AXIOM RESOURCE MANAGEMENT, INC.
STANDARDS OF ETHICS AND CONDUCT
The reputation of Axiom as a fair, reputable, and honest organization can
only be maintained if all of its employees, officers, and partners adhere to high
ethical standards in conducting the Company’s business. The Company has adopted
standards to promote honest and ethical business conduct, and to reasonably deter
wrongdoing and inappropriate or illegal acts.
There is both a management and an individual obligation to fulfill the intent
of this policy. Any clear infraction of applicable laws or of prevailing business ethics
will subject an employee to disciplinary action, which may include reprimand,
probation, suspension, reduction in salary, demotion, or dismissal, depending on the
seriousness of the offense.
Moreover, disciplinary measures will apply to any supervisor who directs or
approves of such actions, or has knowledge of them and does not move promptly to
correct them. Appropriate disciplinary measures also will apply to any supervisor
who fails to carry out the managerial responsibility to ensure that employees are
informed about this policy.
The following pages contain a number of specific directives regarding our
company’s Code of Business Ethics and Conduct. We urge you to review these on a
regular basis so that you may incorporate them into you daily practices. If you need
guidance on particular circumstances that may arise, contact Human Resources for
assistance.
1.
PROFESSIONALISM
Employees are expected to conduct themselves in accordance with the
highest degree of integrity and honestly, with principles of good personal,
professional, and business ethics. Employees must treat fellow employees, our
customers, and the public with respect and courtesy, give accurate and honest
information of records appropriate for release, avoid misuse of time, property, and
resources and follow sound safety and accident prevention practices.
2.
BUSINESS GIFTS
Axiom employees are expressly prohibited from providing a Federal
employee and/or customer of Axiom with any gratuity, gift, favor, loan, or anything
of monetary value in accordance with Federal law and company policy. This
includes but is not limited any and all forms of business courtesies, such as
entertainment, meals, transportation, lodging, and promotional items.
3.
USE OF COMPANY OR CLIENT RESOURCES
This policy has been established to prevent personal use or misuse of
company or client time, property, equipment, and supplies. Employees are obligated
to represent Axiom in the best professional manner, befitting our role as a
contractor to clients.
Employees are expected to be at their worksites and performing their jobs
during their assigned work hours. Repeated instances of arriving late, leaving early,
taking extended breaks or lunch periods, conducting non-emergency personal
business, performing unauthorized professional activities that are not job-related,
or otherwise misusing the time for which the company or the client pays the
employee are not tolerated. Employees are expected to be equally careful in the use
of company and client property and to use it only for approved purposes.
3.1 Personal Telephone Calls and Mail
Keeping our telephone lines as open as possible is very important. Customers
call in requests, prospects make inquiries, people make contacts, and clients are
serviced through the use of company and client telephones. Employees are
requested to use the telephone for business calls only, except for emergencies.
If personal mail is sent in care of the company or a client, it is likely to be
opened with business mail. Therefore, to avoid inconvenience to both the company
or client and the employee, please have personal mail sent to your home. Axiom will
not be held responsible if an employee's personal mail is inadvertently opened.
3.2
Client Sites
Employees are requested to use the telephone, email, and web site for official
use only.
4.
TIMEKEEPING
Employees who file timecards must do so in a complete, accurate and timely
manner. Employees performing U.S. Government contracts must ensure that hours
worked and costs are applied to the account for which they were in fact incurred. No
cost may be charged or allocated to a Government contract if the cost is unallowable
by regulation or contract provision or is otherwise improper.
Employees are required to sign their own timecards. An employees signature
on a timecard is his or her representation that the timecard accurately reflects the
number of hours worked on the specified project or job order. The supervisor’s
signature is a representation that the timecard has been reviewed and that steps
have been taken to verify the validity of the hours reported and the correctness of
the allocation of the hours. Supervisors must avoid placing pressure on
subordinates that could lead them to believe that deviations from appropriate
charging practices will be condoned.
5.
FINANCIAL RECORDS
The records of Axiom are to be maintained in a manner that provides for an
accurate and auditable record of all financial transactions in conformity with generally
accepted accounting principles.
6.
REPORTING OF CRIMINAL CONDUCT
Axiom seeks to promote an organizational culture that encourages ethical
conduct and a commitment to compliance with the law. As such, employees are
encourage to exercise due diligence to prevent and detect criminal conduct in the
workplace. In the event that an employee has any complaints, concerns, or
suspicions regarding any conduct that may constitute a violation of federal criminal
law, including but not limited to circumstances involving fraud, conflict of interest,
bribery, or gratuity violations found in Title 18 of the U.S. Code or a violation of the
civil False Claims Act (31 U.S.C. § 3729-3733), the employee should promptly report
the concern to an Axiom Managing Partner or Human Resources. Suspicious
violations will be investigated under the supervision of Axiom Partners, as they
deem appropriate. Each employee of the company is expected to cooperate in the
investigation of the reported violation, and disciplinary action will be taken as
needed.
6.1
Kickbacks
All employees are prohibited from offering, soliciting, or accepting any kind
of kickback. A kickback is defined as any money, fee, commission, credit, gift,
gratuity, thing of value, or compensation of any kind that is provided for the purpose
of improperly obtaining or rewarding favorable treatment in connection with a
contract with the Federal government. Any employee who has reason to believe
another employee is engaging in offering, soliciting or accepting kickbacks should
report the conduct to an Axiom Managing Partner or Human Resources.
6.2
Whistleblower Protection
Axiom will not discharge, demote or otherwise discrimination against an
employee who reports criminal conduct in accordance with the requirements of the
Whistleblower Protections under the American Recovery and Reinvestment Act of
2009.
7.
PROPRIETARY INFORMATION
In the course of employment with Axiom, employees may be privy to trade
secrets or confidential or proprietary information including, but not limited to,
financial records, personnel records, information regarding business opportunities
and performance, and financial, contractual and special marketing information not
previously published or otherwise disclosed to the general public, and not normally
furnished to others without compensation, which Axiom desires to protect against
unrestricted disclosure or competitive use. All employees shall not disclose such
information to any person or firm, corporation, association or other entity for any
reason or purpose whatsoever or permit any legal entity or person affiliated with
the undersigned to use or disclose to others any such information, documents or
instruments. Axiom employees with valid security clearances who have access to
classified information must ensure that the information is handled in accordance
with applicable Federal procedures.
8.
CONFLICT OF INTEREST (COI)
Axiom expects its employees to devote their full working time and efforts to
the company’s interests and to avoid any activity that might detract from or conflict
with those interests.
8.1
Inappropriate Outside Influences
All employees must be free of outside influences that could cause them to
abuse company benefits, misuse company resources, or perform their jobs at a less
than satisfactory level. These outside influences include, but are not limited to, the
acceptance of gifts, kickbacks, or personal financial advancement provided by others
as a result of information about or activities affecting Axiom. All such situations will
not be tolerated and could lead to termination of employment.
8.2
Outside Relationships and Employment
During the course of the employee’s employment with Axiom, the employee
may not have any employment, consulting, or other business relationship with a
competitor, customer, or supplier of the company, or invest in any competitor,
customer or supplier (except for moderate holdings of publicly-traded securities).
Outside employment may also constitute a conflict of interest if it places an
employee in the position of appearing to represent the company, involves providing
goods or services substantially similar to those the company provides, or lessens the
efficiency, alertness, or productivity reasonably expected of employees. Any outside
employment that raises any questions in this regard must be approved in advance
by the employee’s immediate supervisor.
8.3
Disclosure of Personal Conflicts of Interest
All employees must disclose all personal conflicts of interest that may be
affected by a task to which the employee has been assigned, including: (i) financial
interests of the employee, his close family members and other members of the
employee’s household; (ii) other employment or financial relationships of the
employee (including seeking or negotiating for prospective employment or
business); and (iii) gifts, including travel. All employees must update said disclosure
whenever the employee’s personal or financial circumstances change in such a way
that a new personal conflict of interest might occur because of the task the
employee is performing.
8.4
Mitigation for Potential Work Related COI
In the course of your employment with Axiom, you may be assigned to a
specific procurement-sensitive position to support our clients. If this occurs, the
company may issue a specific instrument for you to be exempted from specific
reporting requirements to the corporation. This exemption would include
proprietary information of another company’s trade secret data. You will be
specifically granted complete confidentiality for your course of conduct and the
company will surrender all right of inquiry into the specifics of your duties
consistent with the concepts contained within 5 U.S.C. Sec. 552 and specifically (m)
therein. The purpose of this is to provide mitigation for the company, by
surrendering its right of inquiry, and to guarantee that no retaliatory action may be
taken against any employee who does not divulge such proprietary information.
8.5
Use of Proprietary Information for Personal Gain
Any employee that is provided with access to proprietary information by
reason of performance of a Government contract is prohibited from using such
information for personal gain.
9.
DISCLOSURE AND COMMUNICATION
Axiom has established an ongoing “Business Ethics Awareness and
Compliance Program” that serves to provide employees with periodic reviews and
updates of company’s business practices, procedures, policies, and internal controls
for compliance with Axiom’s policy regarding Ethics and Conduct. Employees must
review these materials and attend any training provided through this program.
10.
BID PRACTICES
Axiom prohibits its employees from violating the antitrust law provisions
contained in the U.S. Code, which are designed to ensure competition and preserve
the free enterprise system. As such, employees are prohibiting from engaging in an
agreement with one or more competitors to fix prices, an agreement with a
customer to fix a contract price, or any other form of bid rigging.
11.
CONTRACT NEGOTIATION
In the event that an employee is authorized to be involved in the contract
negotiation process, the employee must be accurate and complete in all
representations. A submission to the Federal government customer of a proposal,
quotation, or other document or statement that is false, incomplete, or misleading
can result in civil or criminal liability for the company, the involved employee, and
any supervisors who condone such a practice. Therefore, in negotiating contracts
with the Federal government, employees must disclose current, accurate and
complete cost and pricing data where such data are required under appropriate law
or regulation.
12.
EMPLOYMENT PRACTICES
It is the continuing policy of Axiom to afford equal employment opportunity
to qualified individuals regardless of their race, color, religion, sex, national origin,
age, or physical or mental handicap, and to conform to applicable laws and
regulations.
This policy of equal opportunity pertains to all aspects of the employment
relationship, including application and initial employment, promotion and transfer,
selection for training opportunity, wage and salary administration, and the
application of service, retirement, seniority, and employee benefit plan policies.
It is also the policy of this company to provide employees a workplace free
from any form of sexual harassment. Sexual harassment in any manner or form is
expressly prohibited.
12.1 Hiring of Federal Employees
Prior clearance to recruit, make offers to, or hire (as an employee or
consultant) any current or former Government employee (military or civilian) must
be obtained from the Human Resources Department.
13.
REPORTING VIOLATIONS
Employees are expected to report any suspected violations of this section
governing “Business Ethics and Conduct” to an Axiom Managing Partner or Human
Resources. Alleged violations will be investigated under the supervision of Axiom
Partners, as they deem appropriate. Each employee of the company is expected to
cooperate in the investigation of the reported violation, and disciplinary action will
be taken as needed. No adverse action or retribution of any kind will be taken
against an employee because he or she reports a suspected violation of this section.
Such reports shall be treated confidentially to the maximum extent consistent with
fair and rigorous enforcement of this section.