our code of conduct

RESPECT FOR OUR EMPLOYEES

We believe our most important strength is our employees. We seek to provide a work environment where all employees have the opportunity to reach their full potential and contribute to IRSC’s success. We emphasize personal integrity and believe long-term results are the best measure of an employee’s performance.

IRSC respects the human rights and the dignity of all employees. We endeavor to treat our employees fairly and honestly. We strive to maintain a safe, secure, and healthy workplace and it is against our policy to use forced or child labor. We also strive to follow all applicable employment laws and regulations.
We are committed to equal opportunity in all aspects of employment for employees and applicants. This means providing a workplace free from any form of discrimination or harassment, including sexual harassment. We seek to create a work environment where people feel comfortable and respected, regardless of individual differences, talents, or personal characteristics. Our objective is for the diversity of our employees to reflect the diversity of the population wherever we operate and for the performance of all employees to be judged fairly and based on their contribution to our results.

IRSC encourages an inclusive culture, which enables all employees to do their best. This means we:

• Welcome and embrace the strengths of our differences,
• Treat each other with respect and fairness,
• Foster an atmosphere of trust, open communications, and candor.

We recognize the needs of individuals to achieve professional and personal balance in their lives. We also respect employee privacy and will acquire and retain only that employee’s personal information that is required for the operation of the Company’s business or required by law.

CONSUMERS, CUSTOMERS, SUPPLIERS, AND COMPETITORS

In all of our business dealings with consumers, customers, suppliers, and competitors, we will:

• Avoid any unfair or deceptive practices and always present our services and products in an honest and forthright manner.
• Treat all customers and suppliers honestly, fairly, and objectively.
• Select suppliers based on merit, and make clear to all suppliers that we expect them to compete fairly and vigorously for our business.
• Compete vigorously and with integrity.

BUSINESS GIFTS AND ENTERTAINMENT

Our business decisions are made on merit. Therefore, we will never give or offer, directly or indirectly, anything of value to a third party, including a government official, political party, or candidate, to corruptly influence that person’s business decision or gain an unfair advantage. We will observe IRSC’s International Anti-Bribery Policy at all times. Giving gifts or entertainment to governmental officials is highly regulated and often prohibited. Such gifts and entertainment should not be provided unless you have received Law Department approval.

Gifts or entertainment given to or received from customers or suppliers must never influence, or appear to influence, business decisions. There must be a legitimate business purpose for any business gift or entertainment, it must be in good taste and it must be consistent with the law, with the giver’s and receiver’s policies, IRSC’s policies, and your function/division policies (including the Travel and Entertainment Policy). If business gifts are permitted under your function/division policies, they must be nominal in value and frequency.

HEALTH AND SAFETY

IRSC is committed to providing safe and healthy work environments at its facilities for all its employees, visitors, and contractors. It is our policy to provide employees with a drug-free workplace. In order to create an environment free from threats, violence, and intimidation, we are committed to a policy of zero tolerance for violence.

We are dedicated to designing, constructing, maintaining, and operating facilities that protect our people and physical resources. It is our policy to comply with all applicable health and safety laws and regulations, provide and require the use of adequate protective equipment and measures, and insist that all work be done in a safe and responsible manner. It is the responsibility of each employee to follow all Company policies and procedures related to workplace health and safety.

ENVIRONMENT

IRSC is committed to being a responsible corporate citizen. We are committed to minimizing the impact of our businesses on the environment with methods that are socially responsible, scientifically based, and economically sound. We encourage conservation; recycling and energy use programs that promote clean air and water reduce landfill wastes and replenish the planet’s natural resources. We will follow applicable environmental laws and regulations in the countries where we operate.

CONFLICTS OF INTEREST

IRSC’s conflicts of interest policy is straightforward. All actual or apparent conflicts of interest between personal and professional relationships must be handled honestly and ethically. You must disclose any potential conflict of interest to your supervisor as soon as you become aware of it.

Examples of conflicts that must be disclosed and resolved include:

• Receiving any financial or personal benefit either yourself or through a family member from a company that does or seeks to do business with IRSC.
• Serving on the board of directors or providing consulting services to a company that does or seeks to do business with IRSC.
• Having outside business interests that could affect your job performance because of the amount of time and attention diverted from your responsibilities to IRSC.

CONFIDENTIAL INFORMATION AND INSIDER TRADING

While engaged in IRSC business, you may receive or learn of confidential, competitively sensitive or proprietary information that has not been disclosed to the public. Confidential or proprietary information includes all nonpublic information that, if disclosed, might be of use to competitors or might be harmful to IRSC, our suppliers, or our customers.

You always have a duty to protect the confidential information of IRSC and our business partners. You may not disclose confidential information to anyone outside IRSC, even to members of your own family, unless there is a clear business need to do so, the party receiving the information has signed a confidentiality agreement committing to maintaining the information’s confidentiality and you believe that the disclosure will not harm or embarrass IRSC or its business partners.

Employees should not disclose material, non-public information about IRSC or another company to anyone outside the Company, including family members.

PROTECTION AND PROPER USE OF COMPANY ASSETS

IRSC’s technological resources, including computers, voicemail, e-mail, and Internet access, are to be used for proper purposes in a manner consistent with the Code and all other Company policies, including those related to discrimination, harassment, and intellectual property. As with all IRSC assets, these resources are to be used for business purposes.

It is generally not IRSC’s intent to monitor Internet access or messages on the voicemail and e-mail systems. However, the Company reserves the right to do so in appropriate circumstances, consistent with applicable laws and regulations.

If you have access to IRSC information systems, you are responsible for taking the precautions necessary to prohibit unauthorized access to the system. You should safeguard your passwords or other means of entry.

Employees must not reproduce software assets licensed to IRSC, use illegally obtained software, or distribute the original software media or unauthorized copies of software that the Company does not own or license.

RESPONSIBILITY FOR COMPLIANCE

All employees are expected to display responsible and ethical behavior, to follow consistently both the meaning and intent of this Code, and to act with integrity on a daily basis. Managers and leaders are expected to ensure that our business processes and practices reinforce the Code, serve as positive role models by establishing and adhering to high ethical standards, and create an ethical culture by encouraging and rewarding actions that are consistent with the Code.

This Code cannot provide definitive answers to all questions. For that, we must rely on each person’s judgment and integrity. You are encouraged to seek guidance when a situation may not be clear. Your supervisor, Human Resources manager, or the IRSC Law Department will respond to questions and issues of interpretation about this Code.