The facts and circumstances surrounding Code violations determine the consequences, up to and including termination of employment.
Compliance with and adherence to the Code is everyone’s responsibility. Therefore, if a Covered Person knows of, or reasonably believes there is a violation of this Code, they must report that information immediately to the General Counsel or the Chief Compliance Officer. The Covered Person should not conduct preliminary investigations unless authorized to do so by the General Counsel or the Chief Compliance Officer.
Anyone who in good faith raises an issue regarding a possible violation of law, regulation or company policy or any suspected illegal or unethical behavior will be protected from retaliation. If you, the Covered Person, have violated the Code, however, making a report will not protect you from the consequences of your actions. You can be subject to discipline up to and including termination of employment if you violate the Code or fail to report violations that come to your attention.
Contact the General Counsel or Chief Compliance Officer directly. If a Covered Person does not feel comfortable making direct contact to report a violation, or potential violation, they may use the process detailed in the Confidential Reporting Guide.
No Code can address all specific situations. Accordingly, each Covered Person is responsible for applying the principles set forth in this Code in a responsible fashion and with the exercise of good judgement and common sense. Whenever uncertainty arises, a Covered Person should seek guidance from an appropriate supervisors, a representative from Human Resources, the General Counsel or Chief Compliance Officer before proceeding.
All Covered Persons should promptly report any practices or actions the Covered Person believes to be inappropriate or inconsistent with any provisions of the Code. In addition, all Covered Persons must promptly report any actual violations of the Code to the General Counsel or Chief Compliance Officer directly or through the process detailed in the Confidential Reporting Guide. Any person reporting a violation in good faith will be protected against reprisals.
If you feel uncomfortable utilizing the formal channels, issues may be brought to the attention of the Chief Executive Officer or the U.S. Chief Executive Officer.
Nothing herein, or in any contractual confidentiality provision to which any Covered Person is subject, prohibits Covered Persons from reporting possible violations of law or regulation to any governmental agency or entity, or self-regulatory authority, or from making other disclosures that are protected under the whistleblower provisions of state or federal law or regulation.
Covered Persons do not need INX’s prior authorization to make any such reports or disclosures and are not required to notify INX that they have made such reports or disclosures.
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