CODE AT A GLANCE
Operating with the highest standards of ethics and integrity is critical to our success. It not only makes good business sense, it also shapes our culture of an open, honest environment. Our goal is to ensure that everyone feels engaged and comfortable raising questions and concerns. Our Code of Ethics lays the foundation for our standard of conduct and provides guidance for how we work. We must all follow these guidelines and hold firm to our principles, no matter what business pressures we face. These guidelines are summarized below
We maintain complete, accurate and timely financial and business records. We do not make false or misleading entries, records or reports. If we are aware of or suspect false or misleading entries or records, we report it to the Company.
RESPONDING TO AUDITS, INVESTIGATIONS AND INQUIRIES
We provide accurate and timely information in connection with investigations and in response to requests from internal and external auditors. We never make false or misleading statements and we retain all documents that relate to imminent or ongoing investigations and never conceal, alter or destroy such documents.
COMPLYING WITH LAWS PROHIBITING INSIDER TRADING
We do not buy, sell or trade in stock or other securities of the Company when we have material information that has not yet been made public. We do not share material non-public information with someone else who might use the information to buy, sell or trade in stock or other securities.
PROTECTION OF CONFIDENTIAL INFORMATION
We protect confidential information about the Company and others with whom we do business. Information generally remains confidential until it has been publically disclosed by the owner of the information. Within Brink’s, we share confidential information only with those who have a need to know the information as part of their job duties.
PROTECTION OF COMPANY ASSETS AND RESOURCES
We ensure that the Company’s assets and resources are not misused, lost, damaged or wasted. We do not use company property for improper personal benefit or any other improper purpose.
PROTECTION OF THE BRINK’S BRAND AND OTHER INTELLECTUAL PROPERTY
The Brink’s brand is one of the Company’s most valuable assets, and we protect it and our other intellectual property from being used improperly by third parties. We also respect the intellectual property of others, and do not use or disclose their intellectual property without proper authorization.
AVOIDING CONFLICTS OF INTEREST
We avoid actions and activities that conflict or appear to conflict with our responsibility to act in the best interest of the Company. Conflicts arise when our personal, social or financial activities interfere, or potentially interfere, with our loyalty to Brink’s.
GIFTS AND ENTERTAINMENT
Giving or receiving a gift, meal, travel expense or business entertainment is acceptable when it is reasonable in value and in connection with a legitimate business purpose. We do not engage in these activities to obtain an improper advantage or to influence the decision-making of a third party, or when doing so violates local law or the recipients’ own rules. We avoid these activities if there is even the appearance of an improper motive. Gifts of cash or cash equivalents are never appropriate. We are especially careful in our interactions with government entities, officials and employees, as special rules often apply.
TAKING CARE IN OUR PUBLIC COMMUNICATIONS We support honest and accurate communication to Brink’s stakeholders. We speak with one voice as a Company. For this reason, only certain Brink’s employees are authorized to speak on behalf of the Company. This includes communications through social media, where the same rules apply – only authorized personnel may use social media to communicate on behalf of the Company.
RESPECT FOR OUR COMMUNITIES
DOING BUSINESS AS A GOOD CORPORATE CITIZEN
We maintain complete, accurate and timely financial and business records. We have a responsibility to be a good citizen in the communities in which we do business. We respect universal human rights and condemn human rights abuses. We comply with local, state, national and international laws regarding the employment of minors.
ENGAGING IN THE POLITICAL PROCESS IN COMPLIANCE WITH THE LAW
We maintain complete, accurate and timely financial and business records. s generally makes political contributions through its Political Action Committee. Company contributions comply with applicable law. When we participate individually in the political process, we express our own opinions and do not express opinions or views on behalf of the Company.
RESPECT FOR EACH OTHER
FAIR AND EQUAL TREATMENT
We promote equal opportunity for all employees and make employment decisions based on qualifications, experience, contributions and performance. We do not discriminate on the basis of any factor not related to a person’s qualification for and ability to perform a job.
EMPLOYEE PRIVACY AND DATA PROTECTION
We respect the privacy of employees’ personal data and information. We collect personal information only when necessary for the Company’s business and only disclose this information to those with a legitimate business need.
We are committed to treating everyone with dignity and respect and to providing a workplace that is free from harassment, intimidation and other inappropriate or unprofessional conduct. This includes verbal or physical behavior that is intimidating, threatening, demeaning or offensive.
SAFE AND SECURE WORKPLACE
We comply with the Company’s safety and security policies and procedures and with applicable health and safety laws. We maintain a workplace free from employee threats, intimidation, aggressive behavior and other forms of violence.
RESPECT FOR OUR CUSTOMERS AND THE MARKETPLACE
COMPLYING WITH THE LAW
We comply with the law wherever we operate. As a U.S. public company, we also must comply with certain U.S. laws that may apply to our non-U.S. subsidiaries. If there is ever a difference between a legal requirement and the Code, we apply the most stringent standard. We report violations or suspected violations of the law to the Legal Department.
DEALING FAIRLY WITH ALL THOSE INVOLVED IN OUR BUSINESS
We deal fairly with our customers and others with whom we do business, and we share only truthful and honest information with them. We do not take unfair advantage of anyone through manipulation, concealment, misuse of confidential information or misrepresentation of facts.
We never give or offer payments or other things of value to obtain or retain business, influence an individual’s actions or decisions, or gain an improper advantage. Giving gifts, providing meals or entertainment or paying for travel are evaluated closely to ensure that there is no improper motive or appearance of an improper motive.
COMPETING ETHICALLY AND LEGALLY
We conduct our business ethically and in compliance with antitrust laws wherever we operate. We do not share our business information or practices with competitors and we do not enter into agreements with competitors regarding sensitive subjects such as prices, bids, markets, territories, or strategy. We limit contacts with competitors as much as possible and ensure that when they do occur it is only in a proper forum and manner.
PROTECTING AGAINST MONEY LAUNDERING
We strive to do business only with reputable companies. We do not support or facilitate money laundering and protect against being inadvertently involved in money laundering schemes or other illegal activity. We do this by complying with applicable anti-money laundering laws, knowing the reputation of our customers and being alert to suspicious activities of customers or potential customers.
COMPLYING WITH INTERNATIONAL TRADE RESTRICTIONS
We comply with applicable laws that restrict trade with specific countries, entities and individuals. These laws may include anti-boycott laws, restrictions that govern exports or imports to or from a prohibited or sanctioned country, entity or individual and restrictions on providing services to a prohibited or sanctioned country, entity or individual.