Corporate Ethics

Effective Date: March 1, 2020

The successful business operation and reputation of NCR is built upon the principles of fair dealing and ethical conduct of our employees. Our reputation for integrity and excellence requires careful observance of the spirit and letter of all applicable laws and regulations, as well as scrupulous regard for the highest standards of conduct and personal integrity.

We will comply with all applicable laws and regulations and we expect all directors, officers, agents, volunteers, and employees to conduct business in accordance with the letter, spirit, and intent of all relevant laws and to refrain from any illegal, dishonest, or unethical conduct.

In general, the use of good judgment, based on high ethical principles, will guide you with respect to lines of acceptable conduct. If a situation arises where it is difficult to determine the proper course of action, the matter should be discussed with your supervisor.

Compliance with this policy of business ethics and conduct is the responsibility of every employee. Disregarding or failing to comply with this standard of business ethics and conduct may lead to disciplinary action, up to and including termination of employment, a contract, or the relationship with NCR.

Retaliation against any party who raises any questions, concerns or complaints concerning the honesty and integrity of our operations is strictly prohibited. Similarly, retaliation is prohibited against any party who provides accurate information to any law enforcement agency about the commission of any federal or state offense. Any party who feels that he or she has been retaliated against or threatened with retaliation for these reasons should report the matter immediately to the NCR Chief Compliance Officer, or – in the case of a complaint pertaining to the NCR Chief Compliance Officer – to any Director of the NCR Board.

Protection Against Retaliation

Retaliation is prohibited against any person by another director, officer, employee, agent, or volunteer or by NCR for using this complaint procedure, reporting harassment, or for filing, testifying, assisting or participating in any manner in any investigation, proceeding or hearing conducted by a governmental enforcement agency. Prohibited retaliation includes, but is not limited to, termination, demotion, suspension, failure to hire or consider for hire, failure to give equal consideration in making employment decisions, failure to make employment recommendations impartially, adversely affecting working conditions or otherwise denying any employment benefit.

Please report any retaliation to the NCR Chief Compliance Officer or – in the case of a complaint pertaining to the NCR Chief Compliance Officer – to any Director of the NCR Board.

Any report of retaliatory conduct will be investigated in a thorough and objective manner. If a report of retaliation is substantiated, appropriate disciplinary action, up to and including discharge or termination of the appropriate relationship, will be taken.

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