To all employees of Forrester Research:
We all face choices in our jobs every day. The purpose of this Code of Business Conduct and Ethics (the “Code”) is to help you make the right choices – those that will help maintain the integrity and reputation of Forrester. The ethical standards that form the foundation of this Code have been in place at Forrester since it was founded, and this Code incorporates our existing employee policies, many of which already address the importance of honest and ethical business conduct.
Forrester expects honest and ethical conduct from all of its employees, officers, and directors. Good ethics are good business. Whether you work in research, sales, finance, marketing, technology, strategic growth or in an administrative or executive function, you should consider yourself a guardian of Forrester’s good name. The trust and respect of our clients, stockholders, co-workers, partners, and our communities are assets that cannot be purchased and can only be sustained through our continued vigilance.
This Code is intended to enlist your help in continuing to foster a culture of integrity and accountability here at Forrester.
George F. Colony
Chairman and Chief Executive Officer
Forrester Research, Inc. (“Forrester” or the “Company”) is committed to operating its business ethically and with integrity, and in compliance with all applicable laws and regulations. Dealing honestly and fairly with others and doing our best to make the right choices will help us achieve our business goals and maintain a great working environment. This Code of Business Conduct and Ethics (the “Code”) has two primary purposes: 1) to help all of us maintain Forrester’s values and high standards of conduct and 2) to encourage the reporting of ethical or legal issues, questionable practices, and irregularities to management. Achieving both of these goals is critical to the Company’s success.
Forrester values integrity, honesty, fairness, and ethics as the cornerstones of all employee behavior. By keeping these values in sight as we conduct every aspect of our business, we will pursue only those business opportunities that support these values; treat others as we would like to be treated; and promote relationships and partnerships that withstand the highest public scrutiny and ethical review.
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I. Code of Business Conduct and Ethics
A. General. This Code reflects values already embodied in Forrester’s Integrity, Employee Confidentiality, and Insider Trading policies, as well as other Company policies listed below. Because we cannot address every difficult situation that you might come upon, it is important to use common sense and good judgment – and when in doubt, ask. Any person who has any questions about this Code should contact Forrester’s Chief Legal Officer or the Chief People Officer.
Also, it is an essential part of this Code that you have confidential and effective ways for reporting violations of laws, regulations, or Forrester policies when you become aware of them. These options are described in the Assistance and Compliance section below.
Engaging in the types of activities prohibited by this Code constitutes a serious offense and may subject employees to disciplinary action, up to and including termination.
B. Integrity and Conflicts of Interest. A conflict of interest arises when an individual’s personal interest (financial or otherwise) has the potential to interfere with or influence that individual’s judgment and decision-making in conducting business at Forrester. All of us need to use good judgment, adhere to high ethical standards, and avoid situations that create an actual or potential conflict, or even the appearance of a conflict, between personal interests and the interests of our business. Our Integrity Policy sets forth behavioral guidelines for addressing conflicts of interest specific to our research business, and this Code elaborates on some of the more common conflicts that may arise.
||Business Gifts and Entertainment. Forrester recognizes that in some instances, gifts and entertainment can provide an appropriate means of furthering a business relationship. Normal business courtesies involving no more than ordinary amenities, such as lunch, dinner, a spectator event, or a golf game, are permitted, as are token non-cash gifts of nominal value. The guiding principle is that no gift, favor or entertainment should be accepted or provided if it will exert undue influence on the recipient. In addition to these guidelines, our Integrity Policy prohibits Forrester analysts from accepting vendor or client gifts valued at greater that $100.|