Code-of-Conduct-Policy.pdf

Good faith is when the employee has reasonable and

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Good faith is when the Employee has reasonable and genuine belief that the unethical conduct has occurred or is occurring and is not making the disclosure for personal gain or with an improper motive. Reporting and investigations The Vice President, Corporate Affairs and General Counsel (“VP Corporate Affairs”) , and Vice President Finance & Technology and Chief Financial Officer (“VP Finance & Technology”) are responsible for jointly leading all internal investigations into real or suspected unethical conduct or violation of the Code at ISC except those involving the President and CEO, members of the Executive or members of the ISC Board of Directors. Upon completion of the investigation the VP Corporate Affairs and the VP Finance & Technology will provide a report of the findings to the President and CEO and the Governance and Nominating Committee for appropriate action. The Governance and Nominating Committee will provide a report to the Board of Directors annually. Findings related to an investigation that is financial in nature will also be reported to the Audit Committee. When making a report you should try to include or be able to provide the following: the details of the situation, the person(s) involved, how frequent the unethical conduct or violation of Code has occurred or is still occurring, any other avenues that you may have taken to try and rectify the problem, and your contact information (if you are comfortable in providing this). If you are aware of real or suspected unethical conduct or a violation of the Code, you have a responsibility to report and you have a number of options for reporting the occurrence: Talk to your manager. If you feel comfortable making a report to your manager or another manager/director this is always an option. Managers must involve the VP Corporate Affairs or the VP Finance & Technology in all reports of unethical conduct or violation of the Code at ISC. Make a report to the VP Corporate Affairs or the VP Finance & Technology . If you suspect or know of unethical conduct or violation of the Code at ISC you may submit a report to either of these people in person, by email, telephone or anonymously in writing. Make an anonymous report to Clearview. Clearview is a third party reporting agency used to make anonymous reports of unethical conduct or violation of the Code. If for any reason you feel uncomfortable making a direct report to someone at ISC you can contact the 24/7 anonymous hotline or use the online form to make a report. Your identity will be protected and the unethical conduct or violation of the Code can still be investigated and dealt with. The
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ISC Code of Conduct Policy Page 13 hotline number is 1-877-257-8439. You may also visit the Clearview website: .
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  • Fall '19
  • vice president, isc, Conflict of interest

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