CPV Policies – Setting The Standard For Business Conduct

First and foremost, every CPV employee is required to attest to compliance with the CPV Code of Business Conduct and Ethics when they join the company, and then again on a yearly basis after that. The Code itself is subject to frequent reviews and updates by the CPV Legal Team. CPV’s additional corporate policies stem from our Code of Conduct and further guide our activities and interactions with stakeholders. Our “Zero Tolerance” commitment to anti-corruption is embodied in three key company policies:

• CPV Lobbying Policy and Procedures
• CPV Political Contributions Policy and Procedures
• CPV Charitable Contributions, Sponsorship Payments, and Membership Dues Policy and Procedures

These policies describe the system of checks and balances CPV deploys to ensure that specific measures are taken to safeguard against corruption, bribery, and misuse of company funds. We incorporate these principles and measures into our relationships with our stakeholders, partners, suppliers, and communities.

CPV Corporate Compliance Program

In addition to the guidance of our company policies, CPV’s Corporate Compliance Program is comprised of a number of inputs, including an annual Enterprise Risk Assessment, internal controls audit, annual policy reviews, regular employee trainings, and cases logged (and resolved) via our employee reporting hotline, to name a few. A robust control framework governs CPV’s business dealings and underpins the company’s culture of accountability. Finally, employees are encouraged to speak up if they become aware of something that does not comply with CPV’s standards of business practice.

Employee Training

Every CPV employee, from senior leadership to new hires, completes an annual training curriculum covering IT security awareness, ethical business practice, and CPV-specific compliance procedures and controls.

Quarterly Compliance Reporting To Our Board

On a quarterly basis, CPV’s Chief Compliance Officer prepares a compliance briefing for CPV’s Board of Directors, which is comprised of members of our parent company and our CEO, Gary Lambert. The direct line of communication between our Chief Compliance Officer and our Board ensures that CPV’s directors and senior leadership are consistently informed regarding the company’s compliance posture. The quarterly reporting cadence ensures that we show progress in all areas of compliance on a regular basis and that we continue to incorporate a compliance mindset into all business activities.