Effective Date: September 1, 2023

‍PURPOSE
‍This policy clarifies the distinction between the personal views of individual associate consultants and the official stance of Samuel Associates, its Samuel Group of Companies, and affiliates.

‍SCOPE
‍This policy encompasses all associate consultants affiliated with Samuel Associates and its Samuel Group of Companies.

‍PERSONAL VIEWS
‍Every associate consultant is entitled to hold and express their unique personal views, beliefs, and opinions. Such views are distinct from and do not represent the perspectives or policies of Samuel Associates, its Samuel Group of Companies, or affiliates.

‍NON-REPRESENTATION
‍When articulating personal views, associate consultants must avoid claiming or implying that they are expressing the official position of Samuel Associates or its affiliated entities.

‍CLARIFICATION REQUIREMENT
‍Should any ambiguity arise, consultants are obligated to clearly indicate that the views they express are personal and do not echo the sentiments of Samuel Associates or its associated companies.

‍ONLINE AND SOCIAL MEDIA
‍Consultants, while on online platforms, including social media, are advised to be cautious and maintain professionalism. They should never convey that they are voicing the company's position unless explicitly authorized.

‍USE OF COMPANY RESOURCES
Consultants should refrain from utilizing company assets, including email addresses or branded materials, to express personal views.

‍CONFLICT OF INTEREST
‍If there's a possibility that a consultant's personal views might generate a conflict of interest or adversely influence their professional obligations, it's mandatory for them to inform Samuel Associates' management for appropriate direction.

‍CONSEQUENCES
‍Breaching or misinterpreting this policy can lead to disciplinary measures, potentially including the termination of the consultant's agreement.

‍REVIEW AND UPDATES
‍The policy is subject to an annual review to ensure it remains pertinent and accurate.