【正文】 data gathering ?Exclusivity and client conflict ?Harassment and discrimination ?Insider trading ?General and Expense Policies 12 professionalstandards –client identity –client internal data –proprietary insights –purchased studies (permission may be overarching at case start) –presentations –proposals –backup information –success stories –general insights –general developed information –publicly available information Information Which can and should be shared Which should be shared once sanitized Cannot be shared without explicit permission from the client No confidential or proprietary information (including the client’s identity and characteristics of the relationship), provided by or obtained for, a client may be given to anyone outside the case team. Information which is neither proprietary nor confidential may be shared only with the express approval of a Bain partner on the originating case, and in many cases, the client. Protecting amp。 bc Professional Standards March 1998 Author: Peter Aman Contributors: Barbara Bjornson Laird Reed Copyright169。 Sharing Client Information Guidelines 13 professionalstandards ?When client information is provided to a peting case team or within a Practice Area, the material must be sanitized by or at the direction of the Operating VP who is then also responsible for approving the final product ?When client information is provided to a nonpeting case team, the process of sanitizing the information may be done by or at the direction of the VP asking for the information but the Operating VP is responsible for approving the final product Sanitizing (or disguising) client information and approving/disapproving munication of the information is the responsibility of the Operating VP who did the work according to the following guidelines: Protecting amp。 Company I am doing market research –I am (your name) a potential investor –I am (your name) a potential customer –I am (your name)。 Company will not accept a client assignment worldwide where in our judgment success would cause an existing client assignment to fail. Under many circumstances, this permits Bain to serve two petitors in an industry. However, this will often restrict staffing and the office involved. To our knowledge, no other leading consulting firm operates a standard this rigorous. Exclusivity and Client Conflict Policy Summary (1 of 2) 25 professionalstandards Formal “performance partnership”: ?Where appropriate, we aspire to agree to formal “performance partnerships” with our clients, aimed at creating sustained exceptional client results. Such arrangements are entirely at the behest of our clients. A “performance partnership” relationship is in no way a requirement by Bain amp。 or –the pany is a Bain client (and appears on Bain39。 however, even if there is no local prohibition on “insider trading”, trading in the stock of a Bain client is not permitted. Insider Trading Policy Summary (1 of 2) 28 professionalstandards ?The “Restricted List” of panies in which employees may not trade is maintained by Local Controllers, Corporate Treasury and possibly the senior Librarian in each local office. ?If you own a security, you may –sell the shares immediately (assuming no issue of insider information) or –hold the shares (either in a “blind” trust or until 3 months after you leave Bain) –in rare circumstances and only with the approval of the Center, you may be able to sell a security on the Restricted List within a prescribed window ?The consequences of insider trading violations can be staggering: –civil fines up to 3 times the profit gained or loss avoided by the trading –criminal fines (no matter how small the profit), of up to $1million –liability to those damaged by the trading –the appearance of improper conduct can have a very serious impact on Bain’s business and financial results –sanctions up to and including termination of employment for cause Insider Trading Policy Summary (2 of 2) 29 professionalstandards General and Expense Policies ?Employees may not violate any criminal or civil laws or regulations (federal, state, or local) as part of any work for Bain amp。 Company ?Additionally, if asked, you must give a truthful description of Bain amp。 Company pursuing workrelated issues (., it is not a personal visit). Similarly, if a signin sheet is presented, you must fill in the spot for “Company” with Bain amp。s pany newsletter lying on a table. Once in your rental car, you proceed to drive around the parking lot and count the number of employee cars to use as a proxy for headcount. You drive into town and hire a local photographer to take aerial photographs of the petitor plant and facilities. Before dashing off to the airport, you swing by the local planning office to have copies of the plant and facility blueprints sent to you back at your office. Complication: (continued) ?Is it correct to participate in a tour of a petitor facility without identifying yourself as a Bain employee? ?Is it correct to take petitor information (newsletter) from the property without their expressed consent or knowledge? ?Is it correct to gather petitor data by roaming the petitor premises (parking lot)? ?Is it correct to gather data by utilizing the services of local businesses and government offices? ?Is it correct to have aerial photographs taken? Questions: Data Gathering on a Competitor Site (2 of 3) 44 professionalstandards ?You may attend tours。 Company letterhead may only be used for Bain amp。 or –the pany is otherwise associated with Bain or a Bain client (and appears on Bain39。 Company worldwide Policy Committee is designated “internal gatekeeper”, to ensure any issues relating to possible conflict