The document provides an ethics and code of conduct training for employees. It discusses key topics like conflicts of interest, confidential information, accurate record keeping, international business practices, use of company resources, and workplace conduct. The purpose is to ensure employees understand and follow the company's guidelines in order to protect the business and comply with applicable laws. It also includes hypothetical scenarios to demonstrate how violations of the policies could negatively impact the company or result in corrective action for employees.

1. INSERT COMPANY NAME
Welcome to
Ethics and
Code of Conduct Training
1

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 organizational
2 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 do
3

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 work
4

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 public
5

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 our
6

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, and
7

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 community
8 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 in
9
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 company
10

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 and
11

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 be
12
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 business
13 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 and
14 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 venture
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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 company
16 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 and
17 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 intentionally
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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 any
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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 international
20 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 keeping
21
• 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 advantage
22

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 Department
23

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
needs
24

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 supplies
25

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., for
26

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 misuse
27 is every employee's

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 sexual
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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 your
29

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 corrective
34
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 document
37 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 about
40 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 hours
41

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 violated
42
•

43. Use of Company Resources
Scenario 6
Situation:
Employee brings home
excess
equipment that appears to
be
discarded
43

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 property
44

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 supervisory
46

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 fines
48
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. $36
49

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 charges
50

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 to
52
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 license
53

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
client
54 •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
arena
56
•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 employee
59
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 on
61
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 being
64 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 of
66
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 responsibilities
67

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 work
68

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 are
69
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 paid
70
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 create
71 and maintain an ethical

72. Ethics and Code of Conduct Training
Ethics ...
Take It With You
72