Code of Conduct & Ethics for Service Providers

PURPOSE AND SCOPE

Cullari Communications Global (“CCG”) is committed to operating in the public interest and maintaining high ethical standards and conduct in our business. This Code of Conduct/Ethics for Service Providers outlines the principles, values, and behavior standards to ensure trust among CCG and its stakeholders.  It also sets forth the rules that subcontractors, freelancers, and other third parties (“Our Suppliers”) must follow when facing ethical dilemmas in the workplace.  While the issues that affect business relationships are constantly evolving for various reasons, including regulatory variables, this Code includes provisions including:

• Rules of Engagement

• Honesty & Transparency 

• Fair Dealing

• Improper Incentives

• Anti-corruption & Bribery

• Intellectual Property & Information Security

• Human Rights

• Conflicts of Interest

• Economic Sanctions

• CCG policy enforcement

RELATED CCG POLICIES

• CCG Compliance & Risk Management Policy

• CCG Data Breach Policy

• CCG Data Privacy Policy

• CCG Data Retention Policy

• CCG Third-party Payment Policy

• CCG Diversity, Equity & Inclusion Policy

• CCG WhistleBlower Protection Policy

To request our full list of policies, please contact us at the email provided at the bottom of this document.

CCG DOES NOT VIOLATE LEGAL OBLIGATIONS 

When providing goods and services to CCG or our clients, our suppliers must respect and comply with the laws of the nations, regions, states, and cities in which they operate. Our suppliers acknowledge that CCG is a limited liability company in the United States, and they are therefore aware that services provided to CCG or its clients are subject to all applicable local and regional laws and regulations, as well as those of the United States.

BUSINESS ACTIVITY ALIGNMENT AND BEST PRACTICES

CCG acts as a responsible advocate for our clients. Our Suppliers’ business activities should be guided by a balanced consideration of the interests of all stakeholders, including our clients and the general public. Our Suppliers may not unduly favor the interests of one to the detriment of another or society at large. Our Suppliers must take action to avoid any action that may discredit our client, CCG, or our profession.  

RULES OF ENGAGEMENT

Our suppliers must adhere to the customs, rules, practices, and codes of conduct relevant to our industry and practice areas in all countries where we operate. This includes respecting the guidelines related to our clients, colleagues, and fellow professionals. Our suppliers must conduct themselves to uphold the integrity of public communication channels and respect the independence, rights, rules, and guidelines. By agreeing to provide services for CCG or CCG clients, our suppliers hereby agree to comply with the following standards in all business dealings related to CCG.

HONESTY

We are committed to building trust with the public by providing all information necessary for informed and responsible decision-making. 

• We uphold the highest standards of accuracy and truth in advancing our client's interests and communicating with the public. 

• We do not intentionally disseminate false or misleading information or omit critical information, which is essential to avoid misinformation. 

• Before releasing any information on behalf of our clients, we take reasonable steps to assess the reliability and basis for claims.

• We promptly coordinate with our client to appropriately respond to any erroneous communications for which we are responsible.

TRANSPARENCY

Our Suppliers must not act in any way that may appear to be an attempt to deceive public opinion when performing services for CCG or our clients.

FAIR DEALING & FAIR BUSINESS PRINCIPLES

Our Suppliers must deal fairly with clients, competitors, peers, vendors, public officials, the media, patient advocacy organizations, and the general public. The following principles promote healthy and fair competition among Our Suppliers and preserve an ethical climate while fostering a robust business environment:

• At CCG, we believe in creating opportunities for diversity within our team of professional consultants.

• Transparency and accountability across all CCG clients and staff enable us to collaborate in decision-making processes. Communication is open at all service levels.

• CCG is a certified Women-owned Small Business enterprise. We strive to maintain long-term relationships based on solidarity, trust, and mutual respect that promote growth and fair business practices.

• At CCG, we communicate effectively with our clients and work cooperatively with in-country Fair Business organizations to avoid unfair business competition. Fair Business recognizes, promotes, and protects the cultural identity and traditional skills of independent consultants who support CCG and our client’s needs.

• Payment of a Fair Market Value for our services is mutually agreed upon through dialogue and participation.  Fair pay means the provision of socially acceptable remuneration (in the local context) considered by our clients but also considers the principle of equal pay for equal work.

• We ensure that no child or forced labor is part of any service we provide on behalf of CCG and our clients.

IMPROPER INCENTIVES

Our Suppliers must not directly or indirectly offer bribes, kickbacks, or anything else of value that could be interpreted as an attempt to fraudulently or unethically obtain or retain business on behalf of CCG. Business gifts and entertainment must meet applicable legal, ethical, and cultural norms to preserve the free flow of unbiased information.

ANTI-CORRUPTION & BRIBERY 

(Also included in CCG's Compliance & Risk Management Policy)

In conducting business for CCG and its clients, Our Suppliers must comply with applicable anti-corruption and anti-money laundering statutes. As such, our Suppliers must ensure that no payment, gift, contribution, bribe, rebate, payoff, kickback, or anything else of value is offered, authorized, promised, or paid, directly or indirectly, to (i) obtain or retain business for or with, or direct any business to, any entity or individual; (ii) obtain favorable treatment, special concessions or other improper business advantages; (iii) influence that person to act, make a decision, exercise discretion, pass judgment, fail to act, or make an omission in breach of a duty of good faith, impartiality or trust ("Acting Improperly"), or (iv) otherwise reward that person for acting Improperly.  

MANDATORY COMPLIANCE, ANTI-CORRUPTION, & BRIBERY TRAINING

All CCG Suppliers must complete an annual mandatory compliance training provided online by Traliant, an independent third-party compliance training vendor. This training covers the applicable laws relating to new anti-bribery and corruption regulations, compliance, other risk areas, and related policies and procedures. Traliant will provide each CCG consultant with a formal Certificate of Compliance Training Completion upon completing this training. Every CCG consultant must provide their compliance training completion certificate to CCG's COO before finalizing their annual consultant agreements. 

RESPECT AND PRESERVATION OF INTELLECTUAL PROPERTY 

Our Suppliers must respect and preserve intellectual rights in the marketplace. 

PROTECTION OF CONFIDENTIAL INFORMATION 

The nature of our work often gives us access to confidential information that is not available to the public. If disclosed, this information could be useful to competitors or harmful to us or our clients. Our Suppliers must protect confidential or other sensitive information related to CCG and current, former, and prospective clients. They may not use such information to further their interests or in violation of applicable insider trading regulations. 

PRIVACY & DATA PROTECTION 

Our Suppliers must comply with all applicable data protection and privacy laws and regulations, including the E.U. General Data Protection Regulation (GDPR) and other laws related to collecting, storing, transferring, and processing personal data. 

HUMAN RIGHTS

Our Suppliers must support and respect the free exercise of human rights, not only those in the workplace but also those relating to the freedom of speech and of association, which affect the right of the individual to give and receive information. Compensation, working hours, and minimum age requirements should meet applicable regulatory standards. Forced or involuntary labor may never be used. Employees must be treated with dignity and respect and provided with a work environment that is free from discriminatory practices, harassment, and abuse based on race, color, religion, creed, gender, nationality, ancestry, citizenship, political affiliation, sexual orientation, disability, age, gender identity or expression, genetic information, pregnancy, personal appearance or family responsibilities; or on protected veteran, military, parental or marital status, or any other protected status. 

CONFLICTS OF INTEREST

When performing services for CCG or our clients, Our Suppliers must avoid actions and circumstances that appear to compromise good business judgment or create actual, potential, or perceived conflicts between personal and professional interests. 

Our Suppliers must notify CCG's COO of any potential conflicts they identify. 

QUALIFICATIONS & EXPERTISE

Our Suppliers should only accept work for which they are suitably skilled and experienced. 

ECONOMIC SANCTIONS

CCG complies with trade sanctions that apply to our business in all countries and applicable jurisdictions, including those enforced by the U.S. Office of Foreign Assets Control (OFAC). In agreeing to do business with CCG, Our Suppliers hereby certify that neither they nor their beneficial owners are included on the OFAC Specially Designated Nationals (SDN) list, nor any other blocked party or debarment listing that may be applicable and may impact CCG or its clients’ ability to do business with Our Suppliers.

ENFORCEMENT OF THE CCG CODE OF CONDUCT/ETHICS

To enforce this Code, CCG is committed to enabling and encouraging our supplier's awareness and involvement due to their close visibility of potential breaches of ethics provisions.  To do so:

• As part of their annual contract review, Our Suppliers must sign a verification of acknowledgment and review the CCG Code of Conduct/Ethics.  

• The CCG Whistle Blower Policy provides Our Suppliers with guidance on how to use the procedure to report activities believed to be illegal, dishonest, unethical, or otherwise improper. 

• A secure, internally administered communication email address has been established.

• CCG’s COO is responsible for processing and responding to inquiries or grievances.

• CCG commits to confidentiality/non-retaliation towards any report made in good faith.

CONTACT DETAILS 

For questions or concerns about this Policy, please contact kcullari@cullarigroup.com.