{
  "$schema": "https://clarusclm.com/schemas/policy-rollout/v1.json",
  "template_id": "code-of-conduct",
  "version": {
    "body_text": "CODE OF CONDUCT\n\n1. CORE VALUES\nThe company expects every employee, contractor, and representative to act with integrity, honesty, and professional respect. The Code of Conduct applies to internal interactions and to engagements with customers, vendors, partners, and the public.\n\n2. PROHIBITED CONDUCT\nProhibited conduct includes: harassment or discrimination, theft or misappropriation of company or customer property, falsification of records, bribery or kickbacks, insider trading on material non-public information, knowingly false statements to auditors or regulators, and unauthorized disclosure of confidential information.\n\n3. CONFLICTS OF INTEREST\nEmployees disclose any actual or perceived conflict of interest to their manager and to People at the time the potential conflict arises. Examples include: outside employment with a customer, partner, or competitor; financial interest in a vendor or competitor; family or romantic relationship within reporting chain; serving on the board of a competitor or vendor.\n\n4. GIFTS AND ENTERTAINMENT\nGifts to or from customers, vendors, or partners are limited to nominal value (under $100). Cash gifts are never accepted. Government officials are subject to stricter rules; consult the Anti-Bribery and Anti-Corruption policy.\n\n5. INTELLECTUAL PROPERTY\nAll work product created in the course of employment is the company's property. Use of company time or resources for personal projects requires written approval. Use of customer data for personal benefit is grounds for immediate termination.\n\n6. SOCIAL MEDIA\nEmployees may identify their employer on personal social media but may not speak on behalf of the company without authorization. Confidential information, customer information, and forward-looking financial statements are never shared.\n\n7. REPORTING VIOLATIONS\nViolations are reported through the channels in the Anti-Harassment policy: any manager, People, the anonymous compliance hotline, or the General Counsel. Good-faith reports are protected from retaliation.\n\n8. DISCIPLINE\nViolations may result in discipline up to and including termination, and may be reported to law enforcement when warranted.",
    "change_summary": "Initial 2026 code of conduct."
  },
  "rollout": {
    "audience": {
      "jurisdiction_codes": [],
      "department_ids": [],
      "employee_group_scope": "all"
    },
    "mandatory": true,
    "acknowledgment_required": true,
    "comprehension_check": {
      "enabled": true,
      "questions": [
        {
          "prompt": "An employee may identify their employer on personal social media but may not speak on behalf of the company without authorization.",
          "answer_type": "single_choice",
          "options": ["True", "False"],
          "expected_index": 0
        },
        {
          "prompt": "Cash gifts from customers may be accepted as long as they are under $100.",
          "answer_type": "single_choice",
          "options": ["True", "False"],
          "expected_index": 1
        },
        {
          "prompt": "When must an actual or perceived conflict of interest be disclosed?",
          "answer_type": "single_choice",
          "options": ["At the next annual review", "When a manager asks", "When the potential conflict arises", "Only if the conflict materializes"],
          "expected_index": 2
        }
      ]
    },
    "ai_classification_hints": {
      "summary": "Core values, prohibited conduct, conflict of interest disclosure rules, gift and entertainment limits, IP assignment, social media guidance, reporting channels, and discipline framework.",
      "regulatory_citations": [
        "SOC 2 CC1.1 (commitment to integrity and ethical values)",
        "ISO 27001 A.7.1.2 (terms and conditions of employment)",
        "Foreign Corrupt Practices Act (FCPA)",
        "UK Bribery Act 2010"
      ],
      "key_terms": ["conflict of interest", "intellectual property", "gift limits", "social media", "anonymous reporting"],
      "manager_briefing": "Disclose your own conflicts before asking employees to disclose theirs. Document gift acceptance even when under the limit. Route any government-official engagement to General Counsel. Treat the social media rule as guidance to teach, not a rule to police.",
      "exception_examples": ["industry award accepted on company behalf", "speaker honorarium with prior approval", "wedding gift from long-term colleague"]
    }
  }
}