Fy23 Cintas Codeofconduct Booklet Eng
Fy23 Cintas Codeofconduct Booklet Eng
Fy23 Cintas Codeofconduct Booklet Eng
The Code of Conduct and Business Ethics that follows is one of Cintas’ core corporate
policies and details how we expect our partners to work and operate while representing us.
Cintas has a reputation as a company that operates with strong moral principles and
excellent values. This is a product of our collective efforts, and we’re all responsible for
our actions and our commitment to good business.
“In our business, we face new challenges every I ask that all of our partners not only help us maintain our reputation, but also
help us grow it.
day, and I count on all of our partners to Thank you for joining me in our Company’s commitment to conducting business with
personify our moral and ethical standards ethical principles.
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Policy Resolution Process
Cintas Corporation and its directors, officers and partners have committed to conduct Cintas’ In most situations, our values and integrity will guide us to the right decision. However,
business around the world in accordance with the highest ethical standards. We know it’s not we must always keep in mind how our actions affect the credibility of our organization as
enough to just do the right things; we have to do them in the right way. The way that we a whole, and for this reason, our business ethics must reflect the values and standards of
accomplish our work is as important as the work itself. It is essential that we conduct ourselves conduct outlined in this Code.
at all times with integrity and in full compliance with the laws and
regulations that govern our business activities. Ethics are not always black and white issues. Sometimes they are obvious. For example,
stealing and cheating are obvious violations. But other issues are not so obvious and
This Code applies to Cintas Corporation, its subsidiaries or affiliates around the world in which require additional judgment. Whenever you are confronted with an issue or business
Cintas directly or indirectly owns more than 50 percent of the voting control (“Controlled decision that is not as clear cut, ask yourself these questions for guidance:
Affiliates”), and to all directors, officers, and partners of each. All references to “Cintas” or the
“Company” include Cintas Corporation and all Controlled Affiliates unless otherwise specified. • Will this action endanger anyone’s life, health or safety?
All references to directors, officers and partners include directors, officers, and partners of • Is it legal?
Cintas Corporation and its subsidiaries and Controlled Affiliates. • Will I be violating either a law or a company policy?
• Is it honest in every respect?
Failure to read and/or acknowledge this Code does not exempt a director, officer or • How will my actions make me feel about myself? Will it make me proud or ashamed?
partner from his or her responsibility to comply with this Code, applicable laws, • How will I feel if my actions were disclosed to the media?
regulations and all Cintas policies and guidelines that are related to his or her job • How will I feel if my family knows about it
and/or duties.
If you are still not sure how to proceed after considering these questions or wish to report
This Code is an important part of Cintas’ values and reflects our commitment to ethical questionable behavior and/or a possible violation, you should promptly:
business practices and regulatory compliance. It summarizes the principles and policies that
guide our business activities. This Code is not meant to replace our detailed policies; • Try to resolve the concern through the standard management channels or your human
it enhances our current policies and is a statement of our principles in a number of resource representative.
important areas. • If you are a partner covered by a labor agreement and a local grievance process covers
the issue you are concerned about, you should follow that process.
Each Cintas director, officer and partner is responsible for fully understanding and complying
with the standards of conduct outlined in this Code, applicable government laws, rules and If resolution through standard management channels is not appropriate or you have
regulations of each country in which we work and Cintas’ policies. This Code is not already taken these steps and the issue was not adequately resolved, you may contact the
intended to cover every applicable law or provide answers to all questions that might arise. confidential Cintas Direct Line. The Cintas Direct Line may be accessed through several
Rather, it provides you with some guidelines for meeting ethical and legal methods, including a dedicated, toll-free phone line, an online solution at directline.
obligations and where to go for additional information and partnership. cintas.com, or through a texting service available in North America. The Cintas Direct
Line is available 24 hours a day, 7 days a week, 365 days a year. The Cintas Direct Line is
This Code is not intended to and does not create an employment contract, and does not create operated by an external third-party vendor that has trained multi-lingual professionals to
any contractual rights between Cintas and its partners or create any express or implied take your calls, in confidence, and report your concerns to the appropriate Cintas manager
promise for specific treatment in specific situations. This Code does not limit the obligation for appropriate action. If you wish, you may contact the Direct Line anonymously.
of any partner under existing non-compete, non-disclosure or other employment related
agreements to which the partner is bound or the Company’s policies which Direct Line Phone Numbers Direct Line Website
cover the partner. U.S. and Canada: (800) 461-9330 http://directline.cintas.com
Mexico: (800) 681-6945
RESPONSIBLE OFFICE: Vice President of ESG & Chief Compliance Officer Honduras (all carriers): (504) 2231-3114 Text the Direct Line
Tigo (mobile): (800) 2791-9500 (513) 987-9436
Hondutel (fixed access): (800) 2791-9500 (available in North America only)
For more information refer to Corporate Policy #C-21 (Global), Partner Complaint Policy,
its approved local equivalent or authorized rules addressing this topic.
* Available in North American only.
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Employment Practices and Expectations. Cintas treats all its partners with dignity and
No Retaliation respect. We provide pay and benefits competitive within our industry and the labor markets
in which we operate and consistent with individual performance. A diverse workforce
is essential to our business success. All partners are expected to respect and value the
Cintas will handle all inquiries discreetly and make every effort to maintain, within the
contributions that people of different characteristics, experiences and backgrounds offer.
limits allowed by the law, the confidentiality of anyone requesting guidance or reporting
Cintas promotes a cooperative and productive work environment by supporting the
questionable behavior and/or a possible violation. It is Company policy to ensure that no
diversity of its workforce and is committed to providing equal employment opportunity
retaliation occurs as a result of any partner raising a business conduct or ethical issue or
to all qualified partners and applicants. (For more information, refer to Corporate
reporting a perceived violation of Company policy or the law.
Compliance Policy #C-205, Labor and Employment, its approved local equivalent or
authorized rules addressing this topic.)
Standard of Business Conduct We do not discriminate on any basis, including, but not limited to, race, color, gender,
sexual orientation, religion, national origin, marital status, age, disability or veteran status,
in any personnel practice, including recruitment, hiring, training, promotion, and discipline.
We are committed to interacting with our customers, working employee-partners, Employment decisions are made based on the following criteria: (a) qualifications of
competitors, co-workers, shareholders, vendors, government and regulatory agencies, candidates with respect to job requirements; (b) development needs of individuals and
and the communities in which we operate around the world in a respectful, ethical manner the Company’s succession planning requirements; (c) equal opportunity and achieving
and in full compliance with all regulatory and legal requirements. work-force diversity; and (d) legal and contractual requirements. (For more information,
refer to Corporate Policy #C-152, Hiring System, its approved local equivalent or
Compliance with Laws, Rules and Regulations. We strictly obey the laws and regulations authorized rules addressing this topic).
that govern our businesses in the countries in which we operate. We are responsible for
understanding these laws and regulations as they apply to our jobs and for preventing, Cintas does not tolerate harassment in any form, including, but not limited to, sexual
detecting, and reporting instances of non-compliance. Every partner must conduct harassment, verbal abuse, intimidating behavior, threats or assault. We take allegations
themselves at the Company and all of its functions or when acting on its behalf in a of harassment and unlawful discrimination seriously and address all such concerns that
manner which is in full compliance with all applicable laws, rules and regulations in the are raised regarding this policy. (For more information, refer to Corporate Policy #C-138
countries in which we operate as well as with all of Cintas’ policies. (Global), Workplace Harassment Prevention, its approved local equivalent or authorized
rules addressing this topic.)
Antitrust Laws. The antitrust laws of the United States and of other countries are
designed to preserve and protect competition in goods and services. Every partner must Safety, Health and Environment. A safe and clean work environment is important to the
comply with the antitrust and competition laws of the countries in which we do business. well-being of all Cintas partners. Cintas strives to comply with applicable safety and health
Any business activities involving any of our competitors should be conducted cautiously regulations and appropriate practices in countries we operate. Cintas strives to comply
and in a manner that does not violate these laws. Agreements between competitors with all environmental laws, regulations and policies in countries we operate in order to
relating to prices or allocations of territories or customers are unlawful. If you are involved be a responsible steward of natural resources. Partners who are responsible for, or are
in, have questions about or observe an activity that could raise an antitrust or competition engaged in, activities or operations that might affect the environment should be familiar
law issue, immediately contact your supervisor or call the Legal Department for advice. with the laws, regulations and policies in the countries we operate that relate to these
(For more information, refer to Corporate Compliance Policy #C-200, Antitrust activities and comply with them. (For more information, refer to Corporate Compliance
Compliance, its approved local equivalent or authorized rules addressing this topic.) Policy #C-206 (Global), Safety, their approved local equivalent or authorized rules
addressing this topic, The Cintas Safety Manual or your division specific safety policy.)
Anti-Corruption. The United States Foreign Corrupt Practices Act (FCPA) prohibits
making a payment or offering anything of value to a foreign government official or government Workplace Violence. Caring about the safety of our partners includes offering a workplace
agency to impact a decision to obtain, retain or influence business. Other countries in free from violence. Cintas does not tolerate threats, intimidation, aggressive behavior,
which Cintas conducts business have similar anticorruption laws. Improper activities are physical harm, or other violence of any kind. If you believe that your safety, or that of any
not limited to cash payments and can include suspicious business arrangements and other partner, is in jeopardy contact your supervisor, manager or HR representative
excessive or unnecessary travel, gifts, entertainment and meals. Cintas abides by applicable immediately. You may not have weapons, licensed with a government permit or not,
anticorruption laws of the United States and the countries in which we do business and of any kind on company property.
expects all directors, officers, partners, and third-party representatives, regardless of what
country they work in, to run their business in adherence with these regulations. (For more Drugs and Alcohol. Cintas maintains a work environment free of drugs and alcohol.
information, refer to Corporate Compliance Policy #C-208, Anticorruption Policy, its The use of drugs and alcohol on the job can endanger your life as well as the life of
approved local equivalent or authorized rules addressing this topic). others. The use, transfer, sale or possession of illegal drugs, alcohol or other controlled
substances at a Cintas location is prohibited. Consumption of alcohol is only authorized
as detailed in Corporate Policy #C-115, Drugs and Alcohol, its approved local equivalent
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or authorized rules addressing this topic. Subject to the local work rules and/or applicable
law, violation of this policy will result in disciplinary action up to, and including, termination. Confidentiality
(For more information, refer to Corporate Policy #C-115, Drugs and Alcohol, its approved
local equivalent or authorized rules addressing this topic.)
We are entrusted with confidential information concerning the company, its business
plans, personnel matters, new business efforts, customers, accounting, and financial
matters. Directors, officers, managers and partners shall maintain the confidentiality of all
Conflicts of Interest information entrusted to them by the Company, except when disclosure is authorized or
legally mandated. You should recognize that such information is the property of the
Company and only the Company may authorize its publication or use by others. Confidential
Cintas’ directors, officers and partners have an obligation to promote the best interests information includes, but is not limited to, all non-public information that might be used
of the Company at all times. You should avoid any action which may involve a conflict of by the Company’s competitors or harmful to the Company or its customers, if disclosed.
interest with the Company. Conflicts of interest can exist due to personal relationships, Some examples of confidential information that should be protected include, but are not
relationships with family, vendors, customers or friends, competing with or having interest limited to: sales and profit figures, partner personal information, marketing/strategy plans,
in a company that competes with Cintas, gifts and entertainment or any situation that can new product/service information, research and development ideas, and potential
be perceived as or create the appearance of a conflict of interest. Directors, officers, acquisitions or investments. (For more information, refer to Corporate Policy #C-42
managers and partners should not have any undisclosed, unapproved financial or other (Global), Proper Use of Email & Email Distribution Lists, Corporate Policy #C-43,
business relationships with suppliers, customers or competitors of a magnitude or nature Information Security and Corporate Compliance Policy #C-204 (Global), Information
that could impair the independence of any judgment they may need to make on behalf Systems, their approved local equivalent or authorized rules addressing this topic.)
of the Company.
Directors, officers, managers and partners must also avoid the appearance of conflicts of
interest, which occur where a reasonable observer might assume there is a conflict of
interest and, therefore, a loss of objectivity in their dealings on behalf of the Company. Fair Dealing
Where conflicts of interest arise, directors, officers, mangers and partners must provide
full disclosure of the circumstances and recuse him or herself from any related decision-
Cintas bases its relationships with customers, suppliers, competitors and partners on fair
making process. Directors and officers shall provide full disclosure to the Chairman of the
practices. Accordingly, all directors, officers, managers and partners of the Company
Company’s Audit Committee and the Vice President of ESG & Chief Compliance Officer,
should deal fairly with all customers, suppliers, competitors and partners of Cintas.
and all other partners shall provide full disclosure to their immediate supervisor.
No director, officer, manager or partner shall take unfair advantage of anyone through
manipulation, concealment, abuse of privileged information, misrepresentation of
material facts, or any other unfair dealing practice.
Gifts and Entertainment
We do not accept gifts or business favors. Normal business lunches are permitted. Dinners, Doing Business with the Government
entertainment and trips may only be accepted when they have a definite business
purpose and must first be approved by your officer. We do not want to do anything that
Often times, the rules for selling services to the government are stricter than the rules
would place us in a compromising position or cause us to lose our objectivity. We encourage
that apply to our commercial transactions. We abide by the requirements set forth for
professional relationships with our suppliers and expect our suppliers to understand,
government contracting for the countries in which we operate and strive to protect the
respect and cooperate with this policy. (For more information, refer to Corporate
trust in the relationship we’ve built.
Compliance Policy #C-208 (Global), Anticorruption Policy, its approved local equivalent
or authorized rules addressing this topic).
Social Responsibility
Corporate Opportunities
Cintas is committed to high standards of ethics on issues of social responsibility.
Cintas and its subsidiaries seek to conduct business in an ethical and moral manner in all
Directors, officers, managers and partners shall not take for themselves any business op-
countries in which we have the privilege to work. To achieve this purpose, we expect our
portunities that are discovered through the use of Company property, information or posi-
vendors to subscribe to certain moral and ethical principles in conducting business. While
tion, use the Company property, information or position for personal gain, or compete with
Cintas recognizes that there are different legal and cultural environments throughout the
the Company. All directors, officers, managers and partners owe a duty to the
world, our Vendor Code of Conduct sets forth the basic requirements all vendors must
Company to advance its legitimate business interests when the opportunity to do so arises
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meet in order to do business with us. We conduct periodic audit inspections of suppliers, only discuss this information on a limited, strict “need to know” basis internally, and you
their facilities and business practices to verify compliance with our standards and Vendor may not share it with anyone outside the Company. No partner may buy or sell the public
Code. (For more information, refer to Corporate Policy #C-15, Corporate Disclosure, securities of a company, including Cintas, if he or she has such information, and no partner
Corporate Policy #C-38 (Global), Corporate Accounting, their approved local equivalent shall share (“tip”) this information with others. Because of the extremely sensitive nature
or authorized rules addressing this topic, and our Vendor Code of Conduct). of and severe penalties associated with “insider trading” and “tipping,” contact Cintas’
Chief Financial Officer before you buy or sell public securities in situations that could be of
this nature. (For more information, refer to Corporate Policy #C-25 (Global), Insider Trading
Protection and Proper Use of the of Common Stock, its approved local equivalent or authorized rules addressing this topic.)
Company’s Assets
Corporate Compliance
All directors, officers, managers and partners must safeguard the Company’s property,
whether it is a piece of equipment, an electronic file or confidential information. All We maintain a compliance program to support the Company’s efforts to comply with
directors, officers, managers and partners should ensure that all Company property is applicable legal requirements of the United States and the countries in which we operate
used in an efficient manner and for legitimate business purposes. Theft, carelessness and to appropriately manage risk. We seek to prevent compliance issues from arising by
and waste impact the Company’s profitability and should be promptly reported. (For conducting ongoing risk assessments. This process leads to the creation and maintenance
more information, refer to Corporate Policy #C-43, Information Security and Corporate of compliance policies and procedures that clearly outline our expectations for how
Compliance Policy #C-204 (Global), Information Systems), their approved local equivalent our business should be conducted. Our communication of these policies, as with all our
or authorized rules addressing this topic. policies, helps raise awareness among our partners of critical areas of business risk and
the right ways to handle and manage these risks. We also provide training to support our
partners in performing their jobs in a compliant manner.
Full and Fair Disclosure In addition to the policies referenced throughout this Code, information can be found by
reading our Compliance Policies. These policies include, but are not limited to:
Cintas fully and fairly discloses the financial condition of the Company in compliance
• Antitrust
with applicable accounting principles, governmental laws, rules and regulations and the
• Anticorruption
rules of the Nasdaq Stock Market. All books and records of the Company shall be kept in
• Code of Conduct and Business Ethics
such a way as to fully and fairly reflect all Company transactions. All financial officers shall
• Crisis Management
communicate to our executive management and to the accountants engaged to conduct
• Environmental
an audit of our financial statements all relevant information, professional judgments or
• Financial and Disclosure Controls
opinions that relate to our financial statements.
• Labor and Employment
• Records Retention
Furthermore, senior financial officers of the Company, including the principal financial
• Safety
officer or persons performing similar functions, shall prepare full, fair, accurate, timely and
understandable disclosure reports and documents that Cintas files with or submits to the
Securities and Exchange Commission and in Cintas’ other public communications. (For
more information, refer to Corporate Policy #C-15, Corporate Disclosure and Corporate
Policy #C-38 (Global), Corporate Accounting, their approved local equivalent or
authorized rules addressing this topic.)
Insider Information
In the course of doing business for Cintas or in discussions with one of its customers,
vendors, or partners, you may become aware of material non-public information about the
Company or that organization. Information is considered “material” if it might be used by
an investor to make a decision to trade in the public securities of the Company.
Individuals who have access to this type of information are called “insiders.” You may
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Accountability and Adherence to the Code
All directors, officers, managers and partners are responsible for abiding by this Code.
Directors, officers, managers and partners who violate the Code are subject to disciplinary
action, up to and including termination.
All partners with access to the Cintas Talent Management System will complete the annual
online Code of Conduct and Business Ethics training on demand (TOD).
Hourly partners, production partners and non-management salaried partners who may
not have access to the TOD must be trained annually by their immediate supervisor and
review the Code of Conduct and Business Ethics booklet or Corporate Policy #C-201 and
sign Exhibit A. The signed exhibit must be placed in the partner’s personnel file or other
designated file.
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Acknowledgement Form
From time to time, each of us faces obstacles in our business careers that challenge
our business ethics. It is impossible to put together a “rule book” to cover every
issue we might encounter. The purpose of this booklet is to provide guidance for
your conduct as it relates to our principles and philosophies; governmental laws
and regulations; and any other ethical dilemma you might face.
I have read, and understand, the Cintas Code of Conduct and Business Ethics. I
agree to conduct my business in accordance with this Code as well as with our
other company policies and applicable laws.
Name: ____________________________________________________________________
Date: _____________________________________________________________________
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