Code of Business Ethics and Conduct
TO ALL CERTIFIED SLINGS & SUPPLY® TEAM MEMBERS:
Certified Slings & Supply®, (“Certified Slings & Supply®” or “the Company”) is committed to providing the highest quality products and services to its customers while always observing the highest legal and ethical business standards. The Company requires that all members of the Certified Slings & Supply® team, which includes every employee and member of the Company’s Board of Directors, uphold these standards in order to assure the Company’s continued success. Accordingly, Certified Slings & Supply® has adopted this Code of Business Ethics and Conduct (“Ethics Code”).
This Ethics Code has been adopted to put into effect the Company’s Core Values and to apply them to the conduct of its business affairs. All team members shall comply with the provisions of this Ethics Code.
This Ethics Code does not cover every situation and does not set forth every applicable rule with which all team members must comply. There are other applicable laws, regulations, and Company policies, procedures, and instructions that are not addressed here, as well as common sense standards of conduct, to which all team members are expected to adhere. This Ethics Code is in addition to the Company’s Human Resources Employee Handbook, dated November 1, 2000.
Enforcement of the policies and standards in the Ethics Code is the responsibility of the Company’s Compliance Officer, the President, the Chief Executive Officer, and the Board of Directors.
All team members are required to read the Ethics Code and acknowledge its contents. If you have any questions about the Ethics Code, you are encouraged to contact your supervisor, any management member, or the Company’s Compliance Officer.
Chief Executive Officer
CERTIFIED SLINGS & SUPPLY®.
CODE OF BUSINESS ETHICS AND CONDUCT
*****
Certified Slings & Supply®. (“Certified Slings & Supply®” or “the Company”) is committed to providing the highest quality products and services while at the same time maintaining the highest legal and ethical standards of business conduct in dealing with customers, suppliers, subcontractors, vendors, consultants, and others with whom the Company does business. This Code of Business Ethics and Conduct (“Ethics Code”) sets forth the responsibilities of the Company and its team members – which includes all hourly employees, salaried employees, managers, supervisors, officers, and board members – in conducting our business affairs.
RESPONSIBILITIES OF THE COMPANY
General Responsibilities. Certified Slings & Supply® has the responsibility and duty (i) to conduct its business under the highest legal and ethical standards and in compliance with all applicable laws and regulations, thereby protecting and preserving the integrity of the Company, and (ii) to assure that all team members understand these requirements and comply with them. Certified Slings & Supply® will update this Ethics Code from time to time as appropriate.
Core Values. This Ethics Code is grounded in the Company’s Core Values of integrity, respect, teamwork, commitment, and communication, as described in the Company’s Human Resources Employee Handbook, dated November 1, 2000. These Core Values dictate how we behave individually and as a team in all aspects of the Company’s business, and affect how those with whom we do business perceive us.
Vigilance and Diligence. Certified Slings & Supply® has the responsibility and duty to be alert to any circumstances that might create, or appear to create, an illegal or unethical situation involving the Company or any organization or person with whom the Company does business or has a business relationship.
The Company also has the responsibility and duty to investigate promptly and fully all reports of suspected illegal or unethical conduct. To those ends, Certified Slings & Supply® has assigned the responsibility for Ethics Code compliance to the Company’s Compliance Officer, who is responsible for receiving and investigating suspected illegal or unethical activity, and for reporting findings to Company management. The current Compliance Officer is Kim Vogt, Director of Team Member Management, who will report initially to the President, and then to the Chief Executive Officer and/or Board of Directors as appropriate. Instructions informing all Company team members how to report questionable activity are provided in the section of this Ethics Code entitled Obligation To Report.
Education and Training. Certified Slings & Supply® is committed to educating and training all team members regarding compliance with this Ethics Code. For purposes of compliance with the requirements of this Ethics Code, “team members” shall include consultants to the Company. All team members will receive a copy of the Ethics Code and must provide the Company with a written acknowledgement of its receipt and of its content. Thereafter, the Company will schedule training at least once a year to assure that all team members (i) understand the laws and regulations affecting their duties; (ii) understand the requirements of this Ethics Code and comply with them; (iii) will be alert to potential violations of laws, regulations, or the Ethics Code, and (iv) will recognize their duty to report any conduct or activity that appears to be illegal or unethical to the Company?s Compliance Officer. Training will also address any changes in the Ethics Code resulting from new laws and regulations. At each training team members will be required to take a written test on the contents of the Company?s Ethics Code. Any director, officer, team member, and/or consultant who misses the annual training will be required, within thirty days to read the course syllabus and take a written test on the contents of the Company?s Ethics Code. Any director, officer, employee, and/or consultant who joins, is hired by, or contracts with Certified Slings & Supply® will be required, within thirty days of their association with Certified Slings & Supply®, to read the course syllabus and take a written test on the contents of the Company?s Ethics Code. If a team member does not achieve a passing score on the written test on the contents of the Company?s Ethics Code, the team member will receive remedial training on the Ethics Code and be retested within 60 days. If a new team member joins the Company within 90 days of the annual training of all Company team members as described above, that new team member will receive initial training on the Ethics Code and be required to take the written test on the Company?s Ethics Code, but will not be required to receive separate annual training for that year. Managers, supervisors, officers, and directors may receive additional training as deemed appropriate. Finally, Certified Slings & Supply® will notify its suppliers and subcontractors of the requirements of the Company?s Ethics Code.
Enforcement and Discipline. Certified Slings & Supply® is committed to taking immediate steps to correct any situation that may prove to be, or may appear to be, illegal or unethical. Certified Slings & Supply® has established ethics performance standards as part of the performance review of every team member. If it is determined that a team member has failed to comply with this Ethics Code, such team member will be subject to discipline, including discharge, as appropriate.
If the Company determines that any organization or person with whom the Company does business or has a business relationship is operating illegally or unethically, the Company will no longer do business with that organization or person. In that vein, Certified Slings & Supply®‘ policy is (i) not to hire individuals who are suspended, proposed for debarment, or debarred from government contracting; (ii) to remove from responsibility or involvement with government business any team member who is suspended, proposed for debarment, or debarred; and (iii) subject to provisions of applicable laws and regulations, not to contract with individuals or companies that are suspended, proposed for debarment, or debarred.
RESPONSIBILITIES OF TEAM MEMBERS
General Responsibilities. Every team member must (i) perform his or her job in an efficient and productive manner, (ii) meet reasonable standards of work performance and personal conduct; (iii) obey all Company rules including the policies and standards set forth in this Ethics Code; (iv) adhere to safe work practices; and (v) cooperate with management and fellow team members. Any team member who fails to do so will be subject to discipline, including discharge, as appropriate. Three rules of thumb for all team members are:
- Apply Certified Slings & Supply®‘s Core Values to all business decisions and actions.
- Never knowingly violate laws, regulations, or the policies and standards set forth in this Ethics Code.
- Apply the “media test.” If you think that you or the Company would be embarrassed or jeopardized if your actions were reported in the media, do not act without consulting with your manager or the Company’s Compliance Officer.
All Certified Slings & Supply® team members are required to (i) keep current with their knowledge and understanding of the Ethics Code; (ii) seek help when the proper conduct is unclear; (iii) help create a workplace environment conducive to complying with the policies and standards of the Ethics Code; (iv) be alert to situations that could result in violation of these policies and standards or are otherwise improper; and (v) report suspected violations of the Ethics Code to the Compliance Officer.
Summary of Important Laws. In dealings with all customers (as well as suppliers, subcontractors, vendors, consultants, and competitors), Certified Slings & Supply®‘s team members are the first line of defense in avoiding illegal and unethical activity, or the appearance thereof. This section of the Ethics Code summarizes several laws that all team members must be familiar with in their business dealings. All of these laws apply in some way to Certified Slings & Supply®‘s government contracts, while some apply only to commercial contracts.
Antitrust Laws. These laws prohibit actions and agreements in restraint of trade, including agreements between or among competitors to (i) fix or control prices; (ii) divide or allocate markets; (iii) rig bids; (iv) refuse to deal with others; or (v) engage in other types of anti-competitive activity. All team members must avoid discussing these matters with employees of any potential competitor of the Company, and must inform the Company’s Compliance Officer if any person initiates such discussions. These laws may also prohibit (i) “tying arrangements” (requiring a customer to buy a product or service that it does not necessarily want in order to buy one that it does want), and (ii) attempts to monopolize a market by using strategies designed to destroy a competitor or to foreclose competition. Violations of the antitrust laws are punishable by fines and imprisonment.
Federal Trade Commission Act. This law declares unfair methods of competition, and unfair or deceptive acts or practices to be unlawful. Accordingly, no Certified Slings & Supply® team member should take advantage of any business situation by (i) misrepresenting the quality, features, or availability of the Company’s products or services, or those of its competitors; (ii) manipulation; (iii) misuse of confidential or privileged information; (iv) concealment; or (v) engaging in any other unfair or deceptive act or practice.
False Statements. 18 U.S.C. § 1001 makes it a crime to deceive the government through concealment, false documents or false statements.
Criminal False Claims. 18 U.S.C. § 287 makes it a crime to knowingly present a false, fictitious, or fraudulent claim to any person or officer in the civil or military service of the United States or any of its agencies or departments.
Civil False Claims. 31 U.S.C. §§ 3729-3732 permits the recovery of triple the amount of damages suffered by the United States and civil penalties of $5,500 to $11,000 per violation against any person who presents or causes to be presented a false claim, or causes a false record to be made to get a fraudulent claim paid, or conspires to defraud the government by getting a false or fraudulent claim allowed or paid. The statute also provides a complex procedure for the initiation of qui tam actions in the name of the government by whistleblowers.
Major Fraud. 18 U.S.C. § 1031 is a special provision aimed at contracts or subcontracts valued over $1 million, and violators may incur fines of up to $10,000,000.
Conspiracy. 18 U.S.C. § 286 is a “specific” conspiracy statute that requires agreement to defraud the government through submitting false claims. 18 U.S.C. § 371 is the general statute proscribing conspiracy: an agreement between two or more persons to commit a crime against, or to defraud, the United States (impede lawful governmental functions) and proof of an overt act by one of the conspirators in furtherance of the conspiracy.
Mail and Wire Fraud. 18 U.S.C. § 1341, 1343 and 1346 make it a crime to use the mails, wire, radio or television in devising a scheme or artifice to defraud, i.e., to obtain money or property by false pretense or promises.
Bribery and Gratuities. 18 U.S.C. § 201 prohibits the giving of any kind of gratuity to government personnel or their families. Agency personnel are required to report suspected violations. The government is authorized to terminate the entire contract if it is determined that the contractor or any of its employees or agents offered or gave any gratuity to a government officer, official, or employee to obtain a contract or favorable treatment in the awarding, amending, or making of determinations concerning the performance of the contract.
Truth In Negotiations Act (“TINA”). 10 U.S.C. § 2306a and 41 U.S.C. § 254b generally require prime contractors and subcontractors, when negotiating contracts or contract modifications that are above the TINA dollar threshold, to (i) disclose “cost or pricing data” to the government prior to agreement on price; and (ii) certify that the disclosed cost or pricing data are “accurate, complete, and current.” If the government overpays a contractor due to the contractor’s submission of defective cost or pricing data, the contractor is liable to the government (i) for the amount of the overpayment, plus interest; and (ii) if the submission of such defective data was knowing, for an additional amount equal to the amount of the overpayment.
Procurement Integrity Act. Prohibited activities are (i) offering or discussing, directly or indirectly, future employment or business opportunities with a government procurement official; (ii) offering or giving, directly or indirectly, any money, gratuity, or other thing of value to a government official; (iii) soliciting or obtaining, directly or indirectly, any proprietary or source selection information from any government officer or employee; (iv) improperly obtaining or seeking to obtain confidential bid or proposal information of another offeror before the award of a contract; or (v) disclosing any proprietary or source selection information that has been properly received, other than as authorized by the government?s contracting officer.
Anti-Kickback Act of 1986. 41 U.S.C. §§ 51-58 prohibits kickbacks, i.e., direct or indirect payments of any sort of compensation to a prime contractor, prime contractor employee, subcontractor, or subcontractor employee for the purpose of obtaining or rewarding favorable treatment in connection with a prime contract or in connection with a subcontract relating to a prime contract. Violators are subject to fine and imprisonment.
Drug-Free Workplace/Work Force. Applicable laws and regulations prohibit the illegal manufacture, use, possession, distribution, dispensation, transportation, purchase or transfer of controlled substances or drugs in a contractor’s workplace, and require the contractor to develop and publish a Drug Free Workplace Policy.
Lobbying Expenses. The so-called “Byrd Amendment” prohibits the use of appropriated funds to pay any person for influencing or attempting to influence a government employee or Member of Congress in connection with the award of a contract. Any questions about compliance should be directed to the Company’s legal counsel.
Honest And Accurate Reporting. Certified Slings & Supply® requires honest and accurate accounting and recording of financial and other information in order to make responsible business decisions and provide an accurate account of the Company’s performance for shareholders and reporting purposes. It is a violation of law and Certified Slings & Supply®‘s policy to attempt to improperly influence or mislead any accountant engaged in preparing our audit or review.
In addition, all team members responsible for preparing or reviewing any report or certificate, regardless of whether it is to be used internally or provided to a customer, shall ensure, to the extent applicable:
- That they understand, and that the Company has complied with, all applicable contract provisions.
- That invoices reflect only agreed-upon contract prices, and that
- appropriate refunds or credits have been provided in any instances where excess payments have been received.
- That the provisions of the Truth in Negotiation Act, if applicable, are followed, i.e., the most complete, accurate and up-to-date cost or pricing data are submitted to the government customer prior to completion of price negotiations.
- That applicable government procurement regulations have been followed.
- That team member timecards accurately report time worked in accordance with established Company policies and procedures. Mischarging of costs to inappropriate contracts or charge numbers is strictly prohibited.
- That expense reports are promptly, accurately, and fully completed and documented with appropriate receipts, and that business conference/entertainment expenses are separated from other expenses.
Gifts, Gratuities, Entertainment And Business Courtesies. As a general rule, no team member may offer or promise any gift, gratuity, entertainment, or other favor of value to any government or commercial customer. Certified Slings & Supply® does not seek to gain improper advantage by offering business courtesies such as entertainment, meals, transportation, or lodging in exchange for business. Team members should never offer any type of business courtesy to a customer for the purpose of, or in exchange for, obtaining favorable treatment or advantage. Nevertheless, except for restrictions that apply when dealing with government customers as noted below, if approved in accordance with Company policy, team members may pay for reasonable meals, refreshments, and/or entertainment expenses for customers and suppliers that are incurred only occasionally, are not requested or solicited by the recipient, and are not intended to or likely to affect the recipient’s business decisions with respect to Certified Slings & Supply®. If circumstances make it appropriate to make a more substantial gift to a commercial customer, approval by a supervisor, senior leader, or officer is required, who will document the following: (i) the identities of the giver and recipient, (ii) the date of Company approval, (iii) a description of the gift, (iv) the estimated value of the gift, and (v) the business reason for the gift.
Notwithstanding the above, team members may never provide or pay for any meal, refreshment, entertainment, travel, or lodging expense for any U.S. government employee. State and local governments may also have restrictions on business courtesies, so team members doing business with these entities must check with the Compliance Officer to determine if any restrictions apply. If a meal is brought onto the Company’s premises to accommodate a continuing business meeting with government employees, the government employees shall be given an opportunity to reimburse the Company for the reasonable value of their food.
As a general rule, team members should not accept gifts, gratuities, entertainment, or other favor of value from current or potential suppliers. (This prohibition does not apply to mass-produced items of nominal value, such as pencils, and the like, which are not offered with any intent or expectation of evoking any reciprocity from the Company.) Thus, as a general rule, team members who (i) purchase supplies or services for the Company, (ii) solicit information or data that may reasonably lead to a purchase of supplies or services for the Company, or (iii) interface in a way that influences or tends to influence the purchase on behalf of the Company with suppliers shall not accept a gift, gratuity, or entertainment without the prior approval of the President or Chief Executive Officer. Team members who do not purchase, or do not tend to influence the purchase of, supplies or services for the Company may accept meals, drinks or entertainment only if these courtesies are unsolicited, infrequently provided, reasonable in amount, and directly connected with business discussions. These team members shall not accept a gift, gratuity, or entertainment that has a value in excess of $100.00 without the prior approval of the President or Chief Executive Officer.
Inspection And Testing. It is illegal and unethical not to perform the inspection and tests required by contract, or to fail to provide the necessary documentation in support of such inspection and testing, or to misinform the customer about the nature of the inspection and testing performed. Full compliance by all team members is required.
Nondisclosure Of Information. Company technology is valuable property, and it is improper to use such property for any purpose other than that for which it is furnished and intended. Each team member is obligated to guard against unauthorized disclosure of Certified Slings & Supply®‘s technology. The same strict rules of nondisclosure apply not only to Company-owned technology, but also to private data furnished to the Company by suppliers and customers. Computer systems and the information they contain, control, transmit or process are essential for Certified Slings & Supply®‘s operations. Team members are responsible for ensuring that computer systems and the information that they contain are adequately safeguarded against damage, alteration, fraudulent manipulation, theft and unauthorized access or disclosure. Data processed and stored in computers must be protected as a Company asset, and properly identified and safeguarded according to its proprietary and/or critical nature. Passwords or other procedures used to access or transmit computerized data must be selected, controlled and safeguarded to ensure that Company data is adequately protected. Ultimately, each team member is responsible for the security of information accessed or modified under his or her password or access procedure. Also, as a user or manager of corporate data or computer resources, each team member must strictly adhere to the specific security measures and controls that have been established.
Team members may not make improper use of Company or customer resources or permit others to do so. Improper uses include the unauthorized appropriation, possession or personal use of Company customer assets, including technology, patents, equipment, software and supplies. Team members also may not obtain or use the proprietary information of customers or competitors.
Procurement Of Materials And Services. Materials, supplies, equipment and services shall be purchased from qualified, competent and responsible sources. To the maximum extent practicable, such purchases shall be effected on a competitive basis and in accordance with sound business practices. Objectivity, impartiality and fairness are required in the selection of every supplier for every order. Authorized Company agents are the only persons authorized to commit the Company to a purchase.
Conflicts Of Interest. All team members have fiduciary responsibilities to Certified Slings & Supply® and, in making business decisions, must be objective and impartial. In situations where a team member has a potential conflict of interest, or if there even exists an appearance of a conflict, the team member shall immediately give written notice to his or her supervisor. Such potential conflicts would include any situation in which a team member responsible for purchasing goods or services, or for selecting a vendor or supplier, has an interest in, or does personal business with, the vendor or supplier. The notice shall outline the nature of the conflict and the reasons that the team member believes a conflict might exist or appear to exist.
Team members may not assist competitors in any way or become involved in activities or businesses that compete with Certified Slings & Supply®‘s activities or its business. This policy does not apply to partners in joint ventures with the Company, or to our competitors when performed under approved Company programs. Team members must also avoid any outside activity that could (i) adversely affect the independence and objectivity of their judgment; (ii) interfere with the timely and effective performance of their duties and responsibilities; (iii) discredit the Company; or (iv) conflict, or appear to conflict, with the Company’s best interests. Since each team member’s primary obligation is to the Company, any outside activity, such as a second job or self-employment, must be kept totally separate from employment with the Company. Unless expressly authorized by the Company, no outside activity should involve the use of (i) the Company’s name, time, influence, assets, funds, materials, or facilities, or (ii) the services of other team members.
Political Contributions. All team members are entitled to engage in whatever lawful political activities they deem appropriate, including volunteer work and making contributions to candidates of their choice. But these activities are undertaken by team members as individuals, on their own time, and not as representatives of, or on behalf of, Certified Slings & Supply®. Team members are prohibited from making individual political contributions in the name of the Company, and this prohibition extends to direct and indirect contributions, including cash, goods, loans, property, services, and the use of Company facilities. To the extent allowed by applicable law, the Company may make political contributions in its own name from time to time as may be authorized by the Company’s management.
Inside Information. Team members should not trade in the securities of other companies based on material nonpublic information about these companies that they have learned as part of their job or otherwise. For example, a team member who learns that another company is being considered for a major contract or a joint venture, may not use this information to trade in that company’s securities. Team members should keep any such information about Certified Slings & Supply® or other companies secret and use it only for Company purposes. Inside material information can include anything that could have actual significance in an investor’s decision, such as (i) acquisition plans, (ii) dividends, (iii) earnings, (iv) new contracts, products, or discoveries, (v) major regulatory, court, or legislative events, and (vi) major management changes or other business plans. Such information should be disclosed only to those with a Company authorized need to know.
Copyrighted Works. Certified Slings & Supply®‘s policy is to honor the copyrights of others. This means that team members may not copy any copyrighted work without the permission of the copyright owner or its authorized agent, e.g., the Copyright Clearance Center. This includes articles from newspapers, trade journals, magazines and other publications. Similarly, virtually all purchased computer software is copyrighted. Under copyright law, such software may not be copied except to make an archival copy or as an essential step in its utilization. Team members are responsible for using licensed computer software only as permitted by the specific license.
Drug Free Workplace. All Certified Slings & Supply® team members are required to comply with the drug free workplace policies and standards as set forth in the Company’s Drug Free Workplace Program, dated April 18, 2005. New team members will be asked to review and sign the Company’s Drug Free Workplace Policy when they begin their employment. Present team members will be asked to review and sign the Policy on an annual basis. Team members working on certain government contracts may be subject to periodic random drug testing as required by regulations. Team members are required to notify Certified Slings & Supply® in writing within five days of any conviction for a violation of any criminal drug statute occurring in the workplace. In addition to disciplinary action that Certified Slings & Supply® might take regarding violations, the Company is required to report violations to the government.
Document Retention and Destruction. All team members must fully comply with Certified Slings & Supply®‘s document retention and destruction policies. It is a criminal offense to destroy documents that are subject to a subpoena or other legal process. Once a legal proceeding has begun, or when one is threatened or reasonably likely, Certified Slings & Supply® must preserve relevant documents even before they are requested. Any team member who fails to comply with this policy, as well as applicable laws, is subject to discipline including termination.
Cooperation With Government Investigators and Law Enforcement. The policy of Certified Slings & Supply® is to cooperate with government investigators, regulatory examiners, law enforcement officials, and non-governmental regulators with oversight of our business. All team members must cooperate with such authorities, as well as with internal Certified Slings & Supply® investigators. Failure to cooperate in such maters will result in disciplinary action including termination.
Commercial Contract Compliance Review. To assure compliance of Certified Slings & Supply®? contracts with the policies and standards of this Ethics Code, contract actions will be reviewed as follows:
- Commercial contracts will be reviewed by the Branch Manager, the Executive Vice President of Sales & Operations, the President and/or the Chief Executive Officer and as necessary, the Company?s legal counsel prior to execution.
Government Solicitation & Contract Review. To assure compliance of Certified Slings & Supply®? Government solicitations with the policies and standards of this Ethics Code, contract actions will be reviewed as follows:
- Federal Government solicitations, including written, verbal or e-mail, and contracts will be reviewed by the Government Contracts Administrator, by the President and/or the Chief Executive Officer and, as necessary, by the Company?s legal counsel prior to submission of a bid and execution of a contract.
- State and Local Government solicitations, including written, verbal or e-mail, and contracts will be reviewed by the Branch Manager, the Executive Vice President of Sales and Operations, the President and/or the Chief Executive Officer and, as necessary, by the Company?s legal counsel prior to submission of a bid and execution of a contract.
Certifications and Registrations. Written certifications or registrations for Federal, State or Local Governments and sub-contractors of government entities required by law or contract to be made by the Company shall be signed only by the President or Chief Executive Officer; or by such other appropriate team member as the President or Chief Executive Officer may authorize in writing. As necessary, certifications and registrations will be reviewed by the Company?s legal counsel prior to submission.
Obligation To Report. Team members are required to report any known or suspected violation of law, regulation, Company accounting, auditing, or internal controls, and this Ethics Code to the Compliance Officer, who can be reached by the following methods:
Phone: 321-239-0957 (Cell)
Inter-company Phone (Voicemail):
Corporate x1050
Tampa Office x1350
E-Mail: kvogt@nullcertifiedslings.com
Mail:
PO Box 180127
Casselberry, FL 32718-0127
Inter-company mail:
Place written information in a sealed envelope in your outgoing
branch mail: Attention Kim Vogt, Compliance Officer, Confidential
Team members also may report anonymously. There is a locked box at each Certified Slings & Supply® location, which will be checked by the Branch Manager on a weekly basis, and information in this box will be mailed to the Compliance Officer.
All matters brought to the attention of the Compliance Officer will be handled confidentially to the extent permitted by law and without fear of retribution against anyone who makes an honest report. Certified Slings & Supply® prohibits retaliation against anyone raising compliance issues or being involved in investigations. The Company is not permitted to fire, demote, suspend, harass, or discriminate against any team member who lawfully provides information to, or otherwise assists or participates in, any investigation or proceeding by a regulatory or law enforcement agency, or by the Company, relating to what the team member reasonably believes is a violation of law, ethical standards, or this Ethics Code. The same protection is afforded to a team member who files, causes to be filed, testifies, participates in, or otherwise assists in a proceeding filed, or about to be filed, relating to (i) an act of fraud, (ii) violation of the antitrust laws or regulations, (iii) violation of the False Claims Act or other federal procurement laws and regulations, or (iv) a violation of any wage or discrimination laws.
Consequences Of Violations. All matters reported by team members will be investigated, and all proven violations will result in disciplinary action. Violations of laws, regulations, Company policies including this Ethics Code can result in (i) reprimand, (ii) loss of compensation, seniority or promotional opportunities, (iii) demotion, or (iv) termination.
Each team member is responsible for ensuring that the Company’s conduct fully complies with the policies and standards governing Certified Slings & Supply®‘s business dealings with the federal government. Compliance, both personal and by subordinates, will be a factor in periodic performance appraisals.
Violations of laws and regulations relating to government procurement have particularly serious consequences. Obviously, Certified Slings & Supply® stands to lose contracts if its team members engage in such actions. Certified Slings & Supply® could also face criminal charges, major financial penalties and possible suspension or debarment from government business.
Liability does not end with the Company, however. An individual may also face criminal charges and penalties, including fines and imprisonment. Individuals accused of violations may have to bear their own legal expenses. Illegal conduct can also result in disciplinary action by the Company, including termination.
Acknowledgment Of Standards. As a condition of employment, all new team members and consultants are asked to sign the following acknowledgment:
I have read, understand, and agree to comply with the Certified Slings & Supply® Code of Business Ethics and Conduct (“Ethics Code”), which may be amended by Certified Slings & Supply® from time to time. I understand that if I violate this Ethics Code, I will receive disciplinary action up to and including termination. I also understand that I am responsible for reporting any violations of this Ethic Code to the Company’s Compliance Officer.
Current team members will also be asked to sign the acknowledgment, and team members will sign new acknowledgments whenever the Ethics Code is significantly revised and redistributed. The acknowledgment will be placed in each team member’s individual personnel file. Also, all suppliers are expected to comply with the principles of Certified Slings & Supply®‘s Ethics Code.
CONCLUSION
Certified Slings & Supply® is an organization consisting of many people. The individual and collective efforts of all Company team members will continue to determine its success and its reputation. The Company’s reputation for performance, integrity, and trustworthiness benefits not only the Company, but also each of its team members. Management recognizes that the contribution of each team member to the good name of the Company is meaningful and important, and pledges its full cooperation with all team members in the enforcement of this Ethics Code.