Conflict of Interest Guidelines

It is the policy of Forrester ("Company") to conduct its affairs in strict compliance with the letter and spirit of the law and to adhere to the highest principles of business ethics. Accordingly, all officers, employees and independent contractors must avoid activities which are in conflict, or give the appearance of being in conflict, with these principles and with the interests of the Company. The following are potentially compromising or harmful situations which must be avoided. Any exceptions must be reported to the President and written approval for continuation must be obtained.

1. Confidential Information.

Revealing confidential information to outsiders or misusing confidential information. Unauthorized divulging of information is a violation of this policy whether or not for personal gain and whether or not harm to the Company is intended.

2. Gifts. 

Accepting or offering substantial gifts, excessive entertainment, favors or payments which may be deemed to constitute undue influence or otherwise be improper or embarrassing to the Company.

3. Civic or Professional Organizations.

Participating in civic or professional organizations that might involve divulging confidential information of the Company.

4. Personal Relationships.

Initiating or approving personnel actions affecting reward or punishment of employees or applicants where there is a family relationship or is or appears to be a personal or social involvement.

5. Harassment.

Initiating or approving any form of personal, sexual, or social harassment of employees, customers, suppliers or anyone else.

6. Outside Investment or Involvement. 

Investing or holding an ownership interest or outside directorship in suppliers, customers, or competing companies, including financial speculations, where such investment or directorship might influence in any manner a decision or course of action of the Company.

7. Borrowing and Lending. 

Borrowing from or lending to employees, customers or suppliers.

8. Real Estate. 

Acquiring real estate of interest to the Company.

9. Other Information.

Improperly using or disclosing to the Company any proprietary information or trade secrets of any former or concurrent employer or other person or entity with whom obligations of confidentiality exist.

10. Competitors.

Unlawfully discussing prices, costs, customers, sales or markets with competing companies or their employees.

11. Illegal Agreements. 

Making any unlawful agreement with distributors, competitors or customers with respect to prices, territories, or products.

12. Company Property. 

Improperly using or authorizing the use of any property of the Company or any other thing or property that is owned by person or entity.

13. General Conduct.

Engaging in any conduct which is not in the best interest of the Company.

14. Foreign Payments. 

Making any unlawful agreement with or payment to any domestic or foreign government official or corporate representative.

Each officer, employee and independent contractor must take every necessary action to ensure compliance with these guidelines and to bring problem areas to the attention of higher management for review. Violations of this conflict of interest policy may result in discharge without warning.