Ethics & Compliance

Respect • Integrity • Honesty

Staying true to our Core Values

At ICD, our ethics policy is simple; each employee has the responsibility to act respectfully and conduct all activities with the highest level of integrity.  Our Board of Directors will provide oversight and guidance to ensure ICD’s Code of Business Conduct and Ethics is managed and enforced.  The Code encourages employees to make consistent, ethical decisions and provides employees with a clear understanding of the importance of reporting concerns or violations about actions that may be at odds with our Code, policies, laws or regulations.

Ethics & Compliance

Each employee has a responsibility to ensure our ethics and business practices’ program works.  We should all be alert and sensitive to situations that could result in violations of this Code, ICD policies and or the law.  It is our obligation to report any conduct that may be a violation.

Generally these matters should be raised first with your immediate supervisor.  However, if you are uncomfortable  bringing this matter up with your supervisor, or you do not believe the supervisor has dealt with the matter properly, you should raise the matter with our Compliance Officer, who is our General Counsel and Chief Financial Officer. All inquiries, however reported, will be handled on a confidential, “need-to-know” basis.

If you choose to communicate in writing, you should send your letter to ICD, Attention: Compliance Officer, 20475 SH 249, Suite 300 Houston, Texas 77070 or email your information to [email protected]. If you prefer to remain completely anonymous, you may utilize the Ethics Hotline by phone at 855-748-5766 or utilize the Ethics Website at  Our anonymous hotline is managed by the Chairman of the Audit Committee of our Board of Directors.

Summaries of key ICD policies relating to ethics and business practices are linked below.  Compliance with these policies is a condition of each employee’s continued employment.  These are summaries only and you should consult the Employee Handbook for full disclosure.

ICD reserves the right to amend, modify, revoke, suspend or terminate this Code, in whole or in part, at any time with or without notice.

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