CRA Europe subscribes to the Code of Ethics of the CRA Family of Companies, and we have established our own policies to support it.
This Code of Business Ethics (Code) reflects the principles of the CRA Family of Companies applicable in the ethical conduct of all CRA businesses. The matters referenced in this Code apply both domestically and internationally and are intended to apply to business dealings and transactions of any member company of the CRA Family of Companies. This will include both directly and indirectly owned subsidiaries of CRA Holdings Inc. and will also apply to all partly-owned companies (all of whom are hereafter collectively called “CRA”). This Code is intended to supplement, not to replace, existing CRA policies applicable to the workplace.
CRA professionals are also expected to be aware of and to comply with those codes of ethics of professional licensing organisations applicable to them.
The purpose of this Code is to protect the integrity of CRA, protect its employees from potential liability, and provide a level of protection for business interests of CRA clients as they may relate to CRA activities.
Commitment to Legal and Ethical Conduct
CRA will conduct its business and affairs in accordance with the letter and spirit of all applicable laws in the countries in which it operates. If any CRA employee or representative is ever uncertain as to the interpretation or application of a particular law, he or she should seek advice through contacting a Principal and CRA legal counsel before taking action. Compliance with the law may however, in some instances, fall short of ethical conduct expected by CRA.
Accordingly, it is CRA’s policy that each employee and representative conduct CRA’s business with honesty, integrity, and fairness. It is also CRA policy that all communications be truthful and transparent in a way that will withstand public scrutiny. Working relationships will be based on candor and openness, treating each other with respect, while acting with integrity and weighing responsibilities to all parties.
The laws of nearly all countries create criminal offences for bribery and money laundering. In some cases criminal sanctions can apply to both corporations and individuals. Under no circumstance will CRA’s employees, either directly or indirectly, knowingly offer or give a bribe. An example of a bribe would include a payment, gift, or benefit made to an official representing a public or private organisation for the purpose of obtaining a business advantage by influencing the judgement of the official in connection with a decision to award business, continue business, or regarding the terms of doing business. CRA will not be engaged in a transaction that involves the offer or giving of a bribe, and will use reasonable diligence and care not to be engaged in such a transaction unknowingly.
Conflicts of Interest
All CRA employees are expected to make business decisions in the best interests of CRA and its clients without conflict with an employee’s personal interests. A conflict of interest may arise if a CRA employee is in a position of choosing between CRA’s best interest or that of a client and his or her own interests. To ensure that an employee’s personal interests do not conflict, or appear to conflict with the interests of CRA or its clients, CRA employees must strive to keep the use of his or her judgement free of any personal or financial interests that may arise from business dealings, social ties or other considerations, whether personal or related to the interests of third parties. A conflict would exist if the nature and extent of the personal interest may affect or call into question an employee’s independent judgement. Proper use of professional judgement would include disclosing the conflict or potential conflict in writing to a supervisor or to a Principal and/or the President of CRA.
CRA employees may not engage in any outside work or business activity:
a) That conflicts with their duties as CRA employees
b) That will require use of their knowledge of confidential plans, projects or information, or use of equipment of CRA or its clients
c) That will or is likely to negatively influence or affect them in carrying out their duties as CRA employees
CRA employees are not to receive any cash, or to receive gifts, services, or inducements that by reason of their nature or value may call into question the employee’s impartiality, objectivity, judgement, or performance of duties at CRA. Allowable items not in conflict with this policy would be the receipt by a CRA employee of a gift, on an infrequent basis in respect to the same party, of nominal value (such as a promotional item), business luncheons, or entertainment within normal standards of applicable business hospitality.
Likewise, CRA employees are expected to not provide gifts or inducements to other parties that by reason of their nature or value may call into question the party’s objectivity and impartiality in any dealings with CRA. Providing gifts or entertainment is appropriate only if it is legal, it is done infrequently, it is in CRA’s business interest to do so, it is within applicable local business custom, and the recipient’s policies permit acceptance.
Confidentiality of Information
CRA will respect the privacy of information of its employees and clients. Confidential information in CRA’s possession will be used only for the purpose for which it was intended.
In connection with business operations and the administration of CRA, CRA employees have access to and receive sensitive or confidential information that may be the property of CRA, an individual employee, or that of a client. The improper disclosure of such information or the improper use of such information could cause significant harm or loss, and in certain circumstances may violate privacy laws. Accordingly, employees and representatives of CRA must continually use care in the handling of such information so that it is not disclosed to anyone inside or outside of CRA who is not authorised or legally entitled to receive it.
CRA employees and representatives are expected not to knowingly accept or receive confidential information of other parties, unless in connection with a proper CRA business purpose and with the consent of the owner of the information.
Failure to Comply
Employees who fail to comply with the above Code are subject to potential disciplinary action up to and including dismissal, and may also be subject to legal liability associated with any violation or non compliance with a criminal or civil law.