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Fair Dealing We are committed to following fair dealing principles in all of our business activities. These include rules that are frequently referred to as “competition” or “antitrust” laws. The purpose of these laws is to preserve a competitive economy in which free enterprise can flourish. Our Code’s insistence on full compliance with such laws is based on both our desire to follow the law, and our conviction that the protection of a free, competitive economy is essential. Competition laws generally prohibit agreements between competitors relating to: u Prices u Division of markets u Allocation of clients u Any other activity that restrains competition, whether by vendors or clients We are committed to making business and commercial decisions solely on the basis of our Company’s best interests. We never make these decisions on the basis of understandings or agreements with any competitor. Because we are committed to complying with all competition laws, we should avoid any conduct or behavior that violates or appears to violate them. Should these topics arise in any conversation with a competitor, end the conversation immediately. While industry association meetings and other events provide opportunities for networking and generating business, they also pose certain risks. When we participate in these events, we must see to it that we prevent even the suggestion of unethical business practices. 15 Acting Responsibly with Honest and Integrity Crawford & Company Code of Business Conduct and Ethics
Derek attends an insurance industry association meeting. At lunch with his colleagues from competing organizations, the discussion turns to pricing. One attendee suggests that if they don’t discuss specific price levels, perhaps those gathered could agree not to engage in a price war. How should Derek respond? Around the world, various competition laws bar agreements between competitors that relate to the prices they charge, whether or not specific prices are discussed. On hearing his colleague’s suggestion, Derek should immediately leave the lunch gathering and contact Crawford’s Legal Department or the Confidential AlertLine. Simply being present during illegal conversations, even unintentionally, may lead to consequences under competition laws. For this reason, Derek should protect himself by reporting the incident. Fraud We are committed to upholding the integrity of our Code and business operations. This commitment means that we will not tolerate fraud, dishonesty, or criminal conduct of any kind. If you suspect that a fraudulent or criminal act has occurred, immediately report your concern to: u Your manager or the person to whom you report u Another appropriate manager u The Legal Department u The Confidential AlertLine All reports will be taken seriously and investigated promptly. As with all other violations of our Code, appropriate discipline will be administered—up to and including termination of employment—if any investigation confirms wrongdoing. Crawford & Company Code of Business Conduct and Ethics Acting Responsibly with Honesty and Integrity 16
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 and 18: International Trade Controls As a g
Page 19: Additionally, we have a responsibil
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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