Code of Ethics


Confidential Information

A: No. Sharing this nonpublic information is illegal.

A: Congratulations! Submit a conflict of interest disclosure so that we can work through the details.

A: Talk to your manager to determine what information can be shared publicly.

A: If you believe your login credentials have been compromised first reset your password which can be done using this link:  Second, contact IT immediately so the possible compromise can be investigated.

A: No. All software, source code and documentation generated or provided by teammates, consultants, or contractors for the benefit of Convercent are the property of Convercent.  The property of Convercent must remain on a Convercent asset which includes not storing Convercent code or data on a home PC or personal storage account.

A: Loading personal or non-approved software on a Convercent laptop has the possibility of license infringement, imposing licensing obligations or introducing malware.  If new software is required, an IT request needs to be submitted so it can be reviewed and approved.

A: Yes, if you are disclosing non-public information about Convercent, contact the Legal team for a non-disclosure agreement.

A: Confidential information that has not been publicly shared that could cause the stock price or company valuation to go up or down. Some examples include: information related to employees, inventions, contracts, strategic and business plans, major management changes, new product launches, mergers and acquisitions, technical specifications, pricing, customer information, proposals, financial data, and product costs.


Confidential – Most private or sensitive information that must be controlled always.  Disclosure may cause severe problems for Convercent, its customer or business partners.  Access to this information must be approved by the Executive information owner.  Examples include client data, mergers and acquisitions, and legal information protected by attorney-client privilege.

Restricted – Private information restricted to those with a legitimate business need.  Disclosure may cause significant problems for Convercent, its customers or business partners.  Access to this information must be approved by an information owner that is typically a director level or higher.  Examples are customer account information, billing and invoices.

Internal Use Only – The information is intended for use within Convercent, and in some cases business partners.  Disclosure of this information to outsiders may cause problems for Convercent, its customers, or business partners.  This type of information is widely distributed within Convercent or it could be distributed within the organization without advance permission.  Examples are internal telephone book, most electronic messages, and incident or root cause analysis reports.

Public – This information has been approved for public or prospect release.  Disclosure of this information will not cause problems for Convercent, its customers, or business partners.  Examples are approved marketing brochures and material posted to the Convercent web page.

A: It depends. If the documents contain your former employer’s confidential or proprietary information, you cannot use or share this information.  Convercent expects all teammates to honor any disclosure or use restrictions on the confidential information they have obtained from former employers or third parties. If you’re unsure, talk to Legal or Ethics & Compliance.

A: It is acceptable to collect competitive intelligence through publicly available information or ethical inquiries. For example you may gather and use information from sources such as: publicly available filings with government agencies, public speeches of company executives, annual reports, news and trade journal article and publications. You may also ask third parties about our competitors, or accept competitive intelligence offered by a third party, as long as there is no reason to believe that the third party is under a contractual or legal obligation not to reveal such information.

A: Any illegal or illicit activity to obtain competitive information, including theft, trespassing, eavesdropping, wiretapping, computer hacking, invasion of privacy, bribery, misrepresentation or searching through trash.

A: Consult Legal or Ethics & Compliance before asking the employee anything about a former employer’s business. Never ask a former employee of a competitor about any information that the person is under a legal obligation not to reveal. This would include any of our competitor’s trade secrets, and probably other confidential information as well.

Gifts, Travel, & Entertainment

A: You may accept occasional entertainment from customers and suppliers if the event is attended by the customer or the supplier, and the costs involved are in line with local custom for business-related entertainment. For example, general admission tickets to a local sporting event would generally be acceptable. If the value exceeds $100, you must disclose it through the conflict of interest disclosure form. An event with hard-to-come-by tickets, like the Superbowl, would not be ok.

A: If possible, thank them and politely decline. If returning the gift would offend the giver, you may accept the gift, but notify Ethics & Compliance. Ethics & Compliance will work with you to either donate the item to charity, or to distribute or raffle the item among a large group of employees. If it is an item that can be shared, like a gift basket, share it with your team or put it in a common area (like the kitchen) for everyone to enjoy.

A: It’s best to share items like a gift basket with your team or putting it in a common area for everyone to enjoy. However, if we are currently in negotiations with that vendor or in a dispute with them over a contractual matter, it might not be prudent to accept the gift. Any gift valued greater than $100 must be disclosed.

A: Gift cards and cash are not acceptable.

A: You may speak at the conference and they may cover your conference fees and/or travel fees, but you may not accept honoraria.

How We Treat Each Other

A: All teammates are entitled to a workplace where their teammates and leaders treat them with dignity and respect. You should discuss your concern with your leader, the Employee Experience Team, Ethics & Compliance or the Open and Honest Helpline.

A: If the teammate who is the target of the joke finds this offensive and it interferes with his work performance, it can be considered harassment. It could also offend others, even if it doesn’t offend the teammate. Regardless of whether or not the comment seems to offend the teammate, demonstrate care by not using words or actions that isolate, embarrass or make the teammate feel badly.

A: Questions or concerns about benefits, conflict with teammate or leader, workplace conduct, discrimination, performance, compensation, theft, and harassment are just a few of the many topics.

A: Unwelcome remarks, gestures, or physical contact; display of sexually explicit or offensive pictures or other materials; sexual or offensive jokes or comments (explicit or by innuendo); verbal abuse; threats or taunting.

A: You have the right to your personal beliefs and we encourage you to share them openly, as long as those beliefs are shared respectfully and do not restrict anyone else’s. Be mindful of emotionally-charged topics and with whom you’re having the discussion.

A: If you feel comfortable saying something directly to the customer, do so. You should never feel that your personal safety or being treated with dignity and respect should be compromised because the behavior is from a customer. Immediately report the situation to your leader, Employee Experience, Ethics & Compliance or the Open and Honest Helpline.

Outside Personal Activities

A: Depends. If the company directly competes with Convercent, that is a conflict. If it is an unrelated business, then it might be ok. Fill out the disclosure form so that we can discuss the details.

A: No. While teammates are encouraged to pursue outside interests, working for a competitor is a conflict of interest.

A: We encourage you to be involved in your community. Generally, you may serve on the board unless it conflicts with Convercent’s interests. Submit a conflict of interest disclosure so that we can work through the details.

A: We support teammate involvement in public service. Depending on your role within Convercent we may need to put certain guardrails in place. Submit a conflict of interest disclosure so that we can work through the details.

Personal Relationships

A: Not necessarily. Before making the recommendation, disclose your family relationship by using the conflict of interest disclosure form. Following this process enables us to appropriately manage the conflict.  The company could still be considered as a potential supplier but you will not be able to be involved in the supplier selection or supervising the work of that company.

A: Yes. If you are in a position of influence and you have a romantic relationship with a teammate, it could pose a conflict of interest. Submit a conflict of interest disclosure so that we can put the appropriate guardrails in place.

A: A spouse, partner, parent, in-laws (including mother, father, brother and sister in-laws), children, sibling, grandparent, grandchildren, aunts, uncles, nieces, nephews, and any individual who lives with you, shares a home with, or who is otherwise financially dependent on you, or on whom you are financially dependent.

A: It depends on your role at Convercent and your partner’s role. We need more information to guide you through the situation. Disclose the situation using the conflict of interest disclosure form.

Preserving Company Resources

A: Company money, company product, employees’ time at work and word product, computer systems and software, telephones, wireless communication devices, copiers, proprietary information, trademarks and copyrights.

Speaking Up

A: Ask yourself the following questions and if your response is “no” to any of them, seek out additional guidance from Employee Experience, Ethics & Compliance or your leader.

  1. Is it legal?
  2. Is it aligned with our values and policies?
  3. Does it feel like it’s the right thing to do?
  4. Would I feel comfortable if my family and friends knew about it?
  5. Would I feel comfortable allowing the situation to continue?

6. Is it how I would want to be treated?

A: Each of us has a responsibility to speak up if we see something unsafe, unethical or potentially harmful. If you have a question, need help or want to raise a concern you have several options. Talk to your leader, Employee Experience, Ethics & Compliance or report through the Open and Honest Helpline.

A: Explain your concerns to your manager. If you don’t feel comfortable or are pressured to perform the task despite your concerns, talk to another leader, Employee Experience, Ethics & Compliance or report through the Open and Honest Helpline.

A: You may report through our secure web portal at Open and Honest Helpline or SMS anonymously to 720-573-0378.

A: Convercent does not tolerate retaliation. Retaliation can take many forms, for example: threats, intimidation, exclusion, humiliation and raising issues maliciously or in bad faith.

A: Report your concern to Employee Experience, Ethics & Compliance, or through the Open and Honest Helpline.

A: Convercent investigates all matters brought to the Ethics & Compliance Office fairly and objectively, with the highest degree of confidentiality possible. If you are the subject of an investigation and the allegation is determined to be unsubstantiated, Convercent will not use the investigation findings against you. Convercent does not assume that someone who has been named as a subject in an investigation has done anything wrong.

A: Since you reported an allegation and have now experienced a change in the way your manager is treating or behaving toward you this could be a form of retaliation. However, it is possible there are legitimate reasons for the changes. This is something you should discuss with your manager, Employee Experience, or the Ethics & Compliance Office.

Competing Fairly

A: Correct the error during the meeting if possible. If that is not possible, raise the issue with the teammate, your manager, or other Convercent leader after the meeting, and ensure that Convercent corrects any customer misperception.

A: Giving or offering to give anything of value to a government official to influence a discretionary decision.

A: Small sums paid to non-U.S. government officials to expedite or facilitate non-discretionary actions or services, such as obtaining and ordinary license or phone service.

A: No. All payments much be directly related to products and services outlined in the relevant contract with the governmental agency and the related cost/fee schedules. These payments must be made to the governmental agency and never to any individual government official, without regard to the size of the payment.

A: Elected officials and employees of a federal, national, state or local government, such as customs officials and tax authorities; political parties; candidates for political office; employees of any public agency or state-owned organization such as state-owned hospitals and universities; employees of public international organizations, such as the United Nations.

A: Report your suspicions to Legal or Ethics & Compliance at once. No such payments should be made to the consultant until the company has investigated your concerns.