CORPORATE SOCIAL RESPONSIBILITY

Cicero is deeply committed to providing positive social impact through pro bono services. Cicero management consultants are expected to provide pro bono services at the same level of quality and commitment as billable services. As Cicero is fully committed to positive ESG, pro bono activities should align with Cicero’s Corporate Social Responsibility mission of furthering the U.N.’s Sustainable Development Goals.

Cicero expects that, at a minimum, an average of 50 hours pro bono work is completed per employee in any given year. For illustrative purposes, if Cicero has 100 employees, it is expected that, at a minimum across the firm, 5000 pro bono hours of management consulting work will be completed in any given year.

All Cicero employees, regardless of level, are encouraged to devote a portion of their time and professional services to pro bono matters. Undertaking such activities is an essential element of any Cicero employee’s professional and ethical responsibility. Cicero has a Cicero Group is committed to having a positive social impact. As a firm, we strongly encourage employees to fulfill pro bono work annually. At a minimum, Cicero will complete, on average across the firm,

DEFINITION OF PRO BONO CICERO SERVICES
Pro bono services, for purposes of this policy, refers to activities of the Firm undertaken normally without expectation of a fee and not in the course of ordinary commercial practice and consisting of:

• The delivery of management consulting services to persons of limited means or to charitable, religious, civic, community, governmental and educational organizations in matters which are designed primarily to address the needs of persons of limited means
• Management consulting services to charitable, religious, civic, community, governmental, or educational organizations in matters in furtherance of their organizational purposes, where the payment of standard consulting fees would significantly deplete the organization’s economic resources or would be otherwise inappropriate
• Pro bono work must involve management consulting services for which paying clients would normally be billed. Pro bono work does not include promotional work, client development, career advancement projects, work originally undertaken for a fee, work undertaken for existing or potential paying clients for no fee, work performed for Cicero employees
• Service as an officer or on a board of a charitable or civic organization

Time for pro bono work should be recorded under the appropriate time code number.

PRO BONO COMMITTEE
The Pro Bono Committee is comprised of both management and non-management employees. Pro Bono Committee members serve staggered three-year terms and may serve up to two consecutive terms. The Pro Bono Committee has the following functions:

• Help administer the firm wide pro bono program, including attending Pro Bono Committee meetings, reviewing pro bono proposals, reviewing new pro bono policies, and assisting in gathering information for internal or external reporting
• Promote the pro bono program internally and externally
• Direct office-level pro bono activities, including answering questions regarding submission of pro bono proposals, distributing quarterly supervisor memos, finding and circulating pro bono opportunities, and, for partners, monitoring associates’ pro bono hours
• Participate in the pro bono program, including doing a minimum of 50 hours of pro bono work each year

PRO BONO PROPOSALS
The Pro Bono Proposal Form should be sent to the Pro Bono Committee for approval. Please contact us to obtain the form.

Cicero is fully committed to positive ESG.  Employees and sub-contractors represent Cicero and through their behavior and actions should reinforce Cicero’s commitment to social impact, ethical business, and sustainability.

In accordance with Cicero’s commitment to the highest standards we expect employees and sub-contractors to uphold the following standards:

SYSTEMS AND NETWORK ACCESS
Access to Cicero systems and data is restricted to only those systems and data that are approved by Cicero and necessary to perform the agreed-upon services.  Employees and sub-contractors shall comply with Cicero’s Acceptable Use Policy.  Any attempt to access data not authorized for employee is a violation of Cicero security policy.  If Cicero becomes aware of an employee trying to access systems he or she is not authorized for, Cicero will take immediate action, which may include termination.

Access codes and passwords may not be shared or communicated to anyone other than the individual to whom the access is assigned.  Sharing of these credentials may be cause for termination.  All extranet (those connections that are not located physically on or within a Cicero site) connections must have a Cicero-approved security plan on file before the connection may be established and utilized.  All Cicero-owned hardware and/or employee and sub-contractors-provided hardware used by employees and sub-contractors to access Cicero systems (including via remote access) shall be subject to a systems hardening review and vulnerability testing measures as conducted by Cicero’s information security teams and, if necessary, Cicero can request that measures be added or configurations changed to ensure the devices meet Cicero’s security requirements.

USE OF CICERO PROPERTY
Employees and sub-contractors are responsible for the proper use of Cicero property, and must safeguard it against loss, damage, misuse or theft.  Cicero property is provided to employees and sub-contractors for Cicero business purposes only.  Personal use of Cicero equipment such as phones and computers should be kept to a minimum.  Any unauthorized duplication and use of software is a violation of copyright laws of the United States.  All Internet, intranet and e-mail activities using Cicero systems are to be conducted for legitimate business purposes that are directly related to the services Employees and sub-contractors is performing for Cicero.  Employees and sub-contractors may not post or discuss business information concerning Cicero with the media or on the Internet.

DATA PRIVACY AND CONFIDENTIALITY
Employees and sub-contractors must comply with applicable privacy and data protections laws and regulations in the respective countries of operation, as well as secure Cicero confidential data and individual personal data and prohibit its unauthorized access or use.

ETHICAL STANDARDS
Cicero employees and sub-contractors conduct business with the highest ethical standards.  Employees and sub-contractors should abide by the following ethical standards and guidelines:

• Obey all relevant laws
• Treat each other fairly, with dignity and respect
• Prepare all records of financial transactions carefully and accurately
• Report financial conditions and results of operations, honestly and promptly
• Deal honestly and fairly with clients, customers, Employees and sub-contractors, and financial partners
• Avoid actual and potential conflicts of interest
• Avoid the improper giving and receiving of gifts
• Safeguard Cicero’s assets
• Protect Cicero’s reputation
• Separate personal political activities from Cicero’s business
• Report observed violations of legal and ethical standards

HEALTH & SAFETY
Cicero expects its employees and sub-contractors to strive to implement the standards of occupational health and safety at a high level.  Employees and sub-contractors comply with applicable occupational health and safety regulations and provides a work environment that is safe and conducive to good health, in order to preserve the health of employees and prevent accidents, injuries and work-related illnesses.

Cicero maintains a drug and alcohol-free work environment. No employees and sub-contractors are permitted to possess, consume, sell, or be under the influence of alcohol and illegal drugs (and legal drugs that are not used in a manner consistent with dosage requirements) while in any Cicero facility.  Any employee or sub-contractor found to be in violation of this policy may be removed from company premises and not allowed to re-enter a Cicero facility.  Firearms and any other weapons are not allowed in any Cicero facilities and may not be carried when conducting any Cicero business.  Violent or abusive behavior will not be tolerated at Cicero.

 

PROHIBITIONS AGAINST DISCRIMINATION AND HARASSMENT
Cicero does not tolerate unlawful discrimination or harassment in the workplace.  Employees and sub-contractors must not engage in any unlawful discriminatory or harassing conduct on Cicero’s facilities or directed at anyone in the workplace.  Discrimination or harassment based on race, color, religion, national origin, citizenship, ancestry, gender (including pregnancy), gender identity, age, disability, marital status, sexual orientation, or other protected characteristic or status is strictly prohibited.

Sexual harassment is generally defined as unwelcome sexual advances, requests for sexual favors, or other visual, verbal or physical conduct of a sexual nature when: (i) submission to such conduct is made, either explicitly or implicitly, a term or a condition of employment; (ii) submission to or rejection of such conduct affects employment opportunities; or (iii) such conduct interferes with an individual’s work or creates an intimidating, hostile, or offensive work environment.  Examples of sexual harassment include, but are not limited to: sexual gestures, leering, or displaying sexually suggestive objects or pictures; derogatory comments, epithets, slurs, teasing and jokes of a sexual nature; graphic comments about an individual’s sex life or body; suggestive or obscene letters, e-mails, notes or invitations; and unwelcome physical contact.

Cicero may, in its sole and absolute discretion, remove from the premises any employee or sub-contractor who engages in offending conduct.

Employees and sub-contractors must promptly report any offending behavior, by notifying any member of Cicero management.

COMPLIANCE WITH LABOR LAWS; LABOR STANDARDS
Employees and sub-contractors shall comply with all laws applicable to its business. Employees and sub-contractors should support the principles of the United Nations Global Compact, the UN Universal Declaration of Human Rights as well as the 1998 International Labour Organization Declaration on Fundamental Principles and Rights at Work, in accordance with national law and practice.

CHILD LABOR.  Employees and sub-contractors are prohibited from recommending to clients that they employ workers under the legal age of employment in any country or local jurisdiction. If the minimum age of employment is not defined, the minimum age of employment shall be 15 years of age.

FORCED LABOR.  Employees and sub-contractors shall not recommend to clients that they employ or use any form of forced, bonded or compulsory labor, or other forms of slavery or human trafficking and will take all reasonable steps to ensure that there is no form of forced, bonded or compulsory labor, or other forms of slavery or human trafficking employed or used within its business or in its supply chains.

COMPENSATION AND WORKING HOURS.  Employees and sub-contractors shall comply with the respective national laws and regulations regarding working hours, wages and benefits.

DISCIPLINARY PRACTICES/COERCION.  Cicero firmly believes that everyone should be treated with dignity. No one within Cicero shall inflict or threaten to inflict corporal punishment or any other forms of physical, sexual, psychological or verbal abuse or harassment on any employees.

FREEDOM OF ASSOCIATION.  Employees and sub-contractors shall be free to join organizations of their own choice. Employees and sub-contractors shall respect and recognize the right of others to join and organize associations of their own choosing, and to bargain collectively.  Employees shall not be subject to intimidation or harassment in the exercise of their right to join or to refrain from joining any organization.

ENVIRONMENT
Employees and sub-contractors shall comply with all applicable environmental laws, regulations and standards as well as implement an effective system to identify and eliminate potential hazards to the environment.  Employees and sub-contractors should wherever possible support a precautionary approach to environmental matters, undertake initiatives to promote greater environmental responsibility.

COMMUNITY INVOLVEMENT
Cicero seeks to employ individuals who volunteer to improve the educational, cultural, economic and social well-being of the communities in which they live and serve.

GIFTS; CONFLICTS OF INTEREST
Cicero employees may not accept gifts, gratuities or excessive entertainment (i.e., beyond nominal, conventional business courtesies, such as an occasional luncheon) from any individual or organization with which Cicero has business dealings.  Employees and sub-contractors shall refrain from giving any gifts, payments or the like that would, or could be perceived to violate this policy.  Employees and sub-contractors should further refrain from accepting or giving any gifts, favors, payments, entertainment, loans or the like with a purpose of obtaining any improper advantage or influence for the individual, Cicero or any third party with any client, prospective client or other third party or that create any appearance of impropriety. Employees and sub-contractors must disclose all potential conflicts of interest, including those in which employees and sub-contractors may have been placed inadvertently due to either business or personal relationships with customers, suppliers, business associates, or competitors of Cicero, or with other Cicero employees. Employees may not act on behalf of Cicero in any transaction or business relationship involving themselves or members of their family, or other persons or organization with which they or their family have any significant personal connection or financial interest.

BUSINESS INTEGRITY; CORRUPTION
Corruption, bribery, extortion, and embezzlement, in any form, are strictly prohibited. Employees and sub-contractors shall not violate the Foreign Corrupt Practices Act, the UK Bribery Act, any international anti-corruption conventions, and applicable anti-corruption laws and regulations of the countries in which they operate, and shall not engage in corruption, bribery, extortion or embezzlement in any form. Employees and sub-contractors shall not offer or accept bribes or other means to obtain an undue or improper advantage. Employees and sub-contractors must uphold fair business standards in advertising, sales, and competition.

INSIDER TRADING
Buying or selling securities while in possession of material non-public information that employees or sub-contractors acquire by virtue of their relationship with Cicero is prohibited, as is the communication of that information to others, whether expressly or by way of making a recommendation for the purchase or sale of such securities based upon that information.

FRAUD AND INVESTIGATIONS
Employees and sub-contractors are expected to cooperate with Cicero investigators, law enforcement and regulatory agencies in the event of any investigation of wrongdoing. This cooperation includes reporting violations of the law and cooperating with law enforcement agencies in their prosecution efforts.

Should Employees and sub-contractors receive any subpoenas, regulatory requests, media inquiries, or other third party requests concerning Cicero, Employees and sub-contractors shall promptly forward such matter to Cicero, to the extent permitted to do so by law.

COMPLIANCE
Cicero reserves the right to ask employees and sub-contractors to re-affirm compliance with this Code of Conduct periodically, to investigate compliance by employees and sub-contractors with this Code of Conduct at any time and to immediately remove employees and sub-contractors from Cicero premises and/or terminate employment or contract in the event of noncompliance.

CHANGES TO THE EMPLOYEE AND SUB-CONTRACTOR CODE OF CONDUCT
This employee and sub-contractor Code of Conduct may be revised or updated by Cicero from time to time. To the extent there is a conflict between this Code of Conduct and any applicable law or provision of any agreement between Cicero and Employees and sub-contractors, the applicable law or agreement shall apply.

INTRODUCTION
Cicero is committed to the highest standards of ethical conduct and social and environmental responsibility. We expect our Suppliers to aspire to these same standards in their business operations and, to have their own policies and processes in place addressing the matters detailed herein.  Accordingly, Cicero has created this “Supplier Code of Conduct”, which sets out the standards expected of any Supplier doing business with Cicero.

“Supplier” means any firm or individual that provides a product or service or undertakes any activity for or on behalf of Cicero, either directly or indirectly.

“Supplier Representative” means any individual who works for a Supplier, whether under a contract of employment or any other contract (written or oral) where an individual undertakes to do personally any work or services for the Supplier and includes, without limitation, Supplier’s principals, officers, directors, employees and independent contractors.

SYSTEMS AND NETWORK ACCESS
Access to Cicero systems and data is restricted to only those systems and data that are approved by Cicero and necessary to perform the agreed-upon services.  Any Supplier Representative that is authorized to access Cicero’s systems shall comply with Cicero’s Acceptable Use Policy which will be provided to such Supplier Representative if and as applicable.  Any attempt to access data not authorized to Supplier is a violation of Cicero security policy.  If Cicero becomes aware of a Supplier Representative attempting to access systems he or she is not authorized for, Cicero will take immediate action, which may include (a) removing Supplier Representative from Cicero premises; (b) terminating Supplier Representative’s access; (c) terminating Supplier’s services contract with Cicero.  Access codes and passwords may not be shared or communicated to anyone other than the individual to whom the access is assigned.  Sharing of these credentials may be cause for termination of access of Supplier Representative(s) and Supplier’s services contract with Cicero.  All extranet (those connections that are not located physically on or within a Cicero site) connections must have a Cicero-approved security plan on file before the connection may be established and utilized.  All Cicero-owned hardware and/or Supplier-provided hardware used by Supplier to access Cicero systems (including via remote access) shall be subject to a systems hardening review and vulnerability testing measures as conducted by Cicero’s information security teams and, if necessary, Cicero can request that measures be added or configurations changed to ensure the devices meet Cicero’s security requirements.

The foregoing requirements shall not be deemed to limit, in any way, any representations, warranties or covenants regarding IT, data security and confidentiality included in any agreement between Supplier and Cicero.

USE OF CICERO PROPERTY
Supplier is responsible for the proper use of Cicero property, and must safeguard it against loss, damage, misuse or theft.  Cicero property is provided to Supplier for Cicero business purposes only.  Personal use of Cicero equipment such as phones and computers should be kept to a minimum.  Any unauthorized duplication and use of software is a violation of copyright laws of the United States.  All Internet, intranet and e-mail activities using Cicero systems are to be conducted for legitimate business purposes that are directly related to the services Supplier is performing for Cicero.  Supplier may not post or discuss business information concerning Cicero with the media or on the Internet.

DATA PRIVACY AND CONFIDENTIALITY 
Suppliers must comply with applicable privacy and data protections laws and regulations in the respective countries of operation, as well as secure Cicero confidential data and individual personal data and prohibit its unauthorized access or use.

ETHICAL STANDARDS
Cicero seeks to identify Suppliers that conduct business with ethical standards consistent with its own.  Supplier should abide by the following ethical standards and guidelines:

• Obey all relevant laws
• Treat each other fairly, with dignity and respect
• Prepare all records of financial transactions carefully and accurately
• Report financial conditions and results of operations, honestly and promptly
• Deal honestly and fairly with clients, customers, suppliers, and financial partners
• Avoid actual and potential conflicts of interest
• Avoid the improper giving and receiving of gifts
• Safeguard Cicero’s assets
• Protect Cicero’s reputation
• Separate personal political activities from Cicero’s business
• Report observed violations of legal and ethical standards

HEALTH & SAFETY
Cicero expects its Suppliers to strive to implement the standards of occupational health and safety at a high level.  Supplier complies with applicable occupational health and safety regulations and provides a work environment that is safe and conducive to good health, in order to preserve the health of employees and prevent accidents, injuries and work-related illnesses.

Cicero maintains a drug and alcohol-free work environment. No Supplier or Supplier Representative is permitted to possess, consume, sell, or be under the influence of alcohol and illegal drugs (and legal drugs that are not used in a manner consistent with dosage requirements) while in any Cicero facility.  Any Supplier found to be in violation of this policy may be removed from company premises and not allowed to re-enter a Cicero facility.  Firearms and any other weapons are not allowed in any Cicero facilities and may not be carried when conducting any Cicero business.  Violent or abusive behavior will not be tolerated at Cicero.  Any Supplier Representative engaging in such conduct may be removed from the premises and not allowed to re-enter a Cicero facility.

PROHIBITIONS AGAINST DISCRIMINATION AND HARASSMENT
Cicero does not tolerate unlawful discrimination or harassment in the workplace.  Supplier must not engage in any unlawful discriminatory or harassing conduct on Cicero’s facilities or directed at anyone in the workplace.  Discrimination or harassment based on race, color, religion, national origin, citizenship, ancestry, gender (including pregnancy), gender identity, age, disability, marital status, sexual orientation, or other protected characteristic or status is strictly prohibited.

Sexual harassment is generally defined as unwelcome sexual advances, requests for sexual favors, or other visual, verbal or physical conduct of a sexual nature when: (i) submission to such conduct is made, either explicitly or implicitly, a term or a condition of employment; (ii) submission to or rejection of such conduct affects employment opportunities; or (iii) such conduct interferes with an individual’s work or creates an intimidating, hostile, or offensive work environment.  Examples of sexual harassment include, but are not limited to: sexual gestures, leering, or displaying sexually suggestive objects or pictures; derogatory comments, epithets, slurs, teasing and jokes of a sexual nature; graphic comments about an individual’s sex life or body; suggestive or obscene letters, e-mails, notes or invitations; and unwelcome physical contact.

Cicero may, in its sole and absolute discretion, remove from the premises any Supplier who engages in offending conduct.

Supplier must promptly report any offending behavior, whether such behavior is directed to Supplier or to employees of Cicero, by notifying any member of Cicero management.

COMPLIANCE WITH LABOR LAWS; LABOR STANDARDS
Supplier shall comply with all laws applicable to its business. Supplier should support the principles of the United Nations Global Compact, the UN Universal Declaration of Human Rights as well as the 1998 International Labour Organization Declaration on Fundamental Principles and Rights at Work, in accordance with national law and practice.

CHILD LABOR.  Suppliers are prohibited from using workers under the legal age of employment in any country or local jurisdiction where Supplier performs work for Cicero. If the minimum age of employment is not defined, the minimum age of employment shall be 15 years of age. In cases where minors are authorized to work, we expect our Suppliers to observe all legal requirements, particularly those pertaining to hours of work, wages, minimum education and working conditions.

FORCED LABOR.  Supplier shall not employ or use any form of forced, bonded or compulsory labour, or other forms of slavery or human trafficking and will take all reasonable steps to ensure that there is no form of forced, bonded or compulsory labor, or other forms of slavery or human trafficking employed or used within its business or in its supply chains.

COMPENSATION AND WORKING HOURS.  Supplier shall comply with the respective national laws and regulations regarding working hours, wages and benefits.

DISCIPLINARY PRACTICES/COERCION.  Cicero firmly believes that everyone should be treated with dignity. Suppliers shall not inflict or threaten to inflict corporal punishment or any other forms of physical, sexual, psychological or verbal abuse or harassment on any employees.

FREEDOM OF ASSOCIATION.  Supplier Representatives shall be free to join organizations of their own choice. Suppliers shall respect and recognize the right of employees to join and organize associations of their own choosing, and to bargain collectively.  Employees shall not be subject to intimidation or harassment in the exercise of their right to join or to refrain from joining any organization.

ENVIRONMENT
Supplier shall comply with all applicable environmental laws, regulations and standards as well as implement an effective system to identify and eliminate potential hazards to the environment.  Suppliers should wherever possible support a precautionary approach to environmental matters, undertake initiatives to promote greater environmental responsibility.

COMMUNITY INVOLVEMENT
Cicero seeks to work with Suppliers that partner with local governments and communities to improve the educational, cultural, economic and social well-being of the communities in which they live and serve.

GIFTS; CONFLICTS OF INTEREST
Cicero employees may not accept gifts, gratuities or excessive entertainment (i.e., beyond nominal, conventional business courtesies, such as an occasional luncheon) from any individual or organization with which Cicero has business dealings and Supplier shall refrain from giving any gifts, payments or the like that would, or could be perceived to violate this policy.  Supplier should further refrain from accepting or giving any gifts, favors, payments, entertainment, loans or the like with a purpose of obtaining any improper advantage or influence for the Supplier, Cicero or any third party with any client, prospective client or other third party or that create any appearance of impropriety. Supplier must disclose all potential conflicts of interest, including those in which Supplier may have been placed inadvertently due to either business or personal relationships with customers, suppliers, business associates, or competitors of Cicero, or with other Cicero employees. Employees of Supplier may not act on behalf of Cicero in any transaction or business relationship involving themselves or members of their family, or other persons or organization with which they or their family have any significant personal connection or financial interest.

BUSINESS INTEGRITY; CORRUPTION
Corruption, bribery, extortion, and embezzlement, in any form, are strictly prohibited. Suppliers shall not violate the Foreign Corrupt Practices Act, the UK Bribery Act, any international anti-corruption conventions, and applicable anti-corruption laws and regulations of the countries in which they operate, and shall not engage in corruption, bribery, extortion or embezzlement in any form. Suppliers shall not offer or accept bribes or other means to obtain an undue or improper advantage. Suppliers must uphold fair business standards in advertising, sales, and competition.

INSIDER TRADING
Buying or selling securities while in possession of material non-public information that Supplier acquires by virtue of their relationship with Cicero is prohibited, as is the communication of that information to others, whether expressly or by way of making a recommendation for the purchase or sale of such securities based upon that information.

FRAUD AND INVESTIGATIONS
Supplier is expected to cooperate with Cicero investigators, law enforcement and regulatory agencies in the event of any investigation of wrongdoing by Supplier or others doing business with Cicero. This cooperation includes reporting violations of the law and cooperating with law enforcement agencies in their prosecution efforts.

Should Supplier receive any subpoenas, regulatory requests, media inquiries, or other third party requests concerning Cicero, Supplier shall promptly forward such matter to Cicero, to the extent permitted to do so by law.

REPRESENTATION OF CICERO
Supplier may not represent itself as an employee of Cicero or enter into any agreement on Cicero’s behalf or in Cicero’s name.

COMPLIANCE
Cicero reserves the right to ask Supplier to re-affirm compliance with this Code of Conduct periodically, to investigate compliance by Supplier with this Code of Conduct at any time and to immediately remove Supplier from Cicero premises and/or terminate the related services contract with Supplier in the event of noncompliance.

COMMUNICATION
Supplier should take appropriate steps to ensure that the principles of this Code are communicated to their employees and throughout their own supply chains. Supplier should also take appropriate steps to ensure that the principles of this Code are adopted and applied by their employees, suppliers, agents and contractors to the extent applicable.

ENFORCEMENT
If Cicero determines that any Supplier has violated this Code, Cicero may either terminate its business relationship or require the Supplier to implement a corrective action plan. If corrective action is advised, but not taken, Cicero will suspend placement of future orders and shall terminate its business relationship with Supplier.

REPORTING CONCERNS
Actual, or suspected, material violations by a Supplier of this Supplier Code of Conduct or any other severe violations potentially harming our clients, Cicero’s employees or Cicero as a firm should be raised to your Cicero contact, Cicero’s anonymous global reporting platform, in the first instance.  Similarly, if you are a Supplier to Cicero and suspect that a Cicero employee, or anyone acting on behalf of the firm, has engaged in illegal or otherwise improper conduct, you should report the matter immediately to your Cicero contact

CHANGES TO THE SUPPLIER CODE OF CONDUCT
This Supplier Code of Conduct may be revised or updated by Cicero from time to time. To the extent there is a conflict between this Supplier Code of Conduct and any applicable law or provision of any agreement between Cicero and Supplier, the applicable law or agreement shall apply.

At Cicero, we recognize the value diversity brings to our employees, clients and communities we serve. The goal of Cicero’s Supplier Diversity Program is to promote the inclusion of small and diverse businesses in our purchasing process, and to continuously strive to increase our spend with qualifying enterprises.

Qualifying suppliers must meet business size criteria established by the Small Business Administration, and include enterprises across the following categories:

• Women-owned businesses
• Veteran-owned businesses
• Service-disabled veteran-owned businesses
• LGBT-owned businesses
• Disadvantaged businesses
• Historically Underutilized Business Zone (HUBZone) businesses
• Minority-owned and other small businesses

Suppliers are evaluated on several criteria including price, quality, customer service, delivery, and other business requirements.

Categories of goods and services we purchase include, but are not limited to:

• Professional services (e.g. temporary staffing, legal, coaching)
• Facilities (e.g. construction, maintenance, repair, painting, lighting, cleaning, supplies)
• Office services (e.g. flowers, gifts, catering, meetings & events)
• Marketing (e.g. creative, photo/video, promotional services)

We aim to reach our program goals by:

• Identifying, actively seeking and continuously expanding our network of small diverse business vendors
• Training and encouraging our purchasers to include small diverse business vendors in the purchasing process where there is alignment with our business needs
• Monitoring and measuring the effectiveness of our supplier diversity efforts

Cicero is committed to development of a diverse supplier base. We encourage all employees to be inclusive in their daily business decisions when selecting the best supplier to meet our business needs.

Cicero is fully committed to positive ESG. Procurement, including criteria in evaluating vendor RFP’s, should reinforce Cicero’s expectation that our partners are committed toward s social impact and that they strive for sustainability within their organization. Cicero believes it can drive positive impact by encouraging social impact and sustainability within its sourcing and procurement process.

Through Cicero’s procurement policy, we intend to make our operations more sustainable by:

• Upholding the laws and regulations of the respective countries we operate in
• Endorsing highest standards of economic, social, ethical and environmental practices
• Identifying and moderating risks associated with our procurement process
• Communicating the policy with stakeholders (internal and external) and raising awareness among our suppliers

In accordance with Cicero’s commitment to the highest standards, we also expect our suppliers to aspire to the same standards in their business operations, including but not limited to:

ENVIRONMENT

• Comply and adhere to all the applicable environmental laws in respective countries/jurisdiction
• Undertake initiatives to promote greater environmental responsibility such as:
  • Responsible waste management and disposal
  • Reduction of greenhouse gas and other emissions harmful to the environment
  • Conservation of non-renewable natural resources

BUSINESS ETHICS

• Obey all relevant international and domestic laws regarding ethical business practices
• Demonstrate existence of procedures to prevent:
  • Money laundering
  • Fraud, bribery, corruption
  • Conflicts of interest
  • Data security issues

LABOR AND HUMAN RIGHTS

• Comply with all applicable laws, in accordance with the principles of the International Labor Organization, the UN Global Compact and the UN Universal Declaration of Human Rights
• Prohibit slavery and the use of forced, bonded, or child labor across the supply chain
• Prohibit unlawful discrimination and harassment to provide a safe and inclusive work environment

COMMUNITY DEVELOPMENT

• Provide employees with a living wage, at a minimum
• Partner with the local governments and communities to improve the education, cultural, economic, and social well-being of communities which they operate in

We understand that procurement performance improvement is a continuous process. We recognize and appreciate the contribution of our suppliers in our journey to become more sustainable.