Ethical Standards Policy
and
Compliance Training
Program
ISIS’ Ethical Standards Policy...
• Meet the Policy Document
• ISIS’ Published commitment
to:
your first documentTraining Program.
...andCreate
Compliance
Why an Ethical Standards Policy?
►Effective December, 2007, the Federal
Acquisition Regulation (FAR) was modified...
►FAR Part 3 now includes Subpart 3.10,
“Contractor Code of Business Ethics and
Conduct.”
►Contains requirements that mandate
government contractors performing contracts
of $5 million or more and with a PoP of 120
days or more to have an ethics policy and
training program, and a mechanism for
reporting violations.
►ISIS welcomes the opportunity to provide
guidance to its employees regarding ethical
conduct in the workplace. It is the right thing to
do.
Create your first document
ISIS’ Compliance...
• Create a written Ethical Standards Policy and Compliance Training
Program/Establish Awareness/Promote Compliance
• Create a Method of Reporting Ethical Misconduct or Abuse such as a
Hotline or Other Means
• Create and Display an ISIS Hotline Poster for Reporting Information, or
Use and Display an applicable Government Poster
• Create an Internal Control System for Appropriate Responses and
Solutions to Ethical Issues (Hotline and CAPA)
• As of June 30, 2008, Congress Enacted Legislation that will Require
Contractors to Report Violations of Federal Criminal Law, Violations of
the Civil False Claims Act, or Overpayments in Connection with
Awards of Covered Contracts and Subcontracts.
Create your first document
ISIS’ Ethics Officer
ISIS has a designated Ethics Officer to serve our employees
and to meet the criteria set forth by the government within
the Federal Acquisition Regulation pertaining to
government contractors’ ethics policies.
If a need
arises to
report an
Ethical
Standards
violation,
your anonymity
will be
Safeguarded.
Calls to the ISIS Ethical Standards
Hotline at 520-459-5012, ext. 52
are only accessible by the
Ethics Officer and Ethics staff person.
Corrective Action/Preventive Action
(CAPA) serves as the
ISIS’ Internal Control System
for Ethics issues.
CAPA Ethics Entries
are protected and anonymous.
yourKnoll,
first document
ISIS’ Ethics Officer Create
is Renee
Human Resources Manager.
Meet the document...
“ISIS Employees Do Not Lie, Cheat or Steal.”
A Simple Ethics Statement
Define these values...
Honesty - Truthfulness, Fairness,
Uprightness, Justness, Free from
Fraud, Unadulterated..
Integrity - The Possession of,
and Strict Adherence to, High
Moral Principles and Standards.
Respect - to Show Consideration,
Equality, and Thoughtfulness
toward Another.
Accountability - Purposefully
Exposing One’s Actions to Others
for Open Critique and Analysis.
Transparency - Clarity, Openness,
Hiding Nothing.
Create
your first document
ISIS’
Professional
Values
ISIS’ Employee Expectations...
Employee Conduct
Drugs and Alcohol
No ISIS employee, consultant, or applicant may
use, possess, sell, transfer, trade and/or offer
to sell alcohol, illegal drugs, or intoxicants
while on duty, while conducting business for
ISIS, while applying for an ISIS position, while
on ISIS property, or while operating ISIS
equipment, machinery, or vehicles.
ISIS’ Reputation
is the Sum
of our Employees’ Reputations.
Create your first document
Individuals who work
in a Company are the
Company.
What you do effects
how we do as a
business.
ISIS’ Ethical Standard: Professionalism
Professionalism:
ISIS employees shall not harass any person
while representing ISIS or while conducting
ISIS business.
ISIS personnel shall be respectful, truthful
and professional at all times during the
conduct of business.
Relationships
established and
nurtured through
ethical conduct and
truthful communication.
1
Harassment in any form of a fellow ISIS employee,
within or without the workplace, is prohibited.
2
ISIS requires that all personnel conduct interactions with
other employees, customers, government
representatives, suppliers, or any other individual or
entity with respect and common decency.
Create your first document
Harassment is...
Ø
Ø
Ø
Ø
Unwelcome conduct that is sexual in nature
Racial slurs
Threatening harm of any kind
Remarks regarding age, gender, disability, religion, or sexual orientation
RESPECT
Create your first document
Trustworthiness
ISIS’ assets may not
be utilized for
personal benefit.
ISIS shall maintain
trust, confidentiality
and loyalty to her
customers and
business associates.
Company Assets
ISIS employees may not misuse
company property or assets for
personal benefit or gain. Email, printers,
copiers, telephones, computers, the
Internet, vehicles, and all other
ISIS property and electronic media may not
be utilized for anything other than
company business.
ISIS personnel are obligated to protect
customer and company data, and sensitive
information, from unauthorized distribution
or misuse.
(See also Security and Insider Trading
under Government Contracts and
Business Activities.)
Create your first document
Loyalty to ISIS
As ISIS is loyal to its employees, ISIS’
employees are expected to be loyal as well.
Conflicts of Interest
ISIS employees are not allowed to
enter into situations which may
present a personal or
professional conflict of interest,
including acquiring financial
interests in competitors and
suppliers.
Outside employment that
conflicts with
ISIS’ business activities is also
prohibited.
Create your first document
Government Contracts and Business Activities
TINA
All ISIS personnel shall comply with the TRUTH IN NEGOTIATIONS ACT (TINA)
regarding all government contracting activities. The TRUTH IN NEGOTIATIONS
ACT is defined as “A public law enacted for the purpose of providing for full and
fair disclosure by contractors in the conduct of negotiations with the Government.
The most significant provision included in TINA is the requirement that contractors
submit certified cost and pricing data for negotiated procurements above a defined
threshold.” (http://www.lectlaw.com/def2/t063.htm)
Other Governance
All ISIS employees shall follow any regulations, rules and
laws that regulate government contracting. ISIS employees
shall not knowingly give inaccurate statements,
communications, representations, or untruthful information.
The acquisition of any information about competitors’ bids
or proposals most times is restricted and/or prohibited by
the Procurement Integrity Regulations and other statutes
and regulatory agencies.
Create your first document
G
A Gift...for me?
ratuities/Gifts in Domestic Business Interaction
Certain governmental regulations exist that guide contractors in their
relationships with government personnel and the giving/receiving of gratuities
and gifts. While there are nominal limits set on the acceptable
values of gifts, gratuities, services, entertainment and the like,
a good general rule of thumb is this:
Gratuities, gifts or any items of value that are exchanged with the intent, or
seemingly with the intent, to influence decisions regarding company business,
are prohibited.
There are specific and complicated guidelines for
U.S. Government employees regarding limits on
the value of gifts they may receive.
There are also laws that stipulate what you may
give and receive as gifts and items of value.
If you’re
doubt,
check it out.
Createinyour
first document
Would you please accept this gift...?
1 ISIS’ Ethical Standards Policy applies globally as
well as domestically.
2 Never offer improper gratuities or gifts to foreign
government officials.
3 Remember, if it even appears that you gave or
received a gift that is intended to influence an
official of a foreign government or any ISIS
business, it is forbidden.
Gratuities/Gifts in Foreign Business Interaction
ISIS employees shall not accept or give any items of value, gifts, services,
entertainment, gratuities, etc. intended to influence ISIS business activities
or a government official.
Create your first document
Would you like to work for ISIS?
Violating laws that
govern recruiting
current or former
government
employees may lead
to severe penalties for
the employee and
ISIS.
Hiring Government Workers
Laws and regulations exist that regulate the recruitment, employment
solicitation, discussions regarding hire, and employment offers for postgovernment employees, including military officers. It is best to leave
these activities in the hands of ISIS’ authorized Human Resources
employees to ensure ISIS abides by all required laws and regulations.
Create your first document
Accuracy in Reporting
Cost Recordation
Contracts, laws and regulations
mandate business financial
activities and records. Any misuse
or misappropriation of finances
shall not be tolerated. Costs shall be
charged to the appropriate contract
or account, no matter the status of
the budget. Falsifying time sheets,
charging direct costs to indirect
accounts, or knowingly charging
labor or material costs to the wrong
account shall not occur. Timesheets
shall be completed accurately and
on time, using correct hours and
charge codes.
Integrity Pays
Any failure to
maintain financial
integrity negatively
impacts ISIS’
professional
reputation and
customer confidence.
Know the culture you are in...
International Business Practices
ISIS employees working in foreign countries must comply with the
laws, rules and business regulations of those countries. They shall
also comply with all business regulations and personnel policies set
forth by ISIS, including those within the
Ethical Standards Policy and Compliance Training Program.
No form of trafficking in substances controlled by American law shall
be tolerated in foreign nations. There shall be no trafficking in
persons, no debt bondage, no involuntary servitude, and no other
crimes against people or property while under employment with ISIS.
Create your first document
Protect ISIS...
...and our customers!
ISIS’ employees are prohibited from
sharing information that is owned
by ISIS or any of the company’s
customers both during and after
employment with ISIS.
ISIS may be legally liable if
proprietary information is not
protected.
ISIS sometimes enters into legal
agreements with other entities to
disclose proprietary information,
but all employees are required to
confirm authorization before
releasing that information.
Do not share another company’s
proprietary information with ISIS.
Proprietary Information
can be
technical or non-technical.
Questions about Proprietary
Information
should be directed to your
Create your
first document
supervisor or the ISIS Ethics Officer.
Political Activities
Federal law does not allow corporations to directly or indirectly
donate services, corporate funds or material goods to a
candidate for federal office.
ISIS encourages all employees to engage in
the American political process. However,
employees must do so during their own
personal time and never during work hours.
Employees are prohibited from representing
ISIS in any lobbying efforts that have not
been internally approved, that follow all
applicable ISIS policies, and that comply with
all legal requirements, regulations,
registrations and reporting requirements.
Political party donations and donations to any
political organizations shall not be made by
an employee on behalf of ISIS.
Political party donations and donations to any political organizations shall not be made
Create your first document
by an employee on behalf of ISIS.
Is it Classified?
Security
Legal procedures are in place regarding
employees with security clearances and
their access to, and handling of,
classified information. All ISIS
employees are required to follow those
laws and guidelines.
ISIS’ vast majority of personnel have security clearances.
Know the laws that govern security procedures.
Always act with integrity.
Create your first document
Report Violations...
Anti-Trust
ISIS employees shall not engage in any
activities that violate United States anti-trust
laws. No agreements or understandings
with competitors to control or fix pricing, to
limit services, to boycott customers or
suppliers, or to earmark or set aside market
territories shall be tolerated. Any ISIS
employee with knowledge of such activities
shall report them immediately to the ISIS
Ethical Standards Hotline at 520-459-5012,
ext. 52 or to the Ethics Officer.
1 Never Enter into Agreements
or Understandings with
Competitors to:
Control or Fix prices
Target Customers or
Suppliers for Boycotts
2 Never Enter into Agreements or
Understandings with Customers to:
Create Divisions within a Competitive
Market by Allocating Territories or Markets,
and Limit Products or Product Lines.
Make the Sale or Purchase of Products
Conditional upon Not Doing Business with a
Competitor
Create your first document
Is it publicly known?
Insider Trading
Any information regarding the
award of contracts,
divestitures, business
acquisitions, the purchase or
sale of shares, or any other
trading information not known
to the public shall not be used
for an employee’s personal
monetary advantage,
especially in the event ISIS
becomes a public company. No
such information shall be
passed to outside parties
unless permitted by regulations
and laws, and authorized by
ISIS upper management.
Never speculate in securities with
knowledge affecting the subject
company’s business that is not known to
the public, and never pass the
information to another who has no needto-know.
Create your first document
Environmental Ethics Compliance
ISIS and its employees shall
make every effort to ensure
compliance with
environmentally safe
practices as they may apply,
including the recycling of
paper waste and the
efficient use of resources.
Create your first document
ISIS goes Green
Test your knowledge...
The following questions provide an opportunity to review your
comprehension of the information just presented. Answer each,
considering any scenarios that might present themselves during
your career with ISIS. If any issues are unclear, please ask or contact
your Ethics Officer at 520-459-5012, ext. 52 for clarification.
Knowing the difference
between ethical and unethical
behavior is easy. It is the
moral characteristic of sound
and consistent ethical
practices that sometimes
presents a challenge.
...and understanding.
Create your first document
Test Scenario 1:
I have received the ISIS’ Ethical Standards Training.
Do I understand it?
1. Have I received the ISIS Ethical
Standards Policy and Compliance
Training on-line?
2. Have I asked any questions I had, and
gotten sufficient answers, from our ISIS
Ethics Officer?
*The ISIS Ethical Standards Policy and Compliance Training booklet is available on the ISIS web portal for
Create your first document
your reference under Publications.
Test Scenario 2:
I’m aware of some issues that violate
the ISIS Ethical Standards Policy.
But I don’t really want to be a “snitch”
at work. It’s really none of my
business what someone else does,
is it?
Workplace ethics is everyone’s business and concern.
ISIS could be sued and criminally prosecuted if found to have knowingly
or negligently violated someone’s civil rights or pertinent local, state or
federal laws.
ISIS could lose contracts, and its reputation, because of violations
addressed within the ISIS Ethical Standards Policy.
Create your first document
Test Scenario 3:
I came across some information that obviously violates
our ISIS Ethical Standards Policy. Do I know who to
call to report it, or do I know what to do if I have a
general question about ethics in the workplace?
1. Contact the Ethics Officer for any
questions you may have.
2. Telephone the ISIS Ethics Hotline
at 520-459-5012, ext. 52 to anonymously
report an ethics violation.
The ISIS reporting process
ensures anonymity.
Create
your first
Call the ISIS Ethics
Hotline
atdocument
520-459-5012, ext. 52
Test Scenario 4:
I’m working in Qatar, so do I need to abide by the
ISIS Ethical Standards Policy here, too?
Are there geographical limits
regarding adherence to the
ISIS Ethical Standards Policy
for employees?
The ISIS Ethical Standards Policy
offers guidance regarding the reach
of the policy. Whether in-country or
out, as an ISIS employee, you must
adhere to the ethical standards set
forth in the policy.
Create your first document
Test Scenario 5:
This is the second time Bob, my co-worker, has arrived at work
smelling of alcohol and exhibiting slurred speech.
I like the guy and hate to get him in trouble.
What should I do?
¤
¤
Could Bob have an abuse or
addiction problem for which he
needs help?
Is this a safety or security
issue?
This very well may be a violation of ISIS Ethical Standards.
But beware. Some medical conditions and/or medications
can cause slurred speech and imbalance.
Create
your with
first document
Contact your Ethics
Officer
the information to be safe.
Test Scenario 6:
I‘m going to buy some stock in our prime contractor’s
company. My CEO told me in a confidential conversation
that they are selling out to Monopoly Contracting, but they
are keeping it really quiet. No one else knows about it.
My CEO and I are going to make a bundle!
We’re buying a lot of shares before all this goes public.
Is this employee’s
conduct in line
with the
ISIS Ethical Standards Policy?
No, the employee would be violating the Insider Trading laws
and become subject to criminal charges.
Create your first document
Test Scenario 7:
I need 150 color copies of a flyer my daughter made for her lost kitten.
May I use the ISIS color printer?
Is this compliant with the ISIS Ethical Standards Policy?
No. It violates the policy regarding the Use of Company Assets Policy.
Create your first document
LOST...
Test Scenario 8:
I would like to purchase a special gift for a government
employee who has assisted us with ISIS contracts,
above and beyond what was expected.
May I purchase a gift for him?
Question 1: Would it be perceived that the gift would be an
enticement to show ISIS favoritism for upcoming work?
Question 2: What are the statutory
monetary limits for a
gift given to a person
holding the particular
government position
your proposed recipient
holds?
There are specific guidelines that must be followed under certain circumstances.
To avoid legal problems, always check with your Ethics Officer first.
Create your first document
Test Scenario 9:
I would like to see a friend of mine, who is currently
employed by the government, come onboard with ISIS.
Should I speak with her now or should I let the
ISIS Human Resources personnel approach her first?
What is your best course of action according to the
ISIS Ethical Standards Policy?
Review the policy regarding
Recruiting Government Employees.
To be sure ISIS remains compliant with statutory
requirements, allow Human Resources to conduct
negotiations with potential employees
from the government arena.
Create your first document
Test Scenario 10:
ISIS sent me to DC for a business conference.
My hotel long-distance phone bills are never scrutinized.
I think I’ll take this opportunity to catch up with all my friends I
knew in Hawaii. My company will never know the difference,
and it will be great hearing all their voices again.
Is this compliant with the ISIS
Ethical Standards Policy?
Create
yourregarding
first document
No. It violates the
policy
Recording Costs.
Test Scenario 11:
There was a Security Breech last night at the SCIF
I’m assigned to. My supervisor said she isn’t going to
report it because she doesn’t want to get into trouble.
What should I do?
Is this compliant with the
ISIS Ethical Standards Policy?
No. It violates the policy regarding Security.
Report the Security Breech immediately.
Create your first document
Test Scenario 12:
I had lunch today with one of the contract
people over at Established Contract Systems.
She wants to team with us to go after the new
work everyone is talking about.
But she wants me to get our management
staff to promise we won’t ever team with
Monopoly Contracting before she will
agree to sign with us.
I’m not sure we can do that. Can we?
Is this compliant with the
ISIS Ethical Standards Policy
and federal Anti-Trust law?
No. It violates the ISIS policy and federal statutes regarding Anti-Trust activities.
Create your first document
Test Scenario 13:
I took some of our prime subcontractor’s proprietary
information on the DDIS contract down to the
printer to publish.
I think I’ll make my own copy and
take it to my cousin over at his contracting business.
It could help him with that project
he was asking me about.
Is this compliant with the ISIS Ethical Standards Policy?
No. It violates the policy regarding
Protecting Proprietary Information.
Create your first document
Test Scenario 14:
I’ve just begun to help raise funds for
my uncle who’s running for mayor. I
have about an hour before I get off
work. I think I’ll go ask all the ISIS
employees for donations to help him
get elected.
Is this compliant with the
ISIS Ethical Standards Policy?
Create your
first documentPolitical Activities.
No. It violates the policy
regarding
QUESTIONS....?
Is there anything you would like to ask?
?
Create your first document
The ISIS Ethical Standards...
Report
...H o t l i n e!
Suspected
Violations
of the
ISIS Ethical
Standards Policy
or any
Ethical Abuse or
Misconduct to:
• (520) 4 5 9 - 5 0 1 2, ext. #5 2
Your anonymity will be protected.