Ethic Rules

Based on our christian roots and catholic values we have set up the following rules of conduct and code of ethics in Bordes Consulting and we do our very best to:

1.    Inspire our employees by empowering them with a clear and common understanding of the ethical boundaries in which we must operate.

2.    Engage our workforce by ensuring that we maintain a respectful and welcoming work environment.

3.    Create a sustainable compliance and integrity framework to support innovation in products, processes and solutions in a highly regulated world.

 Rules of Conduct

The Code of Ethics of Bordes Consulting provides an overview of the important legal and ethical guidelines that everyone working for Bordes Consulting must strive to follow. The Code of Ethics sets forth Bordes Consulting ’s aspirational goals for all of its employees, and is designed to help each of us know what the relevant compliance and ethics rules are and how they apply to our business. In addition, employees may be directed to other corporate resources for further information and assistance. For example, Bordes Consulting ’s Key Policies provide more detailed information about certain laws and how they are applied and enforced.

The Code of Ethics and The Key Policies are guidance and policy statements for business conduct and do not create an employment contract. The Code of Ethics and The Key Policies are binding on all Bordes Consulting  employees to the extent permitted by law. A violation of The Code of Ethics, The Key Policies may be grounds for Bordes Consulting  to initiate disciplinary action that could lead to termination and, in some instances, result in civil and criminal liability.

The Code of Ethics and The Key Policies apply to every employee (employees, executives and officers) of Bordes Consulting and its subsidiaries worldwide. Each employee must annually certify that they have completed Code of Ethics training and that they have received, read, understood, complied with and will continue to comply with The Code of Ethics and The Key Policies. Any employee who does not certify in a timely manner may be subject to discipline, including ineligibility for salary increases and/or discretionary bonus payments until he or she has done so. Any employee who refuses to certify may be subject to termination.

Any employee who acts in good faith to seek advice, raise a concern, or report misconduct is following The Code of Ethics. Bordes Consulting SL will not tolerate direct or indirect retaliation of any sort against such individuals. Those who engage in retaliatory conduct will be subject to disciplinary action, which may include termination.

Those who supervise others have the additional responsibilities of ensuring that those they supervise understand The Code of Ethics and The Key Policies, monitoring compliance, and supporting those who report a suspected violation.

Specific Business Units, operating companies or departments within Bordes Consulting may have policies that exceed the standards set forth in The Code of Ethics. All Bordes Consulting SL attorneys will receive a supplement to The Code of Ethics addressing ethical issues unique to their positions and our Board of Directors will receive a Code of Ethics tailored to its role. As we move forward, additional supplements and/or certification processes for other groups or Business Units may also be issued. It is the obligation of each of us to understand and comply with any additional policies as they pertain to us as Bordes Consulting SL employees.

There may be regulations or laws that apply to a specific business activity that are not covered by The Code of Ethics. Even if these laws or regulations are not specifically addressed in The Code of Ethics, they are deemed to be included and must be complied with as if they are. In other words, The Code of Ethics requires that all Bordes Consulting SL employees act in a lawful manner and comply with all applicable laws, rules and regulations that impact their work for the Company. But only in cases that these laws are not affecting, attacking or abusing catholic values of life.

Recognizing that more detailed guidance is provided in The Key Policies,  the employees of Realogy has to make the following commitments:

  • Providing Equal Employment Opportunity:
    We will make employment decisions without regard to race, color, national origin, citizenship, age, sex, veteran status, marital status, disability. We will make reasonable accommodations for qualified disabled employees and applicants, unless such accommodations would impose undue hardship on Bordes Consulting’s operation. This policy applies to all aspects of employment, including recruitment, hiring, testing, compensation, assignment, training, promotion, discipline, termination, and other privileges, terms and conditions of employment.
  • Intolerance of Favoritism:
    We will endeavor to treat employees in a fair and impartial manner. Bordes Consulting managers (that is, all employees who directly or indirectly supervise or direct another employee on a full- or part-time basis) will not favor any employee in assignments, compensation or promotions or similar matters based on any personal friendship or financial or social relationship with the employee or in violation of Bordes Consulting’s Equal Employment Opportunity Policy. In addition, we will not give preferential treatment to third parties or independent contractors based on personal or other relationships.
  • Freedom from Harassment:
    We will create an environment that is free from harassment based on race, color, religion, national origin, citizenship, age, sex, veteran status, marital status, disability, or any other characteristic. We will not tolerate any conduct that constitutes or could lead or contribute to such harassment, toward or by our employees, contractors, clients or vendors.
  • Non-Violent Work Environment:
    We will strive to ensure a safe and secure work environment, free from violence. We will not tolerate threats (whether implicit or explicit), intimidation, aggressive behavior or violence. We will not allow weapons or explosives of any kind in our workplace.
  • Safe Workplace: We will strive to maintain a safe workplace. We will keep ourselves aware of safety issues and policies that affect our work. We will advise Bordes Consulting promptly of any workplace injury or any dangerous situation so that it can be addressed.
  • Addressing Substance Abuse:
    We will maintain a productive workplace in which we forbid the abuse of alcohol and the use, possession or sale of illegal drugs.

Protecting Information

We make the following commitments:

  • Employee Information:
    We value and will protect the privacy and confidentiality of employee personnel and medical records and Personally Identifiable Information, such as social security numbers and birthdates. We will not share or discuss such records or information outside Bordes Consulting, except as authorized by the employee or as required by law, rule, regulation, subpoena, or order issued by a court of competent jurisdiction, or as requested by a judicial, administrative or legislative body.
  • Client Information:
    We will endeavor to maintain the confidentiality of client information and to use it appropriately. We will endeavor to safeguard any confidential or Personally Identifiable Information that our clients share with us.
  • Confidential and Proprietary Information:
    We will protect Bordes Consulting’s confidential and proprietary information and will not communicate it to anyone who is not authorized by Bordes Consulting to see it, including family members. This information could include, but is not limited to, unannounced products or services, sales data, client lists, confidential client information, nonpublic financial information, and significant projects, including proposed acquisitions and divestitures. We will endeavor to maintain the confidentiality of Bordes Consulting’s confidential and proprietary information both while working for Bordes Consulting and indefinitely after ceasing employment with Bordes Consulting. We will not use Bordes Consulting’s confidential and proprietary information for our own benefit or the benefit of any party other than Bordes Consulting, either during or after our employment.
  • Information Security:
    We will take all measures requested by Bordes Consulting to secure the information in our custody whether in paper or electronic format. We will secure our computers, handheld devices, and other equipment issued by Bordes Consulting or used for Bordes Consulting business with passwords or other means. We will not share our passwords with others. We will immediately report any potential breach of security or loss of data to our Compliance and Information Technology departments. We will not attempt to destroy, circumvent, compromise or subvert Bordes Consulting systems, security measures or audit measures. We will not access, remove or destroy files, data or systems without authority to do so.

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