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Ethics Briefing

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  • 1. INSERT COMPANY NAME Welcome to Ethics and Code of Conduct Training1
  • 2. Ethics and Compliance Training Purpose of Meeting: Understanding and adhering to the Code of Ethics and Standards of Conduct Guidelines is critical to the success of our business and Badge 12034 Employee is a condition of employment The purpose of this session is to provide you with information regarding individual and organizational2 responsibilities
  • 3. Ethics and Compliance Training •Your Company is committed to: – High moral and ethical standards – Conducting business with honesty and integrity – Complying with all applicable laws – Meeting obligations to all who have a personal, professional or financial stake in what we do3
  • 4. Ethics and Compliance Training Who me? We are all personally responsible and accountable for achieving the highest standards of conduct in all aspects of our work4
  • 5. Ethics and Compliance Training Along with other USA leading organizations, we have pledged to promote ethical business conduct through the implementation of policies, procedures, and programs in several areas, including: conducting regular ethics training developing internal reporting mechanisms for alleged misconduct self-governance through the implementation of processes to monitor compliance and voluntary disclosure of violations to the government accountability to the public5
  • 6. Ethics and Code of Conduct Training 2012 Code of Ethics Code of Ethics The principles that govern us in our daily Standards of Conduct work Standards of Conduct Your Company’s policies that are in compliance with laws and regulations applicable to our6
  • 7. Ethics and Code of Conduct Training Ethics and Code of Conduct Guidelines Cover: 1. Business courtesies If you don’t understand your 2. Kickbacks responsibilities, ask questions. 3. Conflicts of interests 4. Confidential information 5. Use of company resources 6. Complete and accurate books, records, and communications 7. Bidding, negotiation, and7
  • 8. Ethics and Code of Conduct Training ……..Continued 7. Charges to the government 8. Relationships with suppliers and representatives 9. Violation of standards by others 10.Insider information and investment in securities 11.Antitrust and restriction of trade 12.International business practices 13.Work place relationships and proper conduct 14.Corporate citizenship and relations with the community8 15.Political contributions
  • 9. Ethical Principles Applied to Your Work Life • Adhering to all the codes and standards identified in our guidelines is important and fundamental to staying in business • For purposes of this session, we will focus on 6 of the areas identified, because: – experience tell us that we need to clearly communicate what is expected from employees in9 these areas
  • 10. Ethics and Code of Conduct Training • Before we get started : – It is critical to understand that many of the laws and regulations are more complicated than the examples illustrated. The examples are for given purposes. – Be sure and contact the appropriate expert resource to understand the business requirements. Never assume that you know all the answers. • Remember, honest mistakes can result in phenomenal penalties for your company10
  • 11. Ethics and Code of Conduct Training Today’s Areas of Focus Conflicts of interests Confidential information Complete and accurate books, records, and communications International business practices Use of company resources Work place relationships and11
  • 12. Ethics and Code of Conduct Training Conflict of Interest •Employees are prohibited from having personal, business, or financial interests that are in conflict with their responsibility to your company •All business decisions should be12 made in the best interests of your
  • 13. Ethics and Code of Conduct Training Conflict of Interest • Company policy prohibits employees from serving as consultants to, or as directors, officers, or part-time employees of companies that compete or deal with your company, or that seek to do so, unless the required management approval has been given in accordance with company “Standards of Conduct” • Employees are required to report and disclose to appropriate company personnel all their outside business13 activities that may be a conflict of
  • 14. Ethics and Code of Conduct Training Confidential Information •All employees must protect company confidential and intellectual property •Intellectual property includes: – Patents and copyrights - exclusively federal rights – Trademarks - can be federal, state or common- law – Trade secrets (proprietary or confidential information that is not in public domain) •Theft of trade secrets is a Federal criminal offense under the Economic Espionage Act and can be punishable by fines and14 imprisonment
  • 15. Ethics and Code of Conduct Training Confidential Information •Your company restricts the usage of confidential and XYZ intellectual property COMPETITOR – Prohibits unauthorized possession,use, alteration, destruction, or disclosure of company sensitive data Proprietary Information – Cautions employees to ensure that all suppliers’, customers’ and joint venture15 partners’ proprietary and
  • 16. Ethics and Code of Conduct Training Confidential Information • Confidential Information Includes: – Acquisition-related information, proprietary and source selection information – Information regarding employees or former employees given to outside organizations or individuals – Employees seeking or accepting information from a competitor or customer to which the company16 is not legitimately entitled
  • 17. Ethics and Code of Conduct Training Complete & Accurate Books, Records, & Communication • All company documents, including internal or external correspondence, or communications of any type, must be prepared completely, accurately and honestly, i.e., test and inspection reports, proposals, safety records • All disbursements of funds and17 receipts, such as expense reports
  • 18. Ethics and Code of Conduct Training Complete & Accurate Books, Records, & Communication • Remember: – Cost or Pricing Data Disclosure - never intentionally withhold pertinent cost or pricing data from the customer during negotiations – Contract Performance - never conceal information concerning substandard or non- performance issues, where such issues might not be apparent to the customer – Support to Post Award Audits or Investigations - never intentionally18 withhold or destroy data requested in
  • 19. Ethics and Code of Conduct Training Complete & Accurate Books, Records, & Communication • Inaccurate description of Our rates are too high? or labor costs, such as You are over the falsifying a timecard, is budgeted hours Charge the remainder strictly prohibited to ………. • Employees shall not intentionally allocate costs to contracts contrary to contract provisions • Managers or supervisors shall not direct any19 employee to submit time
  • 20. Ethics and Code of Conduct Training International Business Practices Your Company is a global organization – Many domestic employees are involved in International business transactions – International transactions must conform to both United States and any foreign laws that govern these transactions – Employees need to understand the legal requirements when conducting international20 business transactions
  • 21. Ethics and Code of Conduct Training International Business Transactions Examples - Not Inclusive • Implementing programs that have international work including discussing cost and price data with a non-US customer • Conducting any business transaction with individual(s) who is not a US citizen or a Permanent Resident • Hiring employees to work outside of in the USA • Transferring information that is outside of public domain (faxing information, Intranet, cc:mail, etc.) • Record keeping21 • Escorting a non-US citizen/Permanent
  • 22. Ethics and Code of Conduct Training International Business Practices • Foreign Corrupt Practices Act – Employee may not corruptly offer or give money or anything of value, directly or indirectly, through agents or intermediaries, to foreign officials or political candidates to: • assist in obtaining or retaining business • secure any improper advantage22
  • 23. Ethics and Code of Conduct Training International Business Practices • The Arms Export Control Act Prohibits: – Sending or taking a Defense article out of the US – Disclosing or transferring by any means technical data to a non-US citizen in the US or abroad without export approval from the State Department • When in doubt, always contact the Export Administrator or the Legal Department23
  • 24. Ethics and Code of Conduct Training International Business Practices I need to make a • Employees dealing with call. international customers and suppliers should contact the Legal Department to: – Ensure that they are complying with the Foreign laws and US legal requirements – Identify any specific training needs24
  • 25. Ethics and Code of Conduct Training Use of Company Resources •Company policy prohibits the improper or personal use of company or customer assets, including: – computer Proprietar – software y Informatio – technology and patentsn – communication and copying equipment – office supplies25
  • 26. Ethics and Code of Conduct Training Use of Company Resources • Misuse of Company Resources Includes: My kids could really – Unauthorized destruction of school supplies... use some new property – Taking company property for unauthorized personal use – Inappropriate use of the Internet – Using the company telephone, credit card, etc., for26
  • 27. Ethics and Code of Conduct Training Use of Company Resources • Protecting all company assets, including physical property and intangible assets (such as data and software) against loss, theft and misuse27 is every employees
  • 28. Ethics and Code of Conduct Training Workplace Relationships and Proper Conduct • Employees must be fair, honest and in compliance with the law in all business relationships • Discrimination against any employee or individual involved in our daily business dealings is prohibited • Harassment of any kind or nature, including sexual28 harassment, is prohibited and
  • 29. Ethics and Code of Conduct Training Workplace Relationships and Proper Conduct • Illegal possession, use, manufacture, distribution, dispensing, sale, purchase or transfer of drugs or other controlled substances while on company premises or while conducting company business is prohibited • If you have a substance abuse problem or concern, contact your29
  • 30. Ethics Scenarios I know a way to get easy money Never! I don’t Gosh, I am and relax! care what the so tired, temptations are! overworked and underpaid.... Trade Secrets In the following section, there are 17 hypothetical scenarios that identify “possible consequences” of an individual’s behavior. Examples provided are for illustrative purposes only.30
  • 31. Ethics Scenarios Each scenario has a “Situation” viewgraph followed by a viewgraph that identifies “Perceptions” and/or “Possible Consequences”. Consequences identified in the Scenarios can vary based on circumstances and situations. Before we proceed to the “Perceptions” and/or “Possible Consequences” viewgraph, think about the possible consequences...31
  • 32. Ethics Scenarios Your company reserves the right to determine the appropriate corrective action based on the individual situation and circumstances. Remember, consequences for violations of the Code of Ethics and Standards of Conduct Guidelines can vary depending on many different circumstances. Corrective action (disciplinary action can range from a verbal warning up to and including termination of employment.)32
  • 33. Conflict of Interest Scenario 1 Situation: A vendor knows a company employee loves to play golf and What’s the invites the employee to a golfin a harm tournament. Vendor wines and little golf? dines the employee and pays for all expenses.33
  • 34. Conflict of Interest Scenario 1 Employee’s Perception: •Employee believes that the activity is okay since it is not during business hours. Possible Consequences: •Competing vendors may claim contract award violated government procurement guidelines •Employee receives corrective34 action for inappropriate behavior
  • 35. Confidential Information Scenario 2 Situation: Your company has a partnership with a business that is also a competitor, Company Z. A manager of your company is hosting a meeting and allows Company Z free access to the facility. Company Z has not signed a confidentiality agreement and has no restrictions or identifying information on visitor badge.35
  • 36. Confidential Information Scenario 2 Manager’s Perception: •Competitor is a “nice guy”, wouldn’t harm a fly Possible Consequences: •Company is violating security regulations •Company sensitive documentation can be stolen,36 observed or photographer
  • 37. Confidential Information Scenario 3 Situation: Employee discusses complexities associated with composite materials with a customer, who is having difficulty with a math problem. Employee won’t give out the document because it is marked “Proprietary Information,” but gives some of the information contained in the document37 including the mathematical
  • 38. Confidential Information Scenario 3 Possible Consequences: • Verbal disclosure of data offers no protection from misuse or further disclosure of the information unless the customer signed a confidentiality agreement, or employee informed customer the information to be disclosed is confidential. • Divulging information could jeopardize your company’s future success, proprietary data can be a strategic advantage against competitors.38 • Employee receives corrective action.
  • 39. Confidential Information Scenario 4 Situation: Employee Z has access to Employee B’s records, i.e., performance appraisal and salary information. Employee Z is very upset because Employee B received an “Exceptional” rating and believes the manager is playing favorites. Employee Z tells a co-worker about the situation.39
  • 40. Confidential Information Scenario 4 Possible Consequences: •Employee Z receives corrective action for violating confidentiality related to another employee’s records •Employee Z is reassigned to a position where confidentiality is not required •Employee B finds out about40 breach of confidentiality and
  • 41. Use of Company Resources Scenario 5 Situation: Employee is accessing pornographic material through the Internet No one will know if I visit this web site during non-working hours41
  • 42. Use of Company Resources Scenario 5 Employee’s Perception: •Employee believes he/she is not hurting anyone, after all, it is after hours and he/she has already worked 8 hours Possible Consequences: •Routine audits of Internet usage reveals company policy is violated42 •
  • 43. Use of Company Resources Scenario 6 Situation: Employee brings home excess equipment that appears to be discarded43
  • 44. Use of Company Resources Scenario 6 Perceptions: • Co-workers would have liked to have an opportunity to “take home” equipment • Employee believes he/she was doing the company “a favor” by off-loading discarded equipment Possible Consequences: • Equipment is the property of the government and restitution must be made • May affect approval of property system • Employee receives corrective action for misuse of company property44
  • 45. Charges to the Government Scenario 7 Situation: Employee frequently leaves work early yet indicates he/she worked 8 hours. Supervisor knowingly signs the timecard each Friday.45
  • 46. Charges to the Government Scenario 7 Possible Consequences: • Employee and supervisor receive corrective action including possible termination of employment • Inappropriate time charging must be reconciled • Government criminal prosecution resulting in fines and or penalties for employee and supervisory46
  • 47. Charges to the Government Scenario 8 Situation: Employee’s supervisor is putting pressure on an employee to keep indirect or project costs down. Supervisor suggests that the employee use an incorrect charge number and the employee complies.47
  • 48. Charges to the Government Scenario 8 Possible Consequences: •Employee and supervisor both receive corrective actions up to and including termination of employment •Inappropriate time charging must be reconciled •Adverse government action (debarment for fraudulent labor, criminal action resulting in fines48 and possible prison terms)
  • 49. Complete and Accurate Books, Records, and Communications - Scenario 9 Situation: Employee attends company sponsored training. Submits Expense Report for meals not eaten or inflates the amount of the cost of the meals. $3649
  • 50. Complete and Accurate Books, Records, and Communications - Scenario 9 Employee’s Perception: Everyone does it - they get a per diem so it is okay Possible Consequences: • Employee receives corrective action • Inappropriate charging must be reconciled • Government decrements company overhead rates due to perceived lack of controls • Government mandates receipts for all expenses before allowing charges50
  • 51. Complete and Accurate Books, Records, and Communications - Scenario 10 Situation: Employee signs off on an inspection check that never occurred.51
  • 52. Complete and Accurate Books, Records, and Communications - Scenario 10 Employee’s Perception: Employee is in a hurry to get home and believes that “no harm” can occur given the nature of the check. Possible Consequences: •Employee receives corrective action •Faulty or unsafe product •Adverse government action ranging from increased government inspection and/or oversight to52 potential prosecution
  • 53. International Business Practices Scenario 11 Situation: Domestic employee arranges a site visit for a group of foreign nationals who are potential customers and will have access to technical data without obtaining a foreign Welcome to the United States export license53
  • 54. International Business Practices Scenario 11 Perception: •Employee is acting pro-actively and in the best interests of the company. Possible Consequences: •Employee failed to adhere to federal laws/ITAR regulations •Embarrassment to a potential client54 •Loss of security clearance
  • 55. International Business Practices Scenario 12 Situation: A company vendor wants to ship parts to company’s overseas customer. Vendor requests company’s export license information and ships parts. Vendor ships the parts not covered by export license.55
  • 56. International Business Practices Scenario 12 Perception: •Harmless, honest mistake Possible Consequences: •US Government seizure of parts and everything related to export license •Jeopardizes company’s ability to do Defense work in international arena56 •Heavy fine sanction against
  • 57. Workplace Relationships and Proper Conduct, Scenario 13 Situation: Employee receives an e-mail from an outside party that has several offensive jokes. Employee copies the jokes and distributes them to several co- workers.57
  • 58. Workplace Relationships and Proper Conduct, Scenario 13 Employee Perception: •The jokes are harmless and were given to friends •No offense or harm was meant Possible Consequences: •Receiving employee(s) was offended and reports the incident •Federal & State laws &58 Company policy violated
  • 59. Workplace Relationships and Proper Conduct, Sexual Harassment, Scenario 14 Situation: Female supervisor is Good morning Bob, always standing very you’re looking good today. close to her employees, About that report... frequently touching them (in a non-sexual manner), when she discusses business. She is very complimentary, always telling the employee59 he/she looks nice today,
  • 60. Workplace Relationships and Proper Conduct, Sexual Harassment, Scenario 14 Employee Perception: •Employee feels sexually harassed by supervisor. Possible Consequences: •Supervisor may have meant no harm and uses the same approach with everyone, male or female. •Supervisor is counseled on interpersonal skills; for instance,60 not touching employees, giving
  • 61. Workplace Relationships and Proper Conduct, Sex Discrimination, Scenario 15 Situation: May I have Supervisor is always giving the this dance? “preferred assignments” to opposite sex employees X & Y who report to him/her. Supervisor and employees X & Y are also recreational friends, go bowling, dancing, a couple of drinks on61 Friday nights, etc.
  • 62. Workplace Relationships and Proper Conduct, Sex Discrimination, Scenario 15 CoWorker’s Perceptions: • Supervisor is discriminating against individuals that do not “hang out with” him/her. Impacts promotions, etc. Possible Consequences: • Supervisor is using poor discretion in the type of socializing he or she is doing with employees X & Y.62 • Supervisor is counseled on
  • 63. Workplace Relationships and Proper Conduct, Harassment, Scenario 16 Situation: Employee finds notes left on his/her desk first thing in the morning. Notes have harassing and threatening statements and inappropriate pictures drawn on them.63
  • 64. Workplace Relationships and Proper Conduct, Harassment, Scenario 16 Employee’s Perceptions: • He/she is being harassed and or discriminated against because of their religion, sex, sexual preferences, color, age, weight, race, etc. Possible Consequences: • If the individual leaving the notes is caught, this person could be terminated on first offense depending on the seriousness. • Individual being64 harassed/discriminated against can
  • 65. Workplace Relationships and Proper Conduct, Drug or Alcohol, Scenario 17 Situation: Employee frequently returns to work after lunch with alcohol on his/her breath and acts disoriented. Employee refuses to take a drug/alcohol test or seek help through the EAP program when confronted by HR and their manager.65
  • 66. Workplace Relationships and Proper Conduct, Drug or Alcohol, Scenario 17 Possible Consequences: •If this is a first time occurrence, the employee has an opportunity to seek help through the EAP or a qualified Rehabilitation program. •If employee refuses to seek help or if the employee has violated an agreement regarding rehab, termination of66 employment can result.
  • 67. Ethics and Code of Conduct Training Remember, •Consequences for violations of the Code of Conduct and Ethics Guidelines can vary depending on many different circumstances. •Ask questions. Although it was evident in many of the situations that the employee had violated company policies and procedures, some of the stituations could have been avoided if the individual had understood their responsibilities67
  • 68. Ethics and Code of Conduct Training Purpose of Training: Now that you have had an opportunity to complete this Ethics and Compliance training session, remember: • Understanding and adhering to Badge 12034 the Code of Ethics and Standards Employee of Conduct Guidelines is critical to the success of our business and is a condition of employment • You are personally responsible and accountable for achieving the highest standards of conduct in all aspects of our work68
  • 69. Ethics and Code of Conduct Training It is your personal responsibility to: • Become familiar with the Code of Ethics and Standards of Conduct guidelines and abide by them • Promptly and accurately report violations - you can do so without fear of retaliation • Talk to your supervisor, manager or HR representative if you have questions or concerns • Ask a company expert for guidance in areas that are69 unclear to you, such as
  • 70. Ethics and Code of Conduct Training Ethics Program • Call the Ethics Helpline if you have questions or concerns at 1*888*xxx- xxxx • Access Intranet to learn more about your company’s Ethics Program, WWW.xxxx.COM/ • Obtain a postage paid70 Ethics Write-It (located in
  • 71. Ethics and Code of Conduct Training Your company’s success and reputation are dependent upon our collective efforts to create71 and maintain an ethical
  • 72. Ethics and Code of Conduct Training Ethics ... Take It With You72

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