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CEB Supplier Code of Conduct

Dear Valued Supplier,

CEB dedicates itself to uncovering the drivers of corporate performance. Our research underscores the critical role that a culture of ethics and compliance plays in reducing risk and improving returns. Our corporate values and commitment to high ethical standards are hallmarks of CEB’s performance and relationship with our members.

Our members rely on us to work with suppliers, subcontractors and business partners (“suppliers”) who share these same fundamental values and standards. Therefore, in selecting our suppliers, CEB endeavors to choose reputable companies and individuals who conduct their business in a manner that shows such a commitment.

To ensure consistency and mutual commitment, we require that our suppliers (including their employees, representatives and subcontractors) comply with this Supplier Code of Conduct (“Supplier Code”). This Supplier Code does not replace specific contractual requirements, but rather is intended to supplement our vendor contracts. If a contractual term is stricter than this Supplier Code, the supplier must meet the stricter contractual requirement. Further, supplier actions must be highly ethical regardless of whether the Supplier Code and/or supplier policies specifically address a situation. Thank you for working with us to maintain our high standards of ethics and compliance with laws.

Respectfully,

Pamela J. Auerbach
General Counsel &
Chief Compliance Officer

George Santoro
Head of Procurement

Work Environment

CEB is committed to a work environment that values inclusion, diversity, respect, and integrity.

Respect and Fair Treatment. Suppliers are expected to maintain a workplace where business activities are conducted with respect and where treatment is fair. Suppliers should comply with all applicable laws on non-discrimination and anti-harassment in hiring and employment.

Safety, Security, and Sustainability. Suppliers are expected to promote safe and secure workplaces. Suppliers should have policies and practices in place to ensure the health and safety of their employees and take all necessary steps to provide a safe working environment. Suppliers must also comply with all applicable environmental laws and consider how business decisions affect the environment.

Freedom of Association. Suppliers will respect employees’ lawful right of free association, as well as their lawful right to join, form, or not to join a labor union or otherwise engage in collective bargaining.

Employment Eligibility and Voluntary Labor. Suppliers shall only employ workers with a legal right to work. Illegal child labor, and forced labor (including prison labor, indentured labor, bonded labor, or slave labor) are forbidden in any circumstance.

Appropriate Work Hours and Wages. Suppliers will comply with all applicable laws on work hours and overtime, as well as all applicable laws on wages and benefits.

Business Practices

Protecting CEB confidential information and being a market leader in privacy and data security is integral to our business and reputation.

Communications. Suppliers may not publish any marketing materials, press releases, or media interviews that include a reference to CEB, its members, or the work being completed together without CEB's prior written approval.

Confidential and Proprietary Information. Suppliers will protect CEB confidential and proprietary information and act to prevent its misuse, theft, fraud, or improper disclosure. Suppliers must take all due care in handling, discussing, or transmitting confidential or proprietary information that could affect CEB, its employees, its members, the business community, or the general public.

Intellectual Property. Suppliers must safeguard and take necessary steps to protect CEB's and its members' proprietary intellectual property, even if it is public. This includes trademarks, patents, copyrights, inventions, and other proprietary works. Supplier must only use such intellectual property for the purposes authorized in a contractual agreement. If you are uncertain about a proposed use of CEB's or its members' intellectual property, seek CEB guidance.

Business Records. Supplier shall maintain accurate and complete business records on all matters related to supplier's business with CEB. Supplier shall provide such business records to CEB upon request.

Inside Information and Insider Trading. Suppliers who gain access to any material, non-public information about CEB, or our members, clients or business partners, while working for CEB must not share that information with others or use it for market trading or to tip anyone else in market trading.

Business Relationships and Integrity

CEB expects its Suppliers to conduct their business as CEB strives to conduct its business: in a responsible manner, with integrity and high ethical standards, and in compliance with the law.

Anti-bribery and Anti-Corruption. Supplier must never offer, promise, make, or authorize any payment, bribe, or thing of value in connection with CEB business if the purpose or intent is to gain a business advantage. Supplier must comply with our policy on anti-bribery and all applicable anti-bribery and anti-corruption laws in the countries where we operate, including the US Foreign Corrupt Practices Act and the UK Bribery Act.

Competition. Suppliers will comply with all applicable laws regarding fair competition and antitrust.

Conflicts of Interest. Suppliers are expected to report to CEB any situation that may appear as a conflict of interest, and disclose to CEB if any CEB employee or professional under contract with CEB may have an interest of any kind in supplier’s business or any kind of economic ties with the Supplier.

Gifts or Other Benefits. Suppliers should have in place a thoughtful policy on gifts and entertainment practices. Bribes or inappropriate, luxury gifts to CEB employees are restricted, regardless of local custom. Furthermore, suppliers must not offer entertainment or gifts to government officials—or make direct or indirect political contributions—on CEB’s behalf.

Trade Sanctions and Export Controls. CEB complies with all international trade laws and regulations, including US trade sanctions, and we expect suppliers to comply with all trade and export control laws that apply to their work with CEB.

Supplier Diversity. Encouraging inclusion, Supplier shall endeavor to include small and socioeconomically diverse suppliers in sourcing subcontracting activities where possible.

Compliance and Reporting Misconduct

Accountability and Compliance. Supplier must comply with this Supplier Code and the laws. Suppliers shall be responsible for any monitoring or documenting of their compliance and their efforts to promote compliance within their supply chains. CEB reserves the right to investigate any instances of a supplier’s non-compliance of which it becomes aware. Non-compliance may be grounds for CEB to void or terminate contractual obligations with a supplier.

Reporting. Suppliers who believe that a CEB employee or anyone acting on behalf of CEB has engaged in illegal or otherwise improper conduct with respect to their business with the supplier should report the matter to CEB. Suppliers should also report any potential violation of the Supplier Code. Reports may be made through CEBSupplierReporting@cebglobal.com. A supplier's relationship with CEB will not be affected by an honest report of potential misconduct.