Code of Conduct — The Philippines
TeleTech Holdings, Inc.
From the Chairman and Chief Executive Officer
July 7, 2005
Dear TeleTech Employee:
TeleTech’s Code of Conduct sets forth the ethical and legal standards of business conduct that I expect from
all of our employees, as well as anyone else acting on behalf of the Company. Our Code of Conduct has
been reviewed and approved by the Board of Directors, and has my full support. It emphasizes TeleTech’s
commitment to its employees, clients and their customers, business partners, shareholders, and the global
communities in which we conduct business.
Each of us has an obligation to take ownership in how TeleTech conducts its business. As a member of the
TeleTech team, you must always consider how your actions affect the integrity and credibility of the Company. Every decision and/or action you take in connection with our business should evidence good judgment, and comply with the legal and ethical standards contained in our Code of Conduct.
I expect you to take time to read, become familiar with, and understand how the Code of Conduct applies to
your job.
If you observe or know of conduct that may violate the principles of our Code of Conduct, it is your duty to
report this conduct as described in the Code of Conduct section entitled “Shared Responsibilities.” If you
have any doubt as to the lawfulness or appropriateness of any proposed action, or questions or concerns about
the Code of Conduct, you should seek advice from the appropriate compliance contacts or the Corporate
Compliance Officer.
TeleTech has always taken pride in providing a quality customer care experience for our clients and their
customers. We do so through practicing sound business, ethical, and legal judgments as outlined in this Code
of Conduct. I am confident that with your commitment to these standards we will continue our success into
the future.
Sincerely,
Ken Tuchman
Chairman and Chief Executive Officer
Table of Contents
Our Code of Conduct
What You Need To Do
3
You Are an Owner
13
3
Money
13
Information Security, Classification of
Purpose
Code of Conduct Structure
4
Company Information, and Using
4
TeleTech’s Global Network
13
Core Ethical Values
4
Information Security
13
Policies and Guidelines
5
Classification of Company Information
14
Who Must Follow the TeleTech Code of Conduct
5
Using TeleTech’s Global Network
14
Compliance Plan
6
Business Communications
14
Shared Responsibilities
6
Privacy
14
Compliance Contacts
7
Do-Not-Call Policy
15
Investigations and Discipline
8
Intellectual Property
15
Confidentiality, Retaliation, and False Reports
8
Copyrights, Trademarks, Service Marks
15
External Communications
16
TeleTech Code of Conduct
9
Media Requests
16
Investor Relations
16
9
Procurement
16
Discrimination & Harassment
9
Insider Information & Securities Trading
16
Health and Safety
9
Company Records and Records Retention
16
Violence in the Workplace
9
Whistle Blower Hotline
17
Drugs and Alcohol
10
Off-Duty Misconduct
10
How We Treat Each Other
Inspection of Personal Belongings
10
Community Activities
10
Political Activities
10
Conflicts of Interest
11
Hiring Legal Counsel and Protecting the
Attorney-Client Privilege
17
How U.S. and International Law Affect
Affect Our Business
17
Related Party Transactions
11
Antitrust and Unfair Competition Laws
17
Board Memberships
11
Transacting International Business
18
Employment Outside of TeleTech
11
Foreign Corrupt Practices Act
18
Family Members and Close Personal Relationships
11
Anti-Boycott Laws
18
Consensual Relationships
12
Trade Restrictions/U.S. Embargos
18
Business Gifts and Courtesies
12
Export Regulations
19
Investments and Other Financial Opportunities
12
How We Treat Others
19
12
Protecting the Intellectual Property of Others
Confidential Information of Clients
13
Confidential Information—Former Employers
Fraud
13
And Other Third Parties
19
13
Acknowledgement Form
20
How We Treat Clients and Their Customers
How We Treat Company Assets
TeleTech Holdings, Inc.
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2
Our Code of Conduct
The Code of Conduct establishes the standards that apply to the manner in which you are to conduct business as a
TeleTech employee, and reinforces TeleTech’s long-standing commitment to integrity and ethics in providing services
and products to its customers.
WHAT YOU NEED TO DO
1.
Read the letter from Ken Tuchman, our CEO and Chairman;
2.
Read, become familiar with, and understand how the Code of Conduct applies to your job;
3.
Keep as a reference the contact information for the legal/risk management experts who can help you with any
questions you may have about the Code of Conduct; and
4.
Review and become familiar with the details of the policies, procedures, practices, and guidelines dealing with
your work. To do this, you need to go to the Company’s intranet “OneSite” under the “Code of Conduct” tab.
If you need a printed version of any of our policies and guidelines, simply print one from “OneSite,” or con
tact the appropriate compliance contact.
New employees will review the Code of Conduct within five (5) business days of their employment. Employees are
required to review the Code of Conduct bi-annually.
Important
You will be bound by the most current version of the Code of Conduct, which you may review at
“OneSite” under the “Code of Conduct” tab. The Company may revise this Code of Conduct at
any time without prior notice.
TeleTech Holdings, Inc.
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3
TeleTech Code of Conduct
Responsibility – Opportunity – Integrity
Purpose
The TeleTech Code of Conduct sets forth the ethical and legal principles of business conduct that you are to use as a
guide in your decision-making. Each of us has a personal responsibility to uphold the standards of ethics, integrity, and
conduct established by the Code of Conduct. Ethical behavior and compliance with the Code of Conduct are conditions
of employment.
Code of Conduct Structure
This Code of Conduct is divided into 6 major sections:
1.
2.
3.
4.
5.
6.
Core Ethical Values
How We Treat Each Other
How We Treat Clients and Their Customers
How We Treat Company Assets
How U.S. and International Law Affect Our Business
How We Treat Others
The Code of Conduct drives TeleTech’s business and the policies, guidelines, and other standards that support our core
ethical values.
Code of
Conduct
Core Ethical Values
Corporate Policies
Departmental/Business Unit Policies
Employee Handbook – Policies and Guidelines
Methods, Procedures, Daily Administrative Instructions
Core Ethical Values
Our Company’s reputation as a good corporate citizen is driven primarily by our commitment to legal and ethical standards and how well we support our core ethical values. TeleTech’s core ethical values are that each of our employees
will:
•
•
•
Conduct business as if you are the owner.
Respect all individuals.
Create a safe and secure workplace.
TeleTech Holdings, Inc.
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•
•
•
•
•
•
Act with honesty, integrity, and fairness.
Abide by all applicable and enforceable laws and regulations.
Maintain a steadfast commitment to equal opportunity.
Be receptive to open, honest communication, and feedback.
Promote effective teamwork and quality of operations.
Promote and keep a work environment that fosters each of our core ethical values.
Living by these values is critical to our success. Although we are in business to make a profit, we will not do so at
the sacrifice of our core ethical values.
Policies and Guidelines
In addition to the Code of Conduct, the Company and, when necessary, individual departments/business units, have
developed specific policies and guidelines for particular areas of legal and ethical compliance, and for operational
and management practices. Please refer to these policies and guidelines for more detail. The Code of Conduct and
the policies and guidelines may be found on the Company Intranet “OneSite” “Code of Conduct” tab or may be obtained from any of the compliance contacts. You have the responsibility to become familiar with all policies and
guidelines dealing with your work. The policies described below are general descriptions of certain policies concerning key risk areas; they are not exhaustive and not inclusive. The Company does not expect every employee to
memorize all of the Code of Conduct’s policies word for word, but we do expect that each employee will become
familiar with the core ethical values and policies and guidelines applicable to his or her job.
If you have any questions about whether a policy or guideline is applicable to your job, consult the appropriate compliance contacts (see page 7).
Who Must Follow the TeleTech Code of Conduct
All employees must read, follow, and support TeleTech’s Code of Conduct. The Code of Conduct applies to all officers and members of the Board of Directors of TeleTech, as well as TeleTech’s subsidiaries, partnerships, and joint
ventures where TeleTech exercises management control or has a majority ownership position of more than 50%
(collectively referred to as the “Company” or “TeleTech”). The Code of Conduct also applies to others representing
the Company such as temporary service workers, agents, consultants, vendors and independent contractors.
TeleTech conducts business in more than seventeen countries around the world. Our employees are citizens of many
different countries. As a result, our operations are subject to the laws of many countries, provinces, states, municipalities, and organizations such as the European Union.
An important challenge for all of us is to understand how these laws may apply to our operations. TeleTech Holdings, Inc., the parent company, is a corporation organized in the United States. The laws of the United States frequently extend to the operations of TeleTech and its affiliates throughout the world as well as to the business activities of TeleTech employees wherever they live and work. Other countries may also apply their own laws outside of
their borders to their own citizens and to corporations that are organized under their laws, such as TeleTech subsidiaries or other affiliates.
In the policies that follow, the references to the laws of the United States and the other countries where we do business reflect that our global Company is regulated by many different laws at the same time. In some instances, there
may be a conflict between the applicable laws of two or more countries. When you encounter such a conflict, you
should contact the law department to understand how to resolve that conflict properly.
TeleTech Holdings, Inc.
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Compliance Plan
TeleTech’s Compliance Plan supports the implementation and ongoing administration of the Code of Conduct. Our
Compliance Plan also discusses employee education, policy development, issue resolution, and compliance assessment. The Risk Management Executive Council (RMEC) administers the Compliance Plan. The RMEC is comprised of our general counsel, chief financial officer, chief information officer, head of human resources, head of
operations, head of TeleTech OnDemand, and the corporate compliance officer. The corporate compliance officer
provides day-to-day oversight of the Compliance Plan, with assistance from the law department, site compliance contacts, regional risk management directors, and human resources. Details of the Compliance Plan can be found under
the “Code of Conduct” tab on “OneSite.”
Shared Responsibilities
One of the most important responsibilities each of us has as a TeleTech employee is the obligation to raise a concern
about a possible violation of TeleTech policy or the law. Sometimes it may seem difficult to raise such a concern.
Some of us may even feel it is a breach of personal ethical standards to do so. If you experience that sense of conflict, it’s important to remember the tremendous harm that not raising a concern can cause, including.
•
•
•
Serious damage to the health, safety, and well-being of yourself, your fellow employees, the Company as a
whole, our customers, and the communities in which we operate
The loss of confidence in TeleTech – by customers, share owners, governments, and neighbors
Huge fines, damage awards, and other financial penalties against the Company; fines and/or prison sentences for individual employees
Those are the reasons the Company requires that employees not be silent when they have a policy concern. The point
of raising a concern is not to get a friend in trouble, but to protect a colleague or neighbor from potential harm.
TeleTech Holdings, Inc.
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Compliance Contacts
The Company offers you many ways to get answers to your questions about ethical issues and to raise any concern about
what might be a violation of the Code of Conduct to:
•
•
•
Your supervisor or manager,
Your local compliance contact, or
Corporate compliance officer
Generally, your supervisor or manager or local compliance contact will be in the best position to resolve the issue quickly.
If after raising an ethics concern the issue is not resolved, or you would like to raise a concern anonymously, raise it with
one of the other contacts listed below:
We Hear You
• Employee Hotline
Philippines
Website
Dial 105-11. Wait for the prompts , then dial 1-888788-0032
http://www.teletechwehearyou.com
Corporate compliance officer
303-397-8100
Incident Reporting Hotline numbers:
• Safety, Incident Security, Bomb Threat, Disaster,
Work Place Violence Threat:
Dial 105-11. Wait for the prompts , then dial 1-888788-0032
•
Claims Reporting:
teletech@geyoung.com
Media Relations
303-397-8100 or
media@teletech.com
Investor Relations
303-397-8100 or
investor.relations@teletech.com
You can raise your concern orally or in writing, and if you prefer, you can do it anonymously. The whole idea is to speak
up. Ask questions. Get answers. Bring the concern into the open so that any problems can be resolved quickly and more
serious harm prevented
Early identification and resolution are critical!
TeleTech Holdings, Inc.
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Investigations and Discipline
The Company seriously views alleged violations of the Code of Conduct and will take action to investigate such allegations to determine if a violation has occurred. Based upon its findings, the Company will take immediate and corrective action if appropriate. Any employee found to have engaged in a violation of TeleTech’s Code of Conduct
will be subject to discipline, up to and including termination. Immediate and appropriate steps will also be taken if
any non-employee (such as an agent, vendor, supplier, or consultant) is found to have engaged in an activity that violates the Code of Conduct. The Company expects every employee to fully cooperate with any investigation into an
alleged violation of the Code of Conduct. Failure to cooperate, failure to be truthful, or attempting to impede an internal investigation may lead to disciplinary action, up to and including termination. Disciplinary action may also be
taken against supervisors or other management who condone, permit, or fail to report any violation of the Code of
Conduct.
Confidentiality, Retaliation, and False Reports
To the fullest extent possible and consistent with the need for a thorough investigation, the Company will strive to
keep confidential reports of violations or suspected violations of the Code of Conduct. Retaliation against an employee who, in good faith, reports a suspected violation is strictly prohibited. Purposely making false reports is a
violation of the Code of Conduct and, accordingly, any employee found to have engaged in this type of activity may
be subject to disciplinary action, up to and including termination.
TeleTech Holdings, Inc.
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TeleTech Code of Conduct
How We Treat Each Other
People are our most important asset. The way employees treat one another, as well as others outside the Company, in
large part defines our culture and enables our success. We will treat each other with dignity, respect, and fairness, and
recognize the value of different cultures, backgrounds, and viewpoints. This will make us a stronger, better Company.
Discrimination and Harassment
We are committed to maintaining a work environment based on mutual respect. One that is free from discrimination or
harassment, including intimidating, hostile, or offensive conduct. Discrimination and harassment based on ethnicity or
national origin, race, color, gender, religion, sexual orientation, disability, age, veteran status, or other category protected
by law is strictly prohibited.
Inappropriate or unwelcome sexual behavior is strictly prohibited. The Company does not permit advances, requests for
sexual favors, or other verbal, written, visual, or physical conduct of a sexual nature.
Harassing or discriminating conduct may occur on or off TeleTech premises and during work or non-working hours.
Harassment or discrimination is prohibited whether committed by or against subordinates, managers, supervisors, coworkers, or non-employees, including vendors, clients, or their customers.
A violation can occur even when the conduct does not rise to the level of unlawful discrimination or harassment. Nothing in the Code of Conduct is designed or intended to limit TeleTech’s authority to discipline or take remedial action for
conduct that is, in TeleTech’s sole discretion, determined to be unacceptable.
If you believe that you are being or have been subjected to discrimination or harassment, or you become aware that
someone else has, you must immediately contact one of the compliance contacts on page 7.
Health and Safety
The Company is committed to promoting the health and safety of its employees, contractors, visitors, and clients, and to
providing a safe and secure workplace. Employees are expected to:
•
•
•
Comply with all applicable and enforceable environmental, health, and safety laws and regulations;
Implement all work practices taught in training classes to protect the environment and prevent personal
injury or property loss; and
Immediately report any environmental, health, or safety problems.
Reports of any actual or potential environmental, health, or safety problems, or any questions about employees’ responsibilities should be immediately directed to the appropriate compliance contact.
Violence in the Workplace
The Company prohibits violence, threats of violence, and intimidation, and will take all appropriate actions in response
to employees who violate this policy, including appropriate disciplinary measures. This prohibition includes threatening
language, both verbal and written, threatening gestures, actual physical fighting, pushing, shoving, or brandishing weapons. Firearms and/or weapons of any kind are prohibited in the workplace, in TeleTech vehicles or in any vehicle while
on Company business, in an employee’s possession while on company property (this includes the parking lots), or in an
employee’s possession while performing work duties off the Company’s premises. All employees must adhere to this
policy and report any infraction to the appropriate compliance contact.
TeleTech Holdings, Inc.
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Drugs and Alcohol
The Company is committed to providing and maintaining a safe and productive work environment. Therefore, it maintains a substance-free workplace policy. You may not manufacture, distribute, purchase, sell, process, or use illegal
drugs (including drug paraphernalia) or alcohol while on company premises, prior to or while driving on company business, or during meal and break periods or on-call time. In addition, you may not report for work or drive on Company
business after using any illegal drugs, alcohol, or over-the-counter or prescription medication that impairs your ability to
safely perform your duties. Notify your supervisor immediately if you are using medication that might affect your work.
The use of alcohol at business dinners or events attended by employees as part of the normal course and scope of their
employment is acceptable as long as it is consumed responsibly. Employees should always exercise good judgment
when consuming alcohol at such events and it is in TeleTech’s sole discretion to determine whether an employee has
consumed more than a reasonable amount. You are responsible for ensuring you have safe transportation from an event
at which alcohol is served.
Off-Duty Misconduct
If you engage in off-duty misconduct, you may pose a risk of harm to other employees or the Company’s reputation.
Since employees handle confidential client and customer information, any employee convicted of theft related offences
could present a risk to the business.
Pursuant to local laws, you must report to your supervisor within 24 hours of, or by the following business day after, (1)
your conviction of any criminal offense such as theft, shop lifting, fraud, forgery, assault or child abuse; or (2) any offduty misconduct involving harm or the risk of harm to others. Your supervisor, together with the security department,
human resources, the corporate compliance officer, and the law department will determine if the nature and severity of
any off-duty misconduct requires employment action.
Inspection of Personal Belongings
In order to promote a safe and secure workplace, the Company reserves the right to inspect an employee’s personal belongings, as well as any property in their possession. If you bring personal property into the workplace, you should have
no expectation of privacy concerning your personal property or its contents. We also reserve the right to inspect lockers,
desks, personal vehicles on company property, packages, lunch boxes, containers, articles of clothing, and other items
brought onto company property.
Community Activities, Solicitation, and Distribution
The Company and its employees frequently contribute to the economic and social well being of local communities. You
are encouraged to become involved and participate in activities that support your local community. If you wish to use
Company resources to support nonprofit, nonpolitical, or charitable organizations, you must first contact the appropriate
compliance contact.
Political Activities
Because U.S. law and the laws of many state and local governments forbid companies from contributing to political candidates or parties, contributing money or time on behalf of TeleTech and any use of TeleTech’s name or resources to
support political parties or candidates must be approved in advance by the law department. Further, employees are prohibited from seeking reimbursement from the Company for any political contributions.
TeleTech Holdings, Inc.
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Conflicts of Interest
Every employee has a legal and ethical responsibility to make decisions and act in the best interests of the Company.
The decisions you make and the actions you take are a reflection on the Company as a whole. Your personal interests
or relationships with vendors, clients, competitors, or other outside parties should never affect your judgment when
acting on behalf of TeleTech. Our continued success depends upon the loyalty of each employee throughout his/her
employment.
In order to avoid a situation that could cause, or appear to cause, a conflict of interest, you must disclose to the appropriate compliance contact listed in the “Compliance Contacts” section of the “Code of Conduct,” any family, business,
or close personal relationship you have that has a connection with current or potential clients, vendors, competitors,
employers, or business associations. If you have any questions on whether a conflict of interest might exist, ask the
question and disclose information to the appropriate compliance contact. You will find instructions and approval forms
in “Law/Risk Management” tab on “OneSite.”
Related Party Transactions
All employees must disclose to the corporate compliance officer any potential or actual related party transactions. A
related party transaction is when an employee or a member of the employee’s immediate family has entered, or is about
to enter, into any transaction with a company that has made or received payments to/from TeleTech for any property or
services. “Immediate family” includes your spouse, parents, children, siblings, fathers- and mothers-in-law, sons- and
daughters-in-law, brothers- and sisters-in-law, and close personal relationships.
Board Memberships
As long as your ability to perform your job with TeleTech is not compromised, the Company supports your membership on the board of directors or advisory board of community or nonprofit organizations. You must disclose your role
on any community or nonprofit board of directors to the compliance officer.
Prior to assuming a position as a member of any board of directors or advisory board of a for-profit organization, you
must receive approval from TeleTech’s law department. The law department will determine whether such board representation presents a conflict of interest with TeleTech. You may not serve on the board of directors and/or an advisory
board of any TeleTech competitor. You will be responsible for determining your financial liability, as well as ensuring
you are properly protected, when serving on any board of directors or advisory board.
Employment Outside of TeleTech
If you are employed or considering employment, or becoming an officer, outside of TeleTech, it is important that you:
(1) always devote your best efforts to TeleTech and not allow outside employment to interfere with your ability to do
so, (2) are not employed by a company that competes with TeleTech or a TeleTech client, (3) are not employed by a
company that is a customer or a vendor for TeleTech, and (4) do not use TeleTech’s resources for any outside employment activity.
You must receive written approval from the corporate compliance officer prior to accepting any outside employment
arrangement. If you have any questions on whether a conflict of interest might exist, contact the appropriate compliance contact.
Family Members and Close Personal Relationships
The Company supports the employment of family members, as long as their employment does not interfere with the
Company’s best interests. In order to avoid a conflict of interest, you must remove yourself from being in a position
where you could influence the hire, termination, discipline, evaluation, promotion, or compensation of a relative or
someone with whom you have a close personal relationship. You must also disclose to the appropriate compliance
contact any conflicts of interest that arise when the Company is considering doing business or competing with companies for which a family member works, or has an ownership interest in.
TeleTech Holdings, Inc.
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Consensual Relationships
Consensual relationships between Company employees or between a Company employee and an employee of a vendor or client are discouraged. Such relationships may at some point lead to complications and significant difficulties
for all concerned – the involved employees, the supervisors/managers, co-workers, vendors/clients and the Company.
To avoid issues of favoritism, discrimination, poor morale, confidentiality, and conflicts of interest, it is not appropriate for you to have a consensual relationship with anyone you supervise, anyone with whom you have a reporting relationship, or if you are in a role that affects the terms and conditions of that individual’s employment. Upon being informed or learning of the existence of this type of relationship, the Company may take all steps that it deems appropriate, including but not limited to, moving either party to a different department or job, or, if necessary, terminating either party’s employment.
Business Gifts and Courtesies
At times, business courtesies such as gifts, meals, travel, or entertainment may be extended to build relationships,
celebrate successes, and foster goodwill in the business environment. The giving and receiving of business courtesies
can easily create conflicts of interest or the appearance of a conflict of interest with business relationships.
Business courtesies extended to or offered by TeleTech employees must never affect the business decisions of the gift
giver or recipient. The exchange of gifts, favors, and social amenities is acceptable if they can clearly be related to a
business purpose and are considered as customary in a normal business relationship. Entertainment of guests, employees, or customers involving “adult entertainment” is not suitable for business purposes.
Cultural practices should be considered when determining what is appropriate in extending business courtesies in international settings. When giving business courtesies outside of the United States, employees are required to fully
comply with the Foreign Corrupt Practices Act (see page 18).
It is never appropriate to offer or receive a business courtesy that may be considered extravagant or that may create the
perception of influencing business decisions. If you work with governmental entities, you are prohibited from giving
or receiving business gifts or courtesies of any kind.
As a guideline, employees should only give or accept gifts of nominal value, not exceeding the U.S. equivalent of
$100 per recipient, unless you receive prior approval from the appropriate compliance contact. Wherever possible,
gifts given should include the TeleTech logo. The most current IRS guidelines must be followed with respect to reporting of these items.
Investments and Other Financial Opportunities
Any financial investment that places you in a position that influences your independent judgment while working at
TeleTech is a conflict of interest. "Financial investment” includes owning stock, accepting options to purchase stock,
or pursuing other ownership interests in a company. If you have any questions about whether a financial investment
could be considered a conflict of interest, consult with the appropriate compliance contact.
How We Treat Clients and Their Customers
The success of our Company is dependent on our ability to satisfy clients and their customers by providing them with
quality services and competitive rates. It is equally important for each of us to treat our clients and their customers
with honesty and integrity and only make promises that we are confident we can meet. Our business is highly competitive and, consequently, TeleTech is sometimes required to aggressively market our services. However, we must
never use illegal methods to acquire or solicit business.
TeleTech Holdings, Inc.
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Confidential Information of Clients
TeleTech routinely receives confidential and/or proprietary information from third parties, such as clients and their
customers, as well as our business partners and others with whom we do business. You must handle such confidential and/or proprietary information appropriately and in accordance with our obligations under applicable and enforceable law and client contracts.
Fraud
TeleTech does not tolerate fraudulent behavior from its employees or other users (e.g. independent contractors, alliance partners), together “users”. Any user found to be engaged in fraudulent activity will be subject to disciplinary
action, up to and including, in the case of employees, termination and referral of the fraudulent activity to appropriate
law enforcement officials. Similar disciplinary action will apply to management if it is determined that a supervisor
or manager knew about or perpetuated the fraud by a user. If you disclose your personal password to another employee and fraud is committed, you will be held responsible and will be subject to disciplinary action, up to and including termination.
TeleTech expects all users to be aware of and report suspected fraudulent activity. Failure to cooperate, giving false
information, or failure to provide the Company with information you have about an investigation involving fraud will
subject you to discipline, up to and including termination. Fraud should be reported through the Fraud Hotline,
fraudline@teletech.com, teletechwehearyou.com or to your compliance contact.
How We Treat Company Assets
You are an Owner
To enable you to carry out your job duties, the Company entrusts you with Company assets, like technology, finances, equipment, and information. An overriding principle is that you use the Company’s assets only for legitimate business purposes and that you treat Company assets with the same care as if they are your own. You are expected to safeguard and protect Company assets from misuse, damage, theft, contamination, and use by unauthorized
users.
You must gain approval from the appropriate management to spend money or commit the Company to business dealings by following the appropriate procurement policies and processes described in the “Global Signature Authority
Policy” within the law and risk management tab on “OneSite.”
Money
The Company provides funds to employees authorized to expend money for such things as travel, expenses, purchases, services, equipment, leases, and rentals. The Company also provides funds for investments and operations
through a formal budget process. Typically, employees are reimbursed for authorized expenditures through an Expense Voucher, found on “OneSite.” Employees may receive advance cash payments to cover authorized expenses.
The Company does not provide loans to employees. Employees are prohibited from making or accepting personal
loans from employees or others (such as clients, vendors, consultants, and independent contractors) under their control or supervision.
Information Security, Classification of Company Information, and Using TeleTech’s Global Network
Information Security
It is important that Company information, in any form, including paper, digital media, and electronic communica-
TeleTech Holdings, Inc.
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tions, be protected to assure: (1) that it is available when it is needed, (2) that it has not been altered, and (3) that certain
information be kept confidential. Also, since TeleTech routinely receives confidential and/or proprietary information
from third parties, such as clients and their customers, as well as our business partners and others with whom we do
business, you must make sure that you handle such information to keep it confidential. To ensure that you are properly
handling, creating, classifying, distributing, and disposing of the information, please refer to the details set forth in the
Privacy Policy and the Information Security Policy.
Classification of Company Information
Company information is classified into three categories: (1) public non-confidential, (2) proprietary and confidential,
and (3) privileged and confidential information. As a general matter, proprietary and confidential information should
not be disclosed to any third parties without an applicable, and law department approved, non-disclosure/confidentiality
agreement (“NDA”) or other contract that protects the confidentiality. Even if an NDA is in place, proprietary and confidential information should only be disclosed as absolutely necessary to accomplish the purpose of the disclosure.
You should err on the side of non-disclosure if you have any doubt. Attorney-client privileged information may only
be disclosed when approved by the law department. Further, make sure that you properly mark any Company information that is confidential. If you have any questions about the appropriate handling and disclosure of information, contact the law department.
Using TeleTech’s Global Network
While in the course and scope of doing your job, you use the TeleTech Global Network (“Global Network”). Use of
the Global Network is for legitimate, business purposes only and you must comply with all policies and guidelines outlined in the Information Security Policy. Although the Global Network is intended for business use, TeleTech permits
incidental and limited personal use provided that such use is reasonable and does not interfere with your work.
TeleTech may monitor your activity on the Global Network and access data on Company provided equipment without
prior notification, in accordance with applicable and enforceable domestic and international privacy regulations. Since
that is the case, you should not have any expectation of privacy for any data maintained or utilized on the Global Network.
In general, you may not use the Global Network for:
•
•
•
Accessing, transmitting, or storing prohibited material (such as pornography, online gaming, or gambling)
Posting messages that relate to confidential and proprietary Company business information, personal
information about yourself or others on the Internet, for example, blogging
Writing or displaying defamatory language or images about clients, customers, vendors, or employees
Business Communications
Further, when communicating with employees or third-parties by any means (such as letters, telephone, voicemail,
email, or Instant Messaging) the Company expects that you should be guided by the overriding principles of professionalism and courtesy. Every effort should be made to ensure your communications are not offensive to others, including employees, clients, customers, and members of the community. As you write a document always consider tone
and language – ask yourself – if this message were published in the newspaper, would you be embarrassed?
Privacy
TeleTech expects employees and others (such as independent contractors and alliance partners) to protect the confidentiality of information about employees and our clients. This information may include, among other information, personnel files, contract records, and operations information. As a result, employees and others must: (1) prevent disclosure of private or proprietary information about employees or clients; (2) apply, where necessary, the appropriate protective measures required by the laws or regulations of those countries in which TeleTech operates; and (3) support
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privacy requirements placed on TeleTech in client contracts.
If you have any questions about the applicability of any privacy law or requirement to information that you have, please
contact the appropriate compliance contact.
Do-Not-Call Policy
The Company strives to adhere to all applicable and enforceable federal and state laws and regulations governing telephone solicitation and the protection of telephone consumers. Toward this end, TeleTech has implemented a Do-NotCall Policy and associated training programs to provide the guidelines necessary to follow all applicable and enforceable federal and state Do-Not-Call laws. If you have any questions about the applicability of the Do-Not-Call Policy to
any campaigns, business opportunities, operations, or methods of work, please contact the law department.
Intellectual Property
Intellectual property is considered one of the Company’s most valuable assets. Intellectual property includes materials,
inventions, or ideas that are copyrighted, trademarked, or patented. Trade secrets are also considered intellectual property and include information that provides the Company with a competitive advantage. Examples of trade secrets include:
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Ideas and inventions
Technology designs, research, or code
Marketing plans
Business strategies and plans
Customer lists
Databases
Organizational charts
Processes
Areas of specialized knowledge, training, or experience
Specially developed customer information and sales practices
Financial and pricing information
Intellectual property is considered TeleTech confidential and proprietary information and should be identified and handled in accordance with the Classifications and Use Guidelines of the Information Security Policy. Contact the law
department if you have any questions regarding TeleTech intellectual property. The Company owns all intellectual
property that you create, develop, write, or conceive in the course of your employment.
Copyrights, Trademarks, Service Marks
All written works created by the Company, such as manuals, training materials, marketing materials, templates, and
client presentations, are TeleTech intellectual property and should be imprinted with the copyright (©) designation in
accordance with the Company Style Guide found on the OneSite. Individuals needing information about copyrights
should contact the law department.
All Company trademarks and service marks are also TeleTech intellectual property and should be referenced and used
correctly. The marks should contain the appropriate designation ®, TM, or SM in accordance with the “Style Guide”
located on “OneSite”. Contact the law department if you have any questions on the proper use of trademarks and service marks.
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External Communications
TeleTech will disseminate information to the media and the public in a professional, accurate, and coordinated manner. For this reason, communications with individuals outside of the Company are to be handled in the following
manner:
Media Requests:
All media inquiries should be directed to the media relations department. You should not comment to any media
about TeleTech operations or clients. Immediately contact the Media Relations department at media@teletech.com
with any media inquiries, communications, or articles about TeleTech.
Investor Relations:
All information requests from current or potential investors or requests for financial information should be directed to
the investor relations department. You should not attempt to answer these information requests. Instead, contact the
investor relations department at investor.relations@teletech.com about any financial or investor requests.
Procurement
Only certain individuals are authorized to sign contracts or to make purchasing decisions on behalf of the Company as
described in the Global Procurement Policy found on “OneSite.” Additionally, the Company is committed to participation in the success of minority and women-owned businesses in our communities and will provide opportunities for
these enterprises to earn our business. This philosophy supports our strategy to ensure that our suppliers reflect our
diverse customer base and is consistent with our commitment to be a good corporate citizen. Because the Company
has negotiated certain contracts with vendors for discounts on high-volume purchases – such as travel, office supplies,
cell-phone service, and local and long-distance telephone services – you must justify to your supervisor the selection
of alternative vendors before purchasing products and services from them. No employee or vendor may sign contracts
or conduct business with vendors or suppliers who violate applicable and enforceable laws.
Insider Information and Securities Trading
Insider trading is against the law and a conviction can result in significant fines and prison time. If you have access to
insider proprietary information about Company operations or the operations of one of TeleTech’s clients, and use that
information to engage in a securities transaction or give that information to an individual who reacts to it by engaging
in a securities transaction, you can be held liable under insider trading laws. You also are in violation of this policy if
you or a member of your immediate family engages in a securities transaction while possessing proprietary information about the Company or one of TeleTech’s clients. If you have questions contact the law department.
Company Records and Records Retention
Employees, stockholders, creditors, customers, clients, and government entities all rely upon the accuracy of the Company’s records. The success of TeleTech is also dependent on the reliability and accuracy of its business records.
Each employee must ensure that company records and reports are complete and accurate. These responsibilities include not only efforts to prevent or deter fraud, but also the detection of fraudulent reporting, misappropriation of assets, and/or other unethical business practices.
All financial records and reports must correctly reflect transactions and events and must be presented in conformity
with the Company’s accounting principles and system of internal controls. All entries, regardless of transaction size, in
Company books, records, invoices, reports, or accounts must not contain misleading or false information.
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The Records Retention Policy provides guidelines as to how to store and when it is appropriate to destroy Company
recorded information. The Company produces vast amounts of recorded information and, for the most part, this information is recorded on paper or electronically. Every employee and other custodian of the Company’s records must follow the requirements and guidelines of the Records Retention Policy, which can be found under the “Code of Conduct”
tab on “OneSite.” The Records Retention Policy provides guidelines as to how to store and when it is appropriate to
destroy Company recorded information.
Whistle–Blower Hotline
In compliance with the Sarbanes-Oxley Act of 2002, the Company’s Audit Committee has established a “Hotline” to
receive complaints or concerns from employees and third parties about Company financial or audit practices (Dial 10511. Wait for the prompts then dial 1-888-788-0032), or our Website teletechwehearyou.com. The Hotline permits employees and third parties to remain anonymous if they choose when reporting complaints or concerns to the Company.
Hiring Legal Counsel and Protecting the Attorney-Client Privilege
Only the law department can select, hire, and consult outside legal counsel. Contact the law department if you have any
questions or concerns about a legal matter involving the Company. The Attorney-Client Privilege or Work Product
Doctrine protects certain legal communications involving the Company. All employees must keep all written and verbal
communications with Company attorneys (both in-house and outside counsel) confidential and must not share such communications with another employee or third party or opposing party in a litigation matter without the written consent of
an attorney in the law department.
How U. S. and International Law Affect Our Business
Antitrust and Unfair Competition Laws
Antitrust and unfair competition laws preserve and foster fair and honest competition within the free enterprise system.
Antitrust and unfair competition laws make illegal any agreement or understanding, express or implied, written or oral,
that unreasonably restricts competition or interferes with the ability of the free market system to function properly. Under these laws, neither good intentions nor customer or consumer benefits justify or excuse violations. Communications
with competitors should be avoided unless they concern a true customer-supplier relationship, other legitimate business
venture, or permitted trade association activities. Employees must not engage in any communications with competitors
that could result in price-fixing, bid-rigging (including complimentary bidding), allocation of customers or markets, boycotts of certain customers or suppliers, or production limits to restrain trade.
TeleTech’s policy is to fully comply with both the letter and spirit of the antitrust and competition laws of the countries
where it operates. Any employee who has a question about the potential antitrust implications of a discussion or action
must consult with the law department before any such discussion or action takes place.
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Transacting International Business
All TeleTech officers, employees, agents, and affiliates must comply with (1) all laws of the international jurisdictions
in which the Company operates (except where prohibited by United States law), and (2) all applicable and enforceable
laws of the United States that have application outside the United States territory, including U.S. export control laws,
anti-boycott laws, trade embargo laws, and the Foreign Corrupt Practices Act (“FCPA”). Violations of the FCPA and
the other U.S. laws applicable to international transactions may result in criminal, civil, and/or administrative sanctions.
Foreign Corrupt Practices Act
All employees are required to comply fully with the FCPA, which prohibits the bribery of foreign government officials, political party officials or candidates, or political parties. The FCPA defines a bribe as anything of value (i.e.,
cash or non-cash items) given or offered for the purpose of influencing an act or decision to obtain, retain, or direct
business.
Bribes, kickbacks, or giving anything of value in an attempt to influence the action or inaction of a public official is
strictly prohibited. This prohibition extends to payments to consultants, agents, or other intermediaries when the
payor knows or has reason to believe that some part of the payment or “fee” will be used to bribe or otherwise influence a public official.
If an employee involved in international operations is confronted with a demand for a bribe from anyone, the employee must report the demand immediately to his or her supervisor and to the law department.
The FCPA also requires TeleTech to maintain (1) accurate books and records and (2) a system of internal accounting
controls with respect to both domestic and international transactions and asset transfers.
Anti-boycott Laws
The U.S. anti-boycott laws prohibit the Company from supporting boycotts imposed against countries friendly to the
United States.
The anti-boycott laws prohibit the Company or any of its employees from refusing to do business with anyone based
upon race, national origin, religion, or gender, and from providing information about such matters to customers and
potential customers.
United States law requires that requests to participate in a boycott be reported promptly to the U.S. government. Employees who have questions related to a proposed transaction that may be affected by the U.S. anti-boycott laws must
consult with the law department before proceeding with the transaction.
Trade Restrictions/U.S. Embargoes
The United States from time to time restricts or prohibits trade and other commercial dealings between U.S.
citizens (including U.S. persons, U.S. incorporated companies, alien residents in the U.S., and in some instances foreign-based affiliates of U.S. companies) and certain countries, including residents and citizens of
those countries. The Company requires that all employees adhere to the letter and spirit of U.S. restrictions
and prohibitions on trade with other countries.
The countries that are the target of U.S. restrictions or prohibitions can change frequently, as can the restrictions and
prohibitions themselves. Therefore, it is imperative that employees seek advice from the law department on transactions that may involve any country subject to U.S. restrictions or prohibitions on trade.
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Export Regulations
The United States regulates the export of goods, services, and technology to foreign countries. The definition of
“export” is very broad, and can include, for example, a conversation with a citizen of another country even where the
conversation takes place entirely within the United States.
Employees involved in export transactions must ensure that all information provided in connection with the export is
accurate and truthful. Employees also must ensure that a regulation or specific export license covers the export in question. This requirement applies to exports of goods and services as well as technology. You must be alert to situations in
which inaccurate or fraudulent information may have been furnished to the Company regarding the ultimate destination
or use of the goods, services, or technology to be exported.
Questions about whether a situation involves an “export” or the accuracy of information being provided to the Company
regarding the ultimate destination or use of goods, services, or technology that TeleTech exports should be directed to
the law department.
How We Treat Others
We will only conduct business where the business environment is such that operating in an ethical, legal manner is possible. This applies to relationships with clients, customers, contractors, government representatives, partners, and vendors. This Code of Conduct applies to those acting on behalf of the Company, whether external advisors, contractors,
sub-contractors, consultants, sales consultants, temporary service workers, joint ventures, and alliances or others. We
expect all third parties employed by the Company to abide by this Code o f Conduct.
The Company buys the services of temporary service workers and independent contractors. These individuals are not
Company employees and do not receive bonuses, performance appraisals, company credit cards, business cards, stationery, name plates or picture ID cards, nor are they placed on performance plans or in supervisory positions. In addition,
temporary service workers should not be included in Company events, reward and recognition programs, etc., as this
may create the appearance that they are regular employees. On occasion, temporary service workers or independent
contractors may receive a picture ID card or company credit card when these items are required for them to do their jobs.
Protecting the Intellectual Property of Others
Our policy respects the intellectual property of others. That means that in your work you must not engage in unauthorized use of or copy the intellectual property of another company or person.
Confidential Information – Former Employers and Other Third Parties
You must not, during your employment with TeleTech, improperly use or disclose to TeleTech or any TeleTech employee, agent, or contractor any confidential or private information belonging to your former employer or to any other
party to whom you owe a duty of nondisclosure. Questions should be referred to your compliance contact.
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