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We also play an important global role in preventing and detecting money laundering. This means, in part, that we must be careful to avoid transactions that may involve funds from illegal activities. Such activity would violate anti-money laundering laws. In order to safeguard our operations from money laundering, we must: u Conduct proper due diligence on our potential business partners u Perform all applicable identity verifications of our potential partners u Ensure that we only select business partners who conduct legitimate and legal business activities u Participate in financial transactions only after appropriately verifying that the funds involved come from legitimate sources Because money laundering issues are complicated, do not attempt to handle them alone. If you encounter any potential signs of money laundering or other illegal activity, report these to your manager, the Legal Department, or the Confidential AlertLine. 13 Acting Responsibly with Honest and Integrity Crawford & Company Code of Business Conduct and Ethics
Additionally, we have a responsibility to avoid cooperating with any request to participate in unsanctioned foreign boycotts, or related restrictive trade practices. This means that we may not supply any information, perform any action, or make any statement that could make it seem like we are participating in an illegal foreign boycott. The laws that govern these matters carry severe penalties. Our Company must also report any possible boycott requests to the U.S. government. To aid in this requirement, report any information or requests that you think may relate to illegal boycott requests to your manager, the Legal Department, or the Confidential AlertLine. Jena is negotiating a contract to sell our services to an Egyptian organization. When reviewing a draft of the contract, Jena notices that the potential customer has added a section that requires us to limit our business in Israel. What should Jena do once she sees this new section? Jena must immediately involve her manager and the Legal Department as soon as she notices this language in the contract. If she does not report the potential customer’s change to the contract, she and Crawford may face certain penalties under anti-boycott laws. Jena’s manager and the Legal Department will help her find the best way to handle this situation. Crawford & Company Code of Business Conduct and Ethics Acting Responsibly with Honesty and Integrity 14
Page 1 and 2: Code of Business Conduct and Ethics
Page 3 and 4: Our Vision, Values, and Culture Our
Page 5 and 6: 17 Providing Value to Our Clients 1
Page 7 and 8: Our Code’s Coverage We are each r
Page 9 and 10: Resources for Reporting If you have
Page 11 and 12: Protection when Reporting Crawford
Page 13 and 14: We must also pay very special atten
Page 15 and 16: Similarly, we are never permitted t
Page 17: International Trade Controls As a g
Page 21 and 22: Derek attends an insurance industry
Page 23 and 24: Protecting Client Information Our c
Page 25 and 26: Any action creating an intimidating
Page 27 and 28: Data Privacy and Protection At Craw
Page 29 and 30: Providing a Safe and Healthy Work E
Page 31 and 32: Remember, too, that our Company’s
Page 33 and 34: Some of these types of information
Page 35 and 36: Finally, intellectual property (or
Page 37 and 38: We may not make personal financial
Page 39 and 40: Our shareholders and other stakehol
Page 41 and 42: Corporate Social Responsibility As
Page 43 and 44: Contacts with regulators, legislato
Page 45 and 46: Responding to Requests from Governm
Page 47 and 48: Acknowledgment All employees, offic

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