Protection of Corporate Information
Corporate Information
Ryan Specialty’s business is confidential, as is the business of our Clients and Trading Partners. Therefore, Ryan Specialty expects Employees to not discuss the business of Ryan Specialty or Clients and Trading Partners with third parties, except when it is necessary to perform their jobs and in a manner that protects confidentiality. Ryan Specialty is committed to handling all confidential information in a manner that is compliant with all applicable data and privacy laws and Ryan Specialty contractual obligations.
Trade Secrets and Confidential Information
Employees may be exposed to, or provided with, trade secrets and other confidential and proprietary information relating to Ryan Specialty’s business and that of its clients, consumers, and Trading Partners. All trade secrets or confidential information developed, created or maintained by Employees remains the sole property of Ryan Specialty. Any unauthorized use, disclosure, or transmission of trade secrets or confidential information, purposeful or inadvertent, to a third party will not be tolerated and could be illegal and result in civil or criminal penalties. This includes copying or removing such information from Ryan Specialty systems to any personal systems or for any personal use.
If you have reason to believe that confidential information has been misappropriated or improperly used or disclosed by an Employee, Trading Partner, or another individual, you must report the suspected disclosure or misuse immediately.
Ryan Specialty’s Assets
Employees should protect the Company’s assets and ensure their efficient use. Theft, carelessness and waste have a direct impact on the Company’s profitability and are prohibited. All Company assets should be used only for legitimate business purposes. Any suspected incident of fraud or theft should be reported for investigation immediately.
Company Records
Ryan Specialty requires Employees to ensure that applicable laws and regulations and Ryan Specialty’s Policies are abided by when keeping or maintaining Ryan Specialty records. If there is any hesitation as to the veracity of a record or the timeframe for keeping a specific record, please do not hesitate to contact your manager or the Ryan Specialty Regulatory & Compliance Department.
Government Investigations
You may, in the course of business, be contacted by federal, state, local regulatory or governmental authorities, or the equivalent, or be served with a subpoena. Ryan Specialty expects you to cooperate with all government agents, but also expects you to promptly inform Ryan Specialty about any such occurrence. Until you have received guidance from an appropriate Ryan Specialty manager, you should avoid answering any questions, providing documentation, or permitting a search of any Ryan Specialty premises, if possible. This will ensure that legal rights are preserved and that responses are accurate, timely, and appropriate.
Ryan Specialty prohibits retaliation against any Employees who, in good faith, initiates or participates in an investigation relating to a violation of law conducted by any local, federal, or international agency, as well as any court or other tribunal.
Books and Records
Employees and any Trading Partners who conduct business on Ryan Specialty’s behalf must accurately reflect all transactions in Ryan Specialty’s books and records in compliance with applicable laws and regulations. To that end, Ryan Specialty requires books, records, accounts, and financial statements to be maintained in detail and to fully and accurately reflect all transactions.
Various laws and regulations govern the retention and destruction of records and, additionally, Ryan Specialty may have contractual obligations relating to record retention.
Ryan Specialty requires Employees to ensure that applicable laws and regulations and Ryan Specialty’s Policies are abided by when keeping or maintaining Ryan Specialty records. If there is any hesitation as to the veracity of a record or the timeframe for keeping a specific record, please do not hesitate to contact your manager or the Ryan Specialty Regulatory & Compliance Department.
Keep Confidential Information Safe and Secure
In the course of our work, many of us have access to confidential, proprietary, and/or sensitive information about Ryan Specialty, employees, and customers. We must strive to keep such confidential information secure and limit access only to those that need to access such information.
Confidential information may not be used for personal benefit and should only be disclosed for legitimate business purposes.
Electronic Communications
All Ryan Specialty-owned computers, databases, and personal computers used for Ryan Specialty business, e-mail and voice mail systems, and internet access via Ryan Specialty computers or data lines, are intended to be used to assist Employees in their job duties. Ryan Specialty expressly forbids use of these systems in a way that violates Ryan Specialty’s Code or Policies. This prohibition also applies to personal computers and devices used for Ryan Specialty business, whether or not they are connected with Ryan Specialty’s network on a regular or intermittent basis. The copying or use of unlicensed or pirated software on computers and other equipment is strictly prohibited.
Social Media, Social Networking, and Blogs
Although Ryan Specialty respects Employees’ rights to personal social media use, remember that some social media interactions can have unforeseen, negative implications for business operations, including, but not limited to, Ryan Specialty’s relationships with Clients and Trading Partners, and may create legal liabilities for Ryan Specialty. When using social media, Ryan Specialty expects all Employees to protect confidential information related to Ryan Specialty’s operations and to safeguard Ryan Specialty’s property. Nothing in Ryan Specialty’s Code is intended to limit or restrict the right to discuss the terms and conditions of employment, but it does prohibit the unauthorized disclosure of Ryan Specialty, Employee, Client, Trading Partner, or others’ confidential business or personnel information.
Ryan Specialty expressly prohibits any unlawful discrimination, harassment, and retaliation while using social media or Ryan Specialty’s computers, telephone systems, e-mail, or other electronic communications systems, or otherwise. Furthermore, Employees should be aware that Ryan Specialty monitors the use of its computers, telephone systems, and other electronic and communication systems owned or provided by Ryan Specialty, and that Employees have no right to an expectation of privacy while using such equipment and systems.
Social Media
Social Media is an important way for us to conduct work related communication and share information with others. When using social media on behalf of Ryan Specialty, follow the same standards of professionalism used in traditional forms of written communication.
We should always be clear and transparent in our public communications and follow social media best practices.
Best Practices When Engaging in Social Media
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Respect the privacy of employees, Clients, and Trading Partners.
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If you, as a private individual, participate in online forums, blogs, newsgroups, chat rooms, bulletin boards or other social media such as Facebook and Twitter, remember that you are not to speak on behalf of Ryan Specialty nor give the impression that you are speaking on behalf of Ryan Specialty.
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Ask yourself, “Am I saying the right thing as a Ryan Specialty employee — even when I am using my personal account?”
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Never send or post confidential business information.
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Don’t send or post information that could damage Ryan Specialty’s or a Trading Partner’s reputation.
News Media Inquiries
The Company is subject to compliance with Regulation Fair Disclosure (“Regulation FD”). Regulation FD prohibits the selective disclosure of material nonpublic information. Regulation FD is intended to eliminate situations where the Company may disclose important nonpublic information to certain persons before disclosing the information to the general public. Regulation FD requires that, whenever the Company (or a person acting on its behalf) intentionally discloses material nonpublic information to an Enumerated Person (as defined in our Regulation FD Policy, including broker-dealers, analysts and securityholders), the Company must simultaneously disseminate the information to the public. Subject to limited exceptions, the Company strictly prohibits the selective disclosure of material nonpublic information by the Company or any person acting on the Company’s behalf to Enumerated Persons. As such, Ryan Specialty Employees are prohibited from speaking with the media on Ryan Specialty’s behalf or on Ryan Specialty matters without approval from the Chief Marketing and Communications Officer and in compliance with our Regulation FD Policy. All media inquiries seeking comments on behalf of Ryan Specialty must be directed to the Chief Marketing and Communications Officer. Potential unintentional disclosure of material non- public information during the approved disclosures outlined above must be reported to the office of the General Counsel immediately. See our Regulation FD Policy for more information.