Compliance

For Partners (Analysts and Experts)


1.  Upon joining CASSANDRA and periodically thereafter, Partners are required to make prescribed compliance declarations and undertakings in line with CASSANDRA’s compliance framework, which include the following:

1.1.  The Partner is not prohibited or limited in any way from participating in CASSANDRA (a freelancer network).

1.2.  The Partner will not participate in any engagement that violates any law or regulation, or gives rise to any conflict or suspected conflict, and will discontinue an engagement if the Knowledge Partner determines or suspects a conflict.

1.3.  The Partner will not engage with a CASSANDRA client that competes with his or her current employer.

1.4.  The Partner will not disclose, use or attempt to benefit from any information related to an engagement.

1.5.  The Partner will not disclose any material non-public information (whether concerning a public company or any publicly-traded security or instrument, or otherwise).

1.6.  The Partner will not disclose confidential information including but not limited to: trade secrets, proprietary information, intellectual property, and other information that s/he has a duty to, or be reasonably expected to have a duty to, keep confidential, and will abide by all obligations to third parties, including obligations arising from non-disclosure agreements, severance agreements, and other applicable contractual agreements.

1.7.  The Partner will not carry out any regulated activities in the course of an engagement, nor give financial, legal, medical or other professional advice, and will not disclose any information protected under applicable professional standards and requirements.

1.8.  If a Partner is an officer or director of a company, s/he will not participate in an engagement when any sensitive transactions of such company are pending, including an IPO, merger, or tender offer, unless it can be established to a high degree of fidelity that the engagement is completely unrelated to such transactions.

1.9.  The Partner is required to and will make the prescribed compliance declarations and undertakings prior to each engagement.

1.10.  The Partner is required to ensure that s/he has reviewed all of his or her applicable employment agreements, company manuals, and codes of ethics to ensure that s/he can participate in an expert network before electing to be enrolled as a Partner.

1.11.  The Knowledge Partner is responsible for confirming his or her ability to participate on a specific engagement based on his or her detailed understanding of the subject of an engagement prior to the engagement.

2.   Information on Partners’ areas of conflict are stored systematically and regularly reviewed by employees of CASSANDRA responsible for matching clients with Partners.

3.  Partners are made aware that s/he can refuse to answer client questions and that s/he can report any such questioning that the Partner feels might be in violation of any ethical, legal, regulatory, and contractual obligations or constraints the Partner may have.

4.  CASSANDRA may perform some level of background check on Partners, such as: identity verification, fact-checking of their background as represented on their CVs, profiles or resumes; confirmation that the Partner has not previously committed a securities, criminal or other regulatory violation; or is not the subject of any ongoing litigation.

For Employers


1.  At CASSANDRA, we recognise that employees of companies should be treated differently from independent consultants. All Partners are made to declare that s/he is not prohibited under any contractual or legal obligation from participating as a Partner with CASSANDRA.

2.  Partners are allowed to participate in projects about their current employer, but are prohibited from disclosing any confidential information or material non-public information. In addition, Partners mandatorily undertake to abide by all non-disclosure agreements, employment agreements and other applicable contractual agreements. Partners are also not permitted to participate in projects with their current employer's competitors.

3.  CASSANDRA strives to, where necessary, reach out to companies and to review publicly available corporate policies to find out if they have policies against the engagements offered at CASSANDRA.

4.  CASSANDRA allows organisations to inform us about restrictions or guidelines concerning consulting-related activities by any of their professionals or employees, including those employed by their subsidiaries. CASSANDRA can immediately and comprehensively enforce organisations’ policies prohibiting or limiting external consulting-related activities to any of their employees currently involved with CASSANDRA, or those who apply for entry in the future.

5.  If you’re an employer and want to inform us of any policies you have regarding external consulting-related activities, please feel free to do so by emailing us at compliance@cassandra.global.

For Clients


1.  CASSANDRA’s clients are required to be as specific as possible when outlining requests for Partners. Generalised requests are more likely to lead to non-compliant engagements with Partners.

2.  CASSANDRA allows clients to implement internal policies, such as to permit or restrict access to certain Partners.

3.  CASSANDRA clients are allowed to add their own specific screening questions for potential Partners (supplementing those that are standard for the network).

4.  CASSANDRA’s clients’ compliance officers are allowed to blacklist Partners based on place and status of employment.

5.  CASSANDRA’s clients must not engage in any conduct that will result in abetting or aiding the breach of a Partner’s compliance undertakings or other legal obligations, including but not limited to asking for confidential information, proprietary and intellectual property-related information, trade secrets, and material non-public information.

6.  CASSANDRA’s clients must acknowledge that a Partner can refuse to answer a CASSANDRA’s client’s questions and to report any such questioning that the Partner feel might be in violation of any ethical, legal, regulatory, and contractual obligations or constraints s/he may have.

7.  For further clarifications, feel free to email us at compliance@cassandra.global.

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