CODE OF CONDUCT

Introduction

Our Code of Conduct is a clear set of standards for our business conduct. It provides the ethical and behavioural framework on which we base our decisions every day. The Code is anchored in our values and beliefs and underpins all that we do.

Our commitment

We promote and support the Code in our day-to-day business activities, through both personal leadership and
business practice.
We behave according to the principles contained in the Code.
We encourage consultation and the seeking of advice, as appropriate, from the resources available to assist in the application of the Code.
We understand that deviations from, or violations of, the Code are unacceptable and that we must speak up whenever we are aware of such behaviour.
We do not permit retaliation of any kind for good faith reports of perceived illegal or unethical behaviour.
We acknowledge that breaches of the Code may result in disciplinary action, up to and including termination of employment and/or contract.
We affirm our understanding of the principles contained in the Code and our commitment to abide by them.

Our approach

In everything we do, we ask ourselves the following:

Have I consulted appropriately with colleagues?
Are my actions legal and in compliance with the standards of our profession?
Am I compromising my integrity or the integrity of Interval or its clients, professionals or suppliers?
Am I upholding the values of Interval?
Am I respecting others’ different perspectives and backgrounds?
Is my choice of action the most ethical and do I feel good about my choice?
If I document my decision, would a reviewer agree with the action I have taken?
Would my actions damage the reputation of Interval?

The Code helps guide our behaviour - but it is not possible to cover every situation we might encounter. It is intended to help us think about how we live our values in both how we make decisions and our behaviours. We always abide by laws and regulations as well as our own policies, guidance and procedures, and commit to quality and trust.

Our Code of Conduct holds us to the highest standards in the key areas that we operate in:

Working with one another
Working with clients and others
Acting with professional integrity
Maintaining our objectivity and independence
Protecting data, information and intellectual capital

1. Working with one another

We build relationships with each other based on a shared trust and confidence that each of us has a personal and professional commitment to do the right thing.
We respect one another, we value differences and we strive for an inclusive environment free from discrimination, intimidation and harassment. Mistreatment based on gender and gender identity/expression, sexual orientation, nationality, religion, other identity dimensions defined and constructed by some societies in ethnic, color, cultural, or racial terms, or any other form of mistreatment of people based on perceived differences in human characteristics is not tolerated.
We leverage our differences to create an inclusive environment where all people feel, and are valued, for who they are, have a sense of belonging, and are inspired to contribute their best in every encounter.
We are committed to building diverse teams and maximising the power of different perspectives and backgrounds in our teams.
We consult with each other and value the perspectives of those who are different from us, and those who challenge our own point of view.
We nurture integrity, respect, teaming and inclusiveness.
We are committed to communicating openly and honestly.
We rely upon each other to deliver quality service to clients and for our individual development, and are personally accountable to other team members for the contribution we make.
We encourage and support the professional development of our colleagues and promote individual achievement and continuous learning.
We expect and deliver feedback regularly, candidly and constructively, and positively recognise success.

2. Working with clients and others
No client or external relationship is more important than the ethics, integrity and reputation of Interval.

Working with clients

We commit ourselves, as professionals, to uphold the trust placed in us by others.
We are committed to delivering quality services that reflect our professional capabilities, are appropriate to the specific issues and needs of clients, and in accordance with the terms and conditions in our engagement agreements.
We are robust and courageous in our challenges to clients and are not afraid to deliver unwelcome information to them.
We consider not only whether we can perform an engagement, but whether we should perform that engagement.
We support our people and will withdraw from working for any clients that put our people under undue pressure or threaten them in exercising their professional duties.

Working with regulators

We uphold the professional standards and rules applicable to us, and we actively work with the regulators who oversee our professional conduct to ensure that these rules and standards meet the continuously changing needs of the market.

Working with others

We reject unethical or illegal business practices in all circumstances.
We avoid working with clients and others whose standards are incompatible with our Code of Conduct.
We coordinate as appropriate with other members of our profession in matters of public interest.

3. Acting with professional integrity

Our professional integrity

We comply with laws, regulations and standards that apply to us in our professional conduct.
We uphold the Interval reputation. We do not misrepresent the position that Interval takes in professional and other matters.
We promote a culture of consultation. We address questions of ethics and consult appropriately to help resolve them. We do not hide from or ignore issues.
We understand and comply with all Interval policies, guidance and procedures.
We provide a central mailbox for reporting sensitive ethical issues.
We acknowledge that each of us is responsible for keeping our professional knowledge up to date and for sharing best practices and innovation.

Our competitive approach

We recognise our competitive advantage is achieved through the excellence of our professional advice, and the quality of our products, solutions and service delivery.
We compete energetically and vigorously, and we are honest in our competitive behaviour.
We do not offer personal inducements to secure work or other advantages

Documenting our work

We appropriately document client engagements and business operations.
We never destroy or alter documents, or recommend their destruction or alteration, for any illegal or improper reason.
We archive and store documentation appropriately.

Our fees

We charge appropriate fees for our services in accordance with our engagement terms and professional standards.

Time and expenses

We report actual hours worked and expenses incurred.
We incur expenses in accordance with Interval policies or, where agreed, clients’ expense policies.

4. Maintaining our objectivity and independence

Our objectivity

We maintain and affirm our objectivity and independence, recognising that these are critical to our professional responsibilities.
We employ appropriate professional skepticism.
We reject inappropriate pressure from clients or others.
We are alert for personal and professional conflicts of interest and take immediate and appropriate steps to resolve or manage any that may arise.
We do not accept payments or anything of value if this could reasonably be viewed as influencing our conclusions or advice or is otherwise not in compliance with Interval policies.

Our independence

We comply with relevant independence rules, including the restrictions applicable to our families, and we report in a timely manner, and with any further restrictive local country independence professional standards, laws and regulations.
We avoid relationships that impair our objectivity and independence.
We continuously monitor our independence.

5. Protecting data, information and intellectual capital

We respect and protect confidential data and information obtained from, or relating to, clients or third
parties, as well as personal data and information about our people. We only share information when there is a business purpose, and then do so in accordance with our policies, applicable laws and professional standards.
We take proactive measures to safeguard our documents, computers and other data devices that contain personal or confidential data and information, including following policies on information security and technology.
We promptly report any loss, theft or inappropriate disclosure of personal or confidential information in accordance with applicable laws and policies.
We do not use confidential data or personal information for personal gain and comply with applicable insider trading laws and policies.
We use social media and technology in a responsible way and respect the confidentiality of everybody we work with.
We obtain, develop and protect intellectual capital in an appropriate manner. We respect the restrictions on its use and reproduction.

By delivering on the promise of our Code, we protect and enhance the reputation of Interval, and play a key role in building a better world for our people, for our clients and for our communities.

Where to find support

No code can cover every eventuality - any of us may require the advice and support of others in addressing some of the situations that arise during the normal course of daily business life.

We promote a consultative culture at Interval.

If you have any questions regarding our Code of Conduct, please contact us.