parties to the transaction such that one party has a right to expect that the other party will not disclose any material non-public information or will refrain from trading. The persons described above as “insiders” as well as those identified as “temporary insiders” usually have such an obligation and are prohibited from disclosing the information to others, except in furtherance of a lawful corporate purpose.
An example of misappropriation of material non-public information is when a person who receives the information for a lawful purpose, i.e., to assist a company in some way, instead uses it to benefit him/her or others.
While the above discussion outlines the kinds of activity which are prohibited under the term “insider trading,” it is not all-inclusive. In order to protect the integrity of the Company and preserve the confidence of our clients, any doubts about the propriety of a particular transaction should be resolved by not doing it. Putting the Company’s clients first may result in a temporary restriction on an employee’s freedom to buy or sell certain securities until the confidential information becomes public.
The penalties for violating these principles are very serious. Violations of Company policy will be addressed severely and may result in termination. Under the securities laws, civil and criminal penalties, including fines in excess of $1 million, can be imposed against the Company, and/or its officers, directors and employees where a violation of law has occurred. It is critical, therefore, that all employees understand and adhere to the Company’s policies in this area.
The Company believes that participation in community affairs and political campaigns is an important and worthwhile civic endeavor, and encourages and respects these personal commitments. However, it is the Company’s Policy that your personal political work should ordinarily remain outside the office and not use corporate resources.
Employees engaging in political activities do so as individuals only, not as representatives or agents of the Company. If any Company employee wishes to use his or her skills to support a political party or candidate, such activity must be conducted on the employee’s own time or with official leave from his or her duties at the Company. In particular, the following rules apply:
If you have any questions or need to make special advance arrangements relating to personal political activity, please contact Human Resources.
The Company is prohibited from working on assignments for, and accepting remuneration directly or indirectly from, political parties or candidates for public office. The reasons for the Policy include the recognition that taking political positions or supporting political causes could divide employees and clients.
The Company may, however, compete for and accept government communications accounts, such as tourist commissions, privatization campaigns, or government service contracts (defense services, public issues communications, etc.).
As set forth above in the Policy on Employee Political Activity, the Company does not prohibit employees engaging in personal political activity, as long as such activity is done in compliance with the Policy.
Employees who need help or information regarding the policies in the Code of Conduct are encouraged to discuss that need with their managers, Human Resources, the CEO or the CFO.
Employees who wish to report suspected violations of any of the policies in the Code of Conduct can be assured that their disclosure will not result in retaliation against them.