CxO Coaching Integrity Compliance Program
1. Introduction: The purpose of the Integrity Compliance Program is to ensure that CxO Coaching operates in an ethical and legal manner. We are committed to maintaining high standards of integrity, professionalism, and accountability. This program applies to all employees, including management and executives, and it covers key areas such as conflict of interest, supplier/customer relationships, anti-trust and price fixing, intellectual property, and anti-bribery and corruption.
2. Conflict of Interest: All employees must avoid situations where personal interests could conflict, or appear to conflict, with the interests of the company. Conflicts of interest can compromise judgement and negatively impact the company's reputation. Potential conflicts should be disclosed to the immediate supervisor, HR, or the Compliance Officer. Non-disclosure can lead to disciplinary action, including dismissal.
3. Supplier and Customer: Relationships Relationships with suppliers and customers should be based on fairness, objectivity, and honesty. Employees must not accept gifts or hospitality that could influence, or appear to influence, their objectivity in business decisions. The company will conduct regular reviews of supplier and customer relationships to ensure compliance with this policy.
4. Anti-Trust and Price Fixing: CxO Coaching adheres to all relevant antitrust and competition laws. Anti-competitive behavior, such as price fixing, collusion, or manipulation of markets, is strictly prohibited. Employees must ensure that all dealings with competitors, clients, and suppliers are fair and cannot be construed as anti-competitive. Any suspected violation should be reported to the Compliance Officer.
5. Intellectual Property: The company respects intellectual property rights and expects the same for its own intellectual assets. All employees are obligated to protect the company's intellectual property and to avoid infringing on the rights of others. The misuse of proprietary information, including unauthorized sharing or use, can lead to disciplinary action and legal consequences.
6. Anti-Bribery and Corruption: CxO Coaching has a zero-tolerance policy for bribery and corruption. Employees must not offer, promise, give, request, or accept any bribe or other undue advantage, whether in dealings with public officials or private sector clients. Any suspicion of bribery or corruption should be reported to the Compliance Officer. Violations can result in severe disciplinary action, including dismissal and legal prosecution.
7. Training and Education: The company provides regular training to help employees understand their ethical and legal responsibilities. Training sessions will cover this program's policies and procedures, as well as specific topics like anti-bribery laws and conflict of interest scenarios. Attendance is mandatory, and non-compliance can result in disciplinary action.
8. Reporting and Whistleblowing: Employees are encouraged to report any suspected breaches of this program. The company provides several secure and confidential channels for reporting, and it safeguards the reporter's identity. Retaliation against whistleblowers is strictly prohibited and will be treated as a serious disciplinary offense.
9. Monitoring, Auditing, and Reviewing: The company conducts regular internal audits to ensure compliance with this program. The Compliance Officer oversees these audits, which involve reviewing business practices, evaluating risks, and making recommendations for improvements. Disciplinary measures for non-compliance range from warnings and retraining to dismissal and legal prosecution.
10. Commitment to Compliance: All employees, including executives and management, are responsible for complying with this program. Management should lead by example, encourage ethical behavior, and foster an environment where employees feel safe to voice concerns. We all play a part in maintaining the reputation and integrity of CxO Coaching.
The company reserves the right to modify this program as necessary to adapt to changes in law, regulations, or business operations. Each employee will be notified of any updates and is responsible for staying up to date and compliant with this program.
Note: at CxO Coaching, our current Chief Executive Officer is the acting Chief Compliance Officer. Please contact him at michel@cxocoaching.io with any concerns.