CENTRA Code of Business Conduct & Ethics
CENTRA's Code of Business Conduct & Ethics outlines the company's core principles and standards for ethical, legal, and responsible conduct.
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SUMMARY
This document establishes CENTRA's standards for ethical and lawful conduct, applying to all employees, officers, directors, contractors, consultants, agents, and authorized representatives. It opens with CENTRA's mission as a neutral interconnection provider and the five guiding principles that anchor the Code: integrity, accountability, security, neutrality, and compliance.
The bulk of the document addresses specific compliance areas, including anti-bribery and anti-corruption, trade compliance and sanctions, conflicts of interest, gifts and business courtesies, and fair competition. It also covers the responsible use of company assets, protection of confidential information and intellectual property, handling of material non-public information, and data privacy practices for customer and personal data.
A significant section is dedicated to information security responsibilities, including a subsection on responsible use of AI tools in business workflows. The Code also sets expectations around accurate recordkeeping, business communications, and a respectful, harassment-free workplace, plus commitments to human rights, health and safety, and environmental responsibility.
It closes with the practical mechanics of the program: how to raise a concern, the non-retaliation policy, how investigations are conducted, the range of disciplinary consequences for violations, and how acknowledgments, training, and waivers are managed.