【正文】 y words, acts, jokes, threats, or printed materials which demean or show hostility to an individual race, color, religion, gender, nationality, age, sexual orientation, or disability. 27 professionalstandards ?Our policy on insider trading provides the greatest protection to both individual employees as well as to the firm (designed to prevent any violations of securities laws, inadvertent or otherwise, as well as to avoid the appearance of improper conduct on the part of anyone employed at our firm). ?You are prohibited from trading, and from tipping others to trade, in a pany39。 Company letterhead may only be used for 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。 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 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。 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。 mechanism for mediation –Management reinforce (actively), interpret, apply, provide incentives/disincentives Program Description (3 of 4) 9 professionalstandards ?How –through local resources (Professional Standards Managers coordinated with the Center) –worldwide training for all levels –role modeling at the team level –local munications and marketing coordinated by the center (., intra) –internal/external marketing –incentives and disincentives –BVU Program Description (4 of 4) 10 professionalstandards Agenda ?Compliance and Introduction ?Policies ?Cases ?Sources of additional information 11 professionalstandards Professional Standards Policies ?Protecting and sharing client information ?Competitor 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。 Company is dedicated to helping our clients achieve outstanding results. As such, we pride ourselves on having the most rigorous standards in the consulting industry with respect to confidentially and conflict of interest. Confidentiality of data: ?Our goal is absolute protection of proprietary client data ?Ri