Code of Business Conduct

Last Updated: June 1, 2018

The Response Code of Conduct is one of the ways we put Response’s values into practice. It’s built around the recognition that everything we do in connection with our work at Response will be, and should be, measured against the highest possible standards of ethical business conduct. We set the bar high for practical as well as aspirational reasons: Our commitment to the highest standards helps us to build great products and services and a customer experience that supports our motto: “The customer is the greatest asset.”

Please read the Code and Response’s values, and follow both in spirit and letter, always bearing in mind that each of us has a personal responsibility to incorporate and to encourage other employees and contractors to integrate the principles of the Code and values into our work. And if you have a question or ever think that one of your fellow colleagues or the company as a whole may be falling short of our commitment, don’t be silent. We want – and need – to hear from you.

I. Who Must Follow Our Code?

We expect all of our employees and contractors to know and follow the Code. Failure to do so may result in disciplinary action, including termination of employment. Moreover, while the Code is written explicitly for Response employees and contractors, we expect consultants, vendors, and others who may be temporarily assigned to perform work services for Response to follow the Code in connection with their work for us. Failure of a Response contractor, consultant, or other covered service providers to follow the Code can result in termination of their relationship with Response.

II. What If I Have a Code-Related Question or Concern?

If you have a question or concern, don’t just sit there. You can contact your manager, your Human Resources representative, or Legal.

III. No Retaliation

Response prohibits retaliation against any worker at Response who reports or participates in an investigation of a possible violation of our Code, policies or the law. If you believe you are being retaliated against, please contact Human Resources or Legal.

IV. How We Treat Our Customers – “The Customer Is the Greatest Asset”

Our customers value Response not only because we deliver great products and services, but because we hold ourselves to a higher standard in how we treat and value customers. Keeping the following principles in mind will help us maintain that high standard:

  • Integrity & Trust
    Our reputation as a company that our customers can trust is critical to our success. Every interaction, whether it be an advertisement, a sales presentation, a service call, or any other interaction with our customers should increase their trust in us.
  • Honesty & Clarity in Marketing, Sales, and Service
    Our advertisements, marketing and sales presentations, and other offers should be clear, honest, and complete so that our customers understand the exact nature of what is being offered. The price, the terms of payment, and the commitment involved with providing their information to us or purchasing from us must be clear. Before presenting any marketing, sales, or training material, we must be prepared to substantiate any claims we make. We should accurately communicate the risks and effort required, and not overstate or misrepresent earnings potential, effort required, or that a specific result is guaranteed or risk-free. Response customers should never be unpleasantly surprised.
  • Usefulness of Services
    Our products, features, and services are developed to be useful to our customers. We have many different types of customers from all different backgrounds and with different experience and skill sets. Regardless of their differences, however, the guiding principle is to only promote what will be useful for each customer.
  • Privacy & Security
    Always remember we are asking customers to trust us with their personal information. Preserving that trust requires that each of us respect and protect the privacy and security of that information. Our security procedures strictly limit access to and use of users’ personal information and require that each of us take measures to protect user data from unauthorized access. We must know our responsibilities under these procedures, and collect, use, and access customer personal information only as authorized by our Security Policies, Privacy Policies, and applicable data protection laws.
  • Responsiveness
    Part of being useful and honest is being responsive: We recognize relevant customer feedback when we see it, and we do something about it. We take pride in responding to communications from customers, whether questions, problems, or compliments. If something is broken, we figure out the cause, and we work until its fixed.
  • Take Action
    Any time you feel our customers aren’t being well-served, don’t be bashful – let someone in the company know about it. Continually improving our products and services takes all of us, and we’re proud that Response staff cares about our customers and take the initiative to step forward when the interests of our customers are at stake.

V. Avoid Conflicts of Interest

When you are in a situation in which competing loyalties could cause you to pursue a personal benefit for you, your friends, or your family at the expense of Response or our customers, you may be faced with a conflict of interest. All of us should avoid conflicts of interest and circumstances that reasonably present the appearance of a conflict.

When considering a course of action, ask yourself whether the action you’re considering could create an incentive for you. Could it also appear to others to create an incentive for you? Could it benefit yourself, your friends or family, or an associated business at the expense of Response? If the answer is “yes,” the action you’re considering is likely to create a conflict of interest situation, and you should avoid it.

Below, we provide guidance in four areas where conflicts of interest often arise:

  • Personal Investments
  • Outside employment, advisory roles, and starting or running your own business
  • Business opportunities found through work
  • Accepting gifts, entertainment, and other business courtesies

In each of these situations, the rule is the same – if you are considering entering into a business situation that creates a conflict of interest, don’t. If you are in a business situation that may create a conflict of interest, or the appearance of a conflict of interest, review the situation with your manager and Legal. Finally, it’s important to understand that as circumstances change, a position that previously didn’t present a conflict of interest may present one.

VI. Conclusion

Response aspires to be a different kind of company and a standard to not just others in the same industries, but any company the customer does business with. It’s impossible to spell out every possible ethical scenario we might face. Instead, we rely on one another’s reasonable judgment to uphold a high standard of integrity for ourselves and our company. We expect all Response employees and contractors to be guided by both the letter and the spirit of this Code. Sometimes, identifying the right thing to do isn’t an easy call. If you aren’t sure, don’t be afraid to ask questions of your manager, Human Resources, or Legal.