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Code of Conduct

Chaine is committed to serving our customers and employing individuals with personal standards consistent with that of our Values . This Code is designed to deter wrongdoing and to promote:

  • Honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships.
  • Full, fair, accurate, timely, and understandable disclosure in reports and documents we file with regulatory agencies and in our other public communications.
  • Compliance with applicable laws, rules, and regulations.
  • The prompt internal reporting of violations of this Code.
  • Accountability for adherence to this Code.

Our Code applies to all directors, officers, employees, and contractors of Chaine and its affiliates and subsidiaries. Agents and vendors of Chaine are also expected to read, understand, and abide by this Code.

This Code should help guide your conduct in the course of our business. Many of the principles described in this Code are general in nature, and the Code does not cover every situation that may arise. Use common sense and good judgment in applying this Code. If you have any questions about applying the Code, please seek guidance. Not all information regarding the conduct of our business is found in this Code.

The Code of Conduct will be reviewed on an annual basis to ensure compliance with applicable laws and industry standards.

Discrimination

Having a diverse workforce, made up of team members who bring a wide variety of skills, abilities, experiences and perspectives, is essential to our success. We are committed to the principles of equal opportunity, inclusion, and respect. All employment-related decisions must be based on company needs, job requirements, and individual qualifications. Always take full advantage of what our team members have to offer; listen and be inclusive.

  • We do not tolerate discrimination against anyone, including team members, customers, business partners, or other stakeholders, on the basis of race, color, religion, national origin, sex (including pregnancy), age, disability, HIV status, sexual orientation, gender identity, marital status, past or present military service, or any other status protected by the laws or regulations in the locations where we operate.
  • We comply with laws regarding employment of immigrants and non-citizens and provide equal employment opportunity to everyone who is legally authorized to work in the applicable country.
  • We provide reasonable accommodations to individuals with disabilities and remove any artificial barriers to success.

Report suspected discrimination right away and never retaliate against anyone who raises a good faith belief that unlawful discrimination has occurred.

Confidential Information

Our customers trust us with their confidential information and data. It is important not to disclose confidential information about Chaine or Chaine's customers to anyone.

All of us should avoid conflicts of interest and circumstances that reasonably present the appearance of a conflicts.

Chaine's intellectual property rights (our trademarks, logos, copyrights, trade secrets, code) are among our most valuable assets. Unauthorized use can lead to their loss or serious loss of value. Chaine's logo should not be used for any commercial venture without prior approval. Our customer's intellectual property should be protected in the same way as well.

As with intellectual property, financial information regarding Chaine or its customers should not be shared with anyone. This includes company information that could influence stock prices, which is insider trading and is illegal.

Harassment

Every employee or contractor has a right to a work environment free from harassment, regardless of whether the harasser is a co-worker, supervisor, manager, customer, vendor, or visitor. As is the case with any violation of the Code of Conduct, you have a responsibility to report any harassing behavior or condition, whether you are directly involved or just a witness.

There are two types of Harassment, Sexual and Non-sexual. Sexual harassment includes sexually inappropriate images, videos, emails, and notes. It can also include inappropriate sexual gestures and inappropriate touching. Non-sexual harassment can include using racist slang, phrases, or nicknames, making negative comments about an employee's personal religious beliefs, sharing inappropriate images, videos, emails, or notes, and wearing clothing offensive to an ethnic group. Harassment of any kind will not be tolerated at Chaine.

Complying with the Code

To maintain the highest standards of integrity, we must dedicate ourselves to complying with this Code, company policies and procedures, and applicable laws and regulations. Violations of this Code not only damage our company’s standing in the communities we serve, they may also be illegal. Team members involved in violating this Code will likely face negative consequences. Chaine will take the appropriate disciplinary action in response to each case, up to and including termination. In addition, team members involved may be subject to government fines, or criminal or civil liability.

Reporting Violations

If you think this Code or any Chaine policy is being violated, or if you have an ethics question, you have several options:

  • Discuss the issue with your supervisor or manager.
  • Discuss the issue with another supervisor or manager.
  • Contact Chaine's HR Department

All reports (formal or informal) made to a Chaine supervisor, manager or executive should be promptly escalated to the Chaine's HR Department. Chaine will then review the report promptly and thoroughly to determine if an investigation is warranted.

Investigation Process

If the HR Department has determined it appropriate, Chaine will promptly initiate an appropriate investigation into all possible violations of law and/or Chaine policy. The HR representative will investigate all reports unless:

  • the complaint is against a member of the HR Department team, in which case the investigation will be conducted by Legal (internal Head of Legal or outside counsel, as appropriate).
  • if the case requires the HR to investigate in their own client group, the HR Department and the Head of Legal will determine if an HR representative not supporting the group should lead the investigation.
  • the complaint is made against a member of the executive team or there are multiple complainants regarding the same individual and/or issue, then outside counsel will be retained by the Head of Legal to conduct the investigation. The Board of Directors will be notified of any complaints made against a member of the executive team alleging illegal conduct and/or egregious unethical conduct.

If the complaint involves a member of the executive team that has direct oversight for the Legal department or involves a member of the Legal department, then the Head of HR will work with outside counsel to conduct the investigation. If the complaint involves a member of the executive team that has direct oversight for the HR Department, then Legal will work with outside counsel to conduct the investigation.

Chaine expects all employees and contractors to cooperate fully and candidly in investigations.

Investigation Timeline

Chaine will make all reasonable efforts to initiate an investigation into the allegation(s) and conclude the investigation in a timely fashion. Depending on the type of investigation the steps and timeline for each investigation will vary.

Investigation Findings

The investigation findings will be reported back to the Hr Department. Based on the investigation findings, the HR Departmenmt will make a determination as to whether the allegation(s) were founded, unfounded or inconclusive. This determination will be documented in writing and made part of the investigation report. The determinations are as follows:

  • Violation Found: Where a violation of Chaine policies, workplace rules or law is found to have occurred, the HR Department will review the findings and make a recommendation for corrective action to the executive leader of the accused's reporting line. Together, the HR Department and the business unit will determine the proper corrective action. If the accused is a member of the executive team then the HR Department will confer with the CEO, and where necessary, the Board of Directors. Once corrective action has been determined, the accused will be notified of the finding and of the specific corrective actions to be taken. The accused employee's manager will also be notified if appropriate. No details about the nature or extent of disciplinary or corrective actions will be disclosed to the complainant(s) or witness(es) unless there is a compelling reason to do so (for example, personal safety).
  • No Violation Found: In this situation, the complainant (if known) and the accused should be notified that Chaine investigated the allegation(s) and found that the evidence did not support the claim.
  • Inconclusive investigation: In some cases, the evidence may not conclusively indicate whether the allegation(s) were founded or unfounded. If such a situation occurs, the complainant (if known) and the accused will be notified that a thorough investigation was conducted, but Chaine was unable to establish the truth or falsity of the allegation(s). Chaine will take appropriate steps to ensure that the persons involved understand the requirements of Chaine's policies and applicable law, and that Chaine will monitor the situation to ensure compliance in the future.

Open Door Policy

We encourage maximum communication between team members at all levels of the organization. This is an important part of our culture. Whenever problems or concerns arise, it is expected that they will be addressed as quickly as possible. Your immediate manager is the person on the management team who is closest to you and your work. When you need help or have questions, complaints, problems or suggestions, please contact your manager first. It is your manager's responsibility to assist you - so please ask, and be willing to work the issue out with your manager. They are interested in your success, the success of every team member in their department, and the overall success of Chaine.

If your manager cannot help you or answer your questions, your questions will be referred to someone who can. If you feel your particular question, concern or suggestion cannot be discussed with your manager, you are encouraged to contact your manager's manager, the Head of Legal, the HR Department, or the CEO. It is important to remember that a team member who takes these steps will not be reproached. You can expect to be treated fairly and with respect.

Conclusion

Chaine expects employees to use good judgment and to hold themselves to the highest standards of conduct. It is not possible to spell out every possible ethical scenario that employees might face but expects employees to use good judgment and integrity for themselves and for the company. Identifying the right thing to do is not always easy, if you are unsure or have questions please reach out to your manager or HR.