Ethics & Compliance
At TRECIG, we are inspired and guided by our values: Trust, Respect, Excellence, Collaboration, Innovation, and Giving. By relying on these values, we make a deliberate choice to focus on what is important to us. Our values should always inform our thoughts, words and actions. In that way, they help us create the future we want to experience — and the culture we need to get us there. By committing to a set of shared values, we also promote a more cohesive and supporting organization.
Our Code of Conduct
“Integritas Semper” (Integrity Always), our Code of Conduct, is intended to inspire, guide and enable our best performance — individually and collectively. By helping us identify potentially challenging situations, the Code promotes ethical decision making and conduct. The Code is not simply about avoiding bad outcomes; it is about how we do business. By setting standards and by guiding us in line with our values, the Code helps us to build a strong ethical culture and to achieve our business goals with integrity.
Ethics Resources and Initiatives
TRECIG strives to earn the respect of our customers and shareholders based on the quality of our products and services as well as how we do business. We face a wide range of business and compliance risks, including those associated with corruption.
It is the policy of TRECIG to ensure compliance by its leaders, employees and covered persons, including representatives, consultants and other contracted third parties, with the Foreign Corrupt Practices Act (FCPA), the U.K. Bribery Act and all other relevant anti-corruption laws. TRECIG has a zero-tolerance policy for corrupt behavior.
Our commitment to anti-corruption includes the following:
- Winning Business Solely on the Merits:TRECIG conducts all of its business solely on the merits. We will not bribe anyone to obtain or retain business or secure any other advantage, nor allow anyone to do so for our benefit, in any market — public or private — anywhere. As a general rule, employees cannot seek or accept any payments from anyone doing business with or seeking to do business with TRECIG.
- Books and Records:TRECIG maintains fully accurate and transparent books and records. All assets, liabilities and transactions must be promptly and accurately reflected, and no TRECIG employee must ever make a deliberately false or misleading entry — no matter how small or immaterial — in our books and records. TRECIG maintains a robust audit program to ensure that all of our businesses are upholding these non-negotiable requirements.
- Third-Party Intermediaries:Our third-party intermediaries are subject to similar rules and will be selected after a robust due diligence process aimed at confirming their good business practices. Once on board, they will be trained and monitored. Intermediaries engaged in advocacy and sales on our behalf have limited-term contracts, which cannot be renewed without a refreshed assessment.
- Training:Every TRECIG employee receives annual ethics and compliance training. Anti-corruption compliance is shared through written communication, video-based training, live training, and targeted online and in person training for high-risk personnel with messages encouraging employees to identify issues, ask questions and raise concerns without the fear of retaliation, emphasizing the importance of training, and providing guidance on areas of particular concern to help all employees understand key anti-corruption responsibilities and their personal role in guaranteeing compliance with anti-corruption laws.
- Assessment:TRECIG regularly assesses and reviews the implementation and sustainment of its anti-corruption controls and continually reviews and assesses our anti-corruption policies, training and practices.
- Reporting and Investigations:In conducting investigations, TRECIG is objective, thorough and balanced. In managing risk, TRECIG is conservative and data-driven. We communicate lessons learned from Investigations and apply robust processes and practices for continuous improvement and risk reduction.
In standing by our principles and values, we fight corruption and support the global development of fair markets. Our success relies on abiding by our core principles — regardless of what might be seen as customary or acceptable in a given market.
TRECIG promotes behaviors that build trust, respect and accountability. When employees, contractors and partners observe or suspect something that conflicts with our values, we encourage them to speak up and report it. Those who speak up to protect our company will be protected in return. Our Code of Conduct and policies reinforce our long-standing commitment to a safe reporting environment that is free of fear, bullying and other negative consequences. TRECIG has zero tolerance for retaliation and activities that impact good-faith reporting — and anyone engaging in retaliatory behavior is subject to disciplinary action, up to possible termination. Employees should feel confident asking questions or raising concerns directly with their supervisor, a human resources manager, or an Ethics & Compliance Officer.
How We Manage Enterprise Risk
At TRECIG, we aim to be world-class in everything we do — including our compliance with U.S. and other national laws. Every employee is responsible for ensuring that our business is conducted in compliance with these laws and with our Code of Conduct. Our Enterprise Risk Management assessments measure compliance risks, deploy risk mitigation plans and track implementation for five key areas:
TRECIG has an aggressive antitrust compliance program that promotes and protects competition. We prohibit actions and behavior that support a company’s monopoly or unreasonably restrains competition.
TRECIG does not offer or accept bribes, kickbacks, facilitating payments or anything of value that could improperly influence — or appear to influence — a business decision. Doing so is in direct conflict with our commitment to fair competition. We compete on the merits of our products, services and people each and every day.
Data Privacy and Security
TRECIG is committed to protecting the personal and proprietary information of Its customers, employees, contractors and business partners.
TRECIG focuses on competing fairly, delivering quality products and services, adhering to government accounting and pricing requirements, and the timely and accurate submission of data to the government.