Strategic Innovative Solutions – Ethics and Business Conduct
Strategic Innovative Solutions formally adopted a vision and values statement that acts as a
moral compass for the way we work within the walls of Strategic Innovative Solutions and
interact with our co-workers, our partners, our customers and our communities. As an
organization and individually, Strategic Innovative Solutions employees are responsible for
acting with integrity, treating others with dignity and respect, being honest and fair in all
transactions and consistently striving to “do the right thing.”
Strategic Innovative Solutions’ Code of Conduct provides a common point of reference for
Strategic Innovative Solutions employees.
Introduction
This Code of Conduct is Our General Statement of Ethical Business Conduct and a general
statement of our standards of ethical business conduct, based on our commitment to adhere to
Strategic Innovative Solutions’ values and comply with the law.
Strategic Innovative Solutions’ Core Values are as follows:
Fairness
Act with integrity on all occasions.
Treat each other with respect and dignity.
Be accountable for your actions and decisions.
Trust each other to make the right decisions.
Togetherness
Work together as a team to realize full potential.
Enrich the communities where we work and live.
Create lasting partnerships and productive relationships.
Passion
Work with unparalleled innovation and creativity to make a positive impact.
Have the commitment, confidence and ingenuity to impact change.
Have the passion and enthusiasm to sustain high level of achievement.
Growth
Pursue inventive thinking and take smart risks.
Reward innovation in every part of our business.
Be leaders, deliver superior quality and surpass goals.
The Values Statement includes a commitment to act with unwavering integrity on all occasions.
This includes an obligation to obey the law of the communities in which we do business. As a
consulting company conducting business in the United States, Strategic Innovative Solutions’
operations are subject to the laws of the United State government. We must comply with all
applicable laws, rules and regulations wherever Strategic Innovative Solutions does business.
While the Code of Conduct outlines our broad responsibilities, we also have more specific
guidelines and company policies for various activities. All company policies and the underlying
procedures established for business operations must be consistent with the standards of ethical
behavior outlined in the Code of Conduct. All employees are required and expected to comply
with the Code of Conduct, and with the laws and company policies that govern our activities.
To Whom Does the Code Apply?
Unless stated otherwise, the Code of Conduct applies to all Strategic Innovative Solutions
employees (including temporary, part-time, and seasonal employees). Those With Leadership
Roles Have Additional Responsibilities. Leaders should foster an environment of ethical
behavior by: acting as role models, demonstrating ethical behavior in the performance of their
own duties, making sure that employees understand that business results are never more
important than compliance with the standards for ethical behavior, ensuring that employees are
familiar with the standards for ethical behavior as outlined in the Code of Conduct, and the
company policies that are relevant to the performance of their duties, encouraging open
communication regarding business practices and ethical issues, acting to address incidents of
unethical behavior, including training, counseling and disciplinary action where appropriate, and
recognizing and rewarding ethical behavior.
Where Should We Turn For Guidance or to Raise Concerns?
When questions arise regarding the Code of Conduct, company policy or conduct that may
violate these standards, we should first consult our supervisors or the Human Resources
Department.
As an alternative, Strategic Innovative Solutions has additional policies and procedures in place
to raise concerns or report violations of the Code of Conduct or Company Policies. Employees
can choose to remain anonymous, but are encouraged to identify themselves and to provide as
much information as possible in order to facilitate an efficient and effective investigation of the
reported issue. All questions and concerns will be handled fairly and discreetly.
What Are The Consequences For Failing To Act Ethically?
Failures to act ethically and violations of the Code of Conduct and company policies can impact
Strategic Innovative Solutions’ business and reputation, and can have serious consequences for
all Strategic Innovative Solutions stakeholders, including employees, consumers, investors,
business partners and our communities.
Whenever Strategic Innovative Solutions becomes aware of a violation of the Code of Conduct,
company policy or the law, we will act to correct the problem and prevent future occurrences.
Depending on the circumstances, the corrective and preventive steps might include training,
counseling and disciplinary actions up to and including termination of employment and civil or
criminal prosecution. If anyone believes they are in a situation which they believe may violate or
lead to a violation of the Code of Conduct, company policy or law, we encourage them to follow
the guidelines detailed in our Ethics Training.
Conflicts of Interest
Employees and Executives must act in the best interests of Strategic Innovative Solutions,
without consideration for our personal interests or the potential for personal benefit. A conflict of
interest arises any time our personal interests (including relationships, investments or activities)
might affect our judgment as to what is in the best interest of Strategic Innovative Solutions, or
make it difficult to perform our work for Strategic Innovative Solutions objectively and
effectively. It is very important to consider the appearance of conflicts of interest, since
perceived conflicts can be as damaging to Strategic Innovative Solutions’ reputation as actual
conflicts. Strategic Innovative Solutions will be diligent in recognizing actual and potential
conflicts of interest.
Conflict of Interest Situations Commonly Faced by Employees
It is not possible to anticipate all situations which could present a conflict of interest, and only
some of the more common are listed here. Strategic Innovative Solutions may also at any time
require reporting by employees of activities that could present conflicts of interest.
1. Family Members and Close Personal Relationships
Jobs and work assignments will be awarded on the basis of qualifications, skills and
achievement, and not family or personal relationships. Work assignments involving employees
who are related, or who have close personal relationships, could lead to actual or perceived
favoritism, lack of objectivity and poor employee morale among co-workers. Employees will not
be eligible for employment in positions that could present a conflict of interest, such as a direct
reporting relationship.
Human Resources should be advised when a family or personal relationship between employees
could present an actual or perceived conflict.
2. Business Gifts and Entertainment
In some circumstances business gifts and entertainment can be used to strengthen business
relationships. However, in no event should a gift, favor or entertainment be accepted or provided
if it will obligate or appear to obligate the recipient as such gifts, favors or entertainment can
constitute commercial bribery and are illegal. Requesting or soliciting personal gifts, favors,
entertainment or services is unacceptable. In addition, we should not exploit our position at
Strategic Innovative Solutions to solicit vendors to provide individual preferential treatment in
pricing, terms or loans.
3. Gifts
When considering whether to accept or offer a gift or other business courtesy, we should use
prudent judgment and moderation. We should not accept inappropriate gifts from any person or
organization with whom Strategic Innovative Solutions does business or is in competition, and in
no event should we accept gifts that exceed $100 in value. We may accept gifts that do not
exceed (or that the recipient reasonably believes do not exceed) $100 in value from a single
source during any year and do not involve commercial bribery as discussed above. Gifts in
excess of this value should be returned to the sender with a letter of explanation. However, if it
would be impractical or discourteous to refuse a gift, the gift should be donated to charity
through Strategic Innovative Solutions Philanthropy Programs.
Accepting a gift of cash or cash equivalents (such as checks, savings bonds, stock or other
corporate securities) of any value is strictly prohibited. Certain gift certificates and gift cards that
allow the recipient to choose from a wide range of goods and services may be considered cash
equivalents. For this reason, employees should consult their HR representatives before accepting
a gift certificate or gift card.
We should not offer a gift unless it is a gift that is given as a common courtesy or gesture, is
customary business practice and is proper and reasonable in the circumstances. A gift should not
be offered if the gift would violate known customer business practice or could be deemed a
kickback or commercial bribery. Special restrictions apply to government officials in most
countries, and we should always consult the Legal Department before offering any gifts to any
government officials (see the discussion on Anti-Corruption Laws).
4. Entertainment
We may accept or provide business entertainment and meals that are reasonable in the context of
the business and advance the Company’s interests, for example attending a local cultural event, a
sporting event or a business meal with a business associate (such as a customer or a supplier).
However, accepting tickets to an event if the business associate will not also be present should
not be considered business entertainment, but should instead be considered a gift, subject to the
$100 limitation described above.
5. Outside Activities
6. Secondary Employment
Strategic Innovative Solutions expects the complete commitment of its employees, and therefore
discourages outside employment. We must obtain the approval of the Human Resources
Department before accepting a second job, commencing a business venture or personal project,
or agreeing to act as an advisor, consultant, officer or Executive under circumstances that may
conflict with our ability to fulfill our job duties or may raise a potential conflict of interest.
We must be sure the skills we learn and use at Strategic Innovative Solutions are not used in a
way that could hurt Strategic Innovative Solutions’ business. Providing services in any capacity
to an organization that competes with Strategic Innovative Solutions in any manner presents an
actual conflict of interest, and is prohibited. Providing services in any capacity to suppliers or
customers of Strategic Innovative Solutions will be closely scrutinized because of the high
potential for a conflict of interest.
7. Investments
Our personal investments should not influence, or appear to influence, our business decisions.
For example, if we are in a position to make decisions on behalf of Strategic Innovative
Solutions that could have a significant impact on the business of a supplier or customer, we
should avoid any investment in the supplier or customer of such value that it might affect, or
appear to affect, our business decisions regarding the supplier or customer. We should also avoid
any investment in a competitor which might affect, or appear to affect, our business decisions.
8. Serving Non-Profit or Community Organizations
Strategic Innovative Solutions supports non-profit or community organizations through
Philanthropy Programs with financial contributions, gift donations, organized volunteer
activities, volunteer engagements, or the use of Strategic Innovative Solutions resources.
Strategic Innovative Solutions encourages employees to participate in Strategic Innovative
Solutions’ Philanthropy Programs, and to support charitable organizations and our communities
generally, by taking an active role in volunteer activities. However, we should not allow our
volunteer activities to interfere with the conduct of Strategic Innovative Solutions’ business.
9. Use of Strategic Innovative Solutions Authority for non-Strategic Innovative Solutions
Purposes
When engaged in activities that are not related to Strategic Innovative Solutions’ business or
volunteer activities in support of Strategic Innovative Solutions’ Philanthropy Programs, we
should not use our position in Strategic Innovative Solutions in a manner that would lead
outsiders to believe that we are acting on Strategic Innovative Solutions’ behalf, or that Strategic
Innovative Solutions is actively involved in or sponsors these activities.
10. Seek Guidance and Assistance
We should discuss any questions about Conflicts of Interest with our supervisors and Human
Resources representative, and consult the Legal Department if necessary. Specific guidelines on
these and other common situations, as well as reporting requirements, are provided in the
Conflict of Interest Policy.
11. Corporate Opportunities
Employees and Executives should not compete with Strategic Innovative Solutions, or pursue for
personal benefit opportunities (for example, relating to products, inventions or investments) that
are discovered through the use of corporate property, information or position. We should not use
corporate property, information or position for personal gain. Employees and Executives should
seek to advance the legitimate interests of Strategic Innovative Solutions when the opportunity to
do so arises.
Our Responsibilities
Our Responsibility to Each Other
1. Respect
We will treat others as we want to be treated – with respect, dignity and fairness. We have the
right to work in an environment free from discrimination and harassment based on race, color,
religion, sex (including pregnancy, childbirth or related medical conditions), sexual orientation,
gender identity, national origin, ancestry, social origin, age, disability, marital status, veteran
status or other protected characteristics. We should respect our co-workers’ rights, and remember
that such discrimination and harassment will not be tolerated.
We should speak out when the conduct of a coworker makes us or others uncomfortable. We
each have a responsibility to report to Human Resources any such harassment or discrimination
that we experience or observe.
2. Diversity
Strategic Innovative Solutions recognizes diversity as an asset, and is committed to actively
seeking and promoting diversity in the workforce.
We value the different perspectives, insights and experiences of diverse individuals and cultures,
and we aspire to create a company culture that encourages an expression of, and a respect for,
diverse viewpoints. We provide equal employment opportunity for all applicants and employees,
without regard to factors such as race, color, religion, sex (including pregnancy, childbirth or
related medical conditions), sexual orientation, gender identity, national origin, ancestry, social
origin, age, disability, marital status, veteran status or other protected characteristics. We make
employment decisions to meet our business needs based on factors such as qualifications, skills
and achievement. We comply with local and national employment laws.
3. Employee Health and Safety
Strategic Innovative Solutions is committed to providing a safe, healthful and environmentally
responsible workplace, and has established safety programs to provide information and training
for safe practices in the normal conduct of business and for emergencies.
We are responsible for observing safety and health rules, for taking appropriate precautionary
measures and for reporting unsafe or hazardous conditions to our supervisors or Strategic
Innovative Solutions’ Security personnel.
In order to maintain our high standards for quality, productivity and safety, we should be in
suitable mental and physical condition at work. Possessing, buying or selling, using or being
under the influence of illegal drugs or engaging in any other activities which create an unsafe
work environment while on duty, or when on Strategic Innovative Solutions premises or
contractor work environments, are expressly prohibited. The consumption of alcohol while on
duty, working on Strategic Innovative Solutions’ contracts or when on Strategic Innovative
Solutions premises is prohibited except during approved Strategic Innovative Solutions social
functions, or during business meals.
Our Responsibility to Consumers
1. Product Quality and Safety
Strategic Innovative Solutions is continually building a reputation for quality and is amongst its
most valuable assets. Our commitment to quality is an integral part of our processes, and is
essential to the success of our business. We will meet or exceed legal requirements and industry
standards for quality. We strive every day to earn our consumers’ trust through our dedication in
these areas. Employees have an obligation to immediately report any concerns about quality to
Strategic Innovative Solutions’ Executive Leadership.
2. Client Information
We respect the confidentiality of client information consistent with all applicable privacy and
data protection laws and regulations. We do not share, sell or trade any private or sensitive
personal information obtained online without prior consent or unless compelled by legal process.
3. Advertising and Promotions
Strategic Innovative Solutions’ brand and product promotion activities should be conducted in a
manner consistent with applicable laws and with our reputation for honesty and integrity. We
adhere to high standards of commercial fairness in ads and promotions. We must accurately
portray the features, quality and performance of our products in all advertising media. We do not
misstate facts or provide misleading or deceptive information about Strategic Innovative
Solutions’ products and services, or the products and services of our competitors. We should be
diligent in safeguarding the reputation of Strategic Innovative Solutions by being selective about
promotional opportunities, such as event sponsorship and other joint promotions, avoiding
association of Strategic Innovative Solutions’ name with any product, service or activity which
might be considered unsafe.
Our Responsibility to Shareholders
1. Protecting Strategic Innovative Solutions Assets
All employees and Executives share in the responsibility to protect Strategic Innovative
Solutions’ assets, including physical assets, financial assets, intellectual property and proprietary
information from theft, loss, damage, misuse or waste. Those of us who have custody of
company property, such as vehicles and laptop computers, should take appropriate measures to
ensure their proper security and use.
Company assets should not be used for illegal purposes, or for personal benefit. (Except as may
be allowed in company-approved compensation arrangements). Incidental personal use of
company assets, such as telephones, personal computers and photocopying machines, is
permitted as long as such use does not interfere with the employee’s duties, is not done for
monetary gain, does not conflict with Strategic Innovative Solutions’ business and does not
violate any Strategic Innovative Solutions policy or applicable law. The security of computer
systems and electronic data should be protected by allowing access only by authorized persons,
and by properly using passwords.
2. Commitments and Expenditures
Strategic Innovative Solutions has established policies that grant authority and establish review
and approval requirements for commitments and expenditures. These guidelines apply to all
financial expenditures (including capital expenditures), and to all agreements that commit
Strategic Innovative Solutions’ resources and define its business activities. Licensing
agreements, joint venture or other strategic agreements, and contracts for the engagement of
services, investments, acquisitions, or the lease or sale of corporate assets are examples of
commitments subject to these guidelines. Only officers of Strategic Innovative Solutions
(generally those having a title at or above the Vice President level) are authorized to enter into
agreements on behalf of Strategic Innovative Solutions, and this authority is to be exercised only
in compliance with the guidelines. We are each responsible for being familiar with these
guidelines, understanding the scope of our authority, and ensuring that we do not make
commitments (including oral commitments) that exceed our authority.
3. Intellectual Property and Confidential Information
Strategic Innovative Solutions’ intellectual property, including trademarks, trade names,
copyrights, patents, software (code), internet domain names and similar rights or interests are
among its most important assets. Improper use of intellectual property in advertising, packaging,
correspondence and contracts can erode Strategic Innovative Solutions’ rights. Questions
regarding the proper use of Strategic Innovative Solutions’ intellectual property should be
referred to the legal department.
Confidential information is any information not generally known to the public that is useful to
Strategic Innovative Solutions, that would be useful to its competitors or other third parties or
that would be harmful to Strategic Innovative Solutions or its customers if disclosed.
Confidential information includes revenue and profit information and projections, information
regarding potential acquisitions, divestitures and investments, new product information,
marketing plans, design and development efforts, manufacturing processes, and other trade
secrets.
Employees and Executives should not discuss confidential information with those who are not
obligated to maintain the information in confidence or in public places where the information is
not likely to be kept secret, such as planes, restaurants and elevators.
In view of the competitive nature of Strategic Innovative Solutions’ business and the significant
impact of the theft or unauthorized use of Strategic Innovative Solutions’ intellectual property on
Strategic Innovative Solutions’ business and consumers, the protection of Strategic Innovative
Solutions’ intellectual property is one of the most important responsibilities of employment with
Strategic Innovative Solutions. This obligation continues even after employment ends.
Strategic Innovative Solutions recognizes and respects rights in intellectual property and
confidential information owned by third parties. Strategic Innovative Solutions’ employees
should protect the confidential information of third parties from theft, misuse or unauthorized
disclosure with the same degree of care used to protect Strategic Innovative Solutions’
confidential information.
4. Accuracy of Company Records, Public Reports and Communications
Strategic Innovative Solutions is committed to provide full, fair, complete, accurate, timely and
understandable disclosure of information, including financial information. Financial books,
records and accounts must be maintained in reasonable detail, accurately reflect transactions and
events and conform to applicable legal and accounting requirements and to Strategic Innovative
Solutions’ system of internal controls. In order to fulfill our responsibility for sound decisionmaking, we require honest and accurate recording and reporting of business information and
transactions, including quality, safety and personnel data records, as well as financial
transactions and records. Falsification of any record or financial report, such as quality and
project information, time reports or expense reports, will result in immediate disciplinary action.
5. Recording and Retaining Business Communications
Communications (even those we may consider “private” or “personal”) may become public, so
all correspondence should be clear and accurate. We should avoid exaggeration, inappropriately
colorful language and derogatory characterizations. These guidelines apply to communications
of all kinds, including e-mail, text messaging and video conferencing.
Our Responsibility to Business Partners
1. Doing Business with Others
We are committed to expanding and improving Strategic Innovative Solutions’ business through
business alliances, including customers, suppliers, vendors, subcontractors, licensees, agents,
joint ventures, etc. We will build productive relationships with business partners based on
integrity, legal and ethical behavior and mutual trust. We seek to do business with customers and
suppliers who reflect the diversity of the worldwide community in which we operate.
Integrity, ethical behavior and mutual trust should be important criteria when evaluating and
selecting our business partners. We should seek to do business with parties who enjoy a history
of ethical behavior.
2. Fair Dealing
Employees and Executives should endeavor to deal fairly with Strategic Innovative Solutions’
customers, suppliers, competitors and employees. We should never take unfair advantage of
anyone through manipulation, concealment, abuse of privileged information, misrepresentation
of material facts or any other unfair-dealing practice.
3. Purchasing Practices
All suppliers should be treated in a fair, ethical and impartial manner. All decisions regarding
suppliers and vendors of goods and services should be made on the basis of factors such as
suitability, quality, price, and delivery. Individuals involved in the review and selection of
potential suppliers, vendors and services providers must be diligent in avoiding actions that
convey or imply that decisions will be influenced by favors or concessions, or by personal or
family relationships.
4. Government Agencies and Customers (Contracts)
There are special rules, restrictions and procedures for dealing with government customers
(including government-owned enterprises). Requirements may include enhanced disclosure
requirements in contract negotiations, special billing or shipping procedures or stringent
restrictions on gifts, travel and entertainment which can be offered to government employees. All
statements and representations to government procurement officials must be accurate and
truthful. Strategic Innovative Solutions will comply with all governmental rules and regulations.
In special circumstances, these may often supersede our own internal rules and regulations.
Our Responsibility to Fair Competition
1. Gathering Competitive Information
Strategic Innovative Solutions does not seek to obtain competitive information by illegal or
unethical means, and we do not knowingly use any information obtained in this manner.
If we find ourselves in possession of information that may have been obtained in an illegal or
unethical manner, such as information provided to us in breach of a confidentiality agreement,
we should immediately inform the Legal Department and should turn the information over only
to a member of the Legal Department staff, without showing it to or sharing it with other
Strategic Innovative Solutions employees.
2. Fair Competition and Antitrust
Strategic Innovative Solutions competes aggressively and fairly in each market in which it
operates and is dedicated to compliance with the applicable antitrust and competition laws in all
its worldwide activities and locations.
Antitrust laws are designed to prohibit agreements among companies that would fix prices,
divide markets, allocate customers, limit production or otherwise impede or destroy market
forces. We must strictly comply with the antitrust laws of all countries, states and localities in
which we conduct Strategic Innovative Solutions business.
In addition, we should generally avoid exchanging or discussing with any customer information
about another competitors pricing policies, product offerings, marketing strategies or any other
similar competitive information. We should always consult the Legal Department before we
agree to perform any category management services for a customer that may expose us to
confidential information about competitors’ pricing, product offerings, marketing strategies or
any other similar competitive information.
Membership in trade associations, while helpful to Strategic Innovative Solutions’ business, may
also inadvertently create opportunities for discussions that may be contrary to the antitrust laws.
If a prohibited subject comes up during the course of a trade association or other meeting, we
should leave the meeting and inform the Legal Department.
Our Responsibility to Communities
1. Community Service
Strategic Innovative Solutions is committed to improving the communities in which it operates
through Philanthropy programs supported by Strategic Innovative Solutions and accomplished
by voluntary efforts of Strategic Innovative Solutions employees. As a company, Strategic
Innovative Solutions works to improve the lives of citizens in need through a variety of efforts,
including corporate financial and product contributions, organized employee volunteer activities
and through programs administered by the Strategic Innovative Solutions.
2. Environment and Sustainability
Strategic Innovative Solutions is committed to protecting the health and safety of its employees,
as well as minimizing our impact on the environment.
3. Communication to the Media
In order to ensure that the information provided to the public is accurate and consistent, all
communications to the media should be coordinated with the Executive Team. We should not
engage in conversations with the media without prior authorization from the Executive Team,
and if contacted by a member of the media should refer inquiries to them.
Our Responsibility to Government and Compliance with the Laws
1. Employees and Executives must comply with all applicable laws, rules and regulations
wherever we do business.
When we have any questions or concerns about the legality of an action, we should seek
guidance from the Legal Department. Each of us has a responsibility to understand the legal and
policy requirements that may apply to our jobs or role.
Which law applies?
Strategic Innovative Solutions is a corporation organized in Florida of the United States. The
laws of the United States frequently extend to the operations of Strategic Innovative Solutions, as
well as to the business activities of Strategic Innovative Solutions employees wherever we live
and work.
The Code of Conduct has been written to promote compliance with the laws and regulations that
govern Strategic Innovative Solutions’ business. However, if compliance with the Code of
Conduct would bring us into conflict with applicable laws or regulations in any jurisdiction
where Strategic Innovative Solutions conducts its business, we must obey the laws and
regulations and notify the Legal Department of any such conflict as soon as possible. If any local
business custom or practice conflicts with the Code of Conduct, we must comply with the Code
of Conduct and notify our supervisor of any such conflict as soon as possible.
2. Political Activity
Strategic Innovative Solutions’ funds and resources, including personnel, facilities and
inventory, should not be used directly or indirectly to make a political contribution to any elected
official, political candidate or party or for campaigning, fundraising or any other political
activity, without required approval according to Strategic Innovative Solutions policy.
Political activities by corporations, including lobbying, are subject to detailed restrictions under
U.S. law. In order to avoid any inadvertent violation of the laws which control these activities, all
political and lobbying activities should be discussed and coordinated in advance with the
Executive Team.
Voluntary personal contributions to candidates, parties and civic organizations are encouraged
and are consistent with Strategic Innovative Solutions’ commitment to citizenship and
community involvement. Our individual involvement must be totally voluntary and must be on
our own time and at our own expense.
3. Anti-Corruption Laws
We must follow the laws of the U.S. and other countries on bribery and improper payments to
government officials.
Bribery of or the offer or payment of money to public officials is absolutely prohibited. We
should not offer directly or indirectly anything of value to government authorities, including
political parties or candidates, to obtain an improper advantage, or to retain or obtain business.
No gifts, contributions, meals or entertainment are to be offered which might create an
appearance of impropriety. U.S. law also requires accurate books and recordkeeping so that all
payments are properly recorded.
We should also follow the laws of the U.S. and other countries that prohibit commercial
bribery. We should not give to our business partners any advantage including kickbacks or other
improper payments, gifts or favors as an inducement to do or forbear from doing something.
Because Strategic Innovative Solutions’ business partners (vendors, suppliers, licensors,
licensees, joint venture partners, etc.) may also be required to comply with these laws, we should
exercise proper due diligence in selecting our business partners and should avoid relationships
with parties with a history of corrupt practices.
Because of the complexity of the laws, and the severity of the consequences for violations of the
anti-corruption laws, the Legal Department should be consulted in advance for advice on
dealings with government officials including any proposed meals, travel or entertainment. We
should immediately report to the Legal Department any suspected violation of these
requirements.
4. Money Laundering
Money laundering occurs when individuals or companies try to conceal illicit funds or make the
source of such funds look legitimate. Strategic Innovative Solutions does not permit its
employees or resources to be used in money laundering activities. Strategic Innovative Solutions
complies with all U.S. and international laws against money laundering, which prohibit the
acceptance or processing of proceeds of criminal activities (e.g., drug trafficking, arms trading,
bribery, or fraud).
5. International Trade
The U.S. and other nations strictly regulate the import and export of products, materials,
services, information and technology. We should also comply with the customs and import laws
and regulations in all countries in which we do business. We should not transact business
directly or indirectly with countries, persons and entities which have been identified as
prohibited trading parties (e.g., sanctioned countries, businesses in sanctioned countries,
terrorists and nuclear proliferators).
We must comply with all applicable laws, regulations and restrictions on trade, and we should
contact the Legal Department with any questions.
Strategic Innovative Solutions will not cooperate with any restrictive trade practices or boycotts
prohibited or penalized under U.S. or applicable local laws, such as boycotts against countries
friendly to the U.S. (such as Israel) or blacklisted firms. Boycott-related requests must be
reported immediately to the Legal Department.
How to Get Help and Raise Concerns
General
When faced with an ethical decision, you should ask yourself these questions:
What is the ethics issue?
Start by identifying the problem – what is it about the situation that makes you feel
uncomfortable?
Is it a violation of Strategic Innovative Solutions’ Code of Conduct, Company Policy or the
law?
If it is, don’t do it. If you’re not sure, you should talk to your supervisor, your Human Resources
representative, or the Legal Department.
How will it affect Strategic Innovative Solutions’ stakeholders?
What is the impact on Strategic Innovative Solutions’ consumers, investors, fellow employees,
communities and other stakeholders?
How will this affect my reputation and the reputation of Strategic Innovative Solutions?
Are your actions consistent with Strategic Innovative Solutions’ values? Are you playing fair?
Would you feel comfortable explaining the situation to your family or the news media? How
does your conscience feel? What would a trusted friend advise?
If you have questions about the Code of Conduct, you should speak up, bring your concerns into
the open and ask for help. Strategic Innovative Solutions offers many resources to assist you in
obtaining answers to your questions. The first place to turn is to your immediate supervisor.
Other resources include the Human Resources Department and/or the Legal Department.
Taking action to correct problems
Taking action to correct problems is part of the Strategic Innovative Solutions culture. If you
observe conduct that you believe may be unethical, illegal or in violation of the Code of Conduct
or other company policies, you are encouraged to report your concerns to your supervisor, the
Human Resources Department or Legal Department. All reported concerns will be handled
promptly, fairly and discreetly. Employees must cooperate fully with any investigation that
Strategic Innovative Solutions undertakes and must answer truthfully any questions that are
asked as part of the investigation.
Retaliation is not tolerated
Retaliation toward any employee who in good faith reports an integrity or ethical concern or
issue will not be tolerated. Any employee who believes that he or she is being subjected to
retaliation for reporting an issue in good faith or assisting in good faith with a Strategic
Innovative Solutions investigation should report the matter immediately to the Human Resources
Department or the Legal Department.
Additional guidance
Because these guidelines are very general, it is possible that under unusual circumstances, the
Code of Conduct may not appear to provide complete guidance. You should always seek the
advice and agreement of the Executive Team before taking any action that would conflict with
the Code of Conduct. In addition, any waiver of any provision of the Code relating to any
Executive Officer must be approved, and will be promptly disclosed as required by applicable
laws or regulations.
Raising Concerns or Complaints about Accounting or Auditing Matters
Any employee may submit a good faith concern or complaint regarding accounting, internal
accounting controls or auditing matters to Strategic Innovative Solutions, without fear of
retaliation of any kind, in any of the following ways (these are general complaint procedures and
may vary from country to country due to local laws and regulations):
1. Contact an Officer: Employees with complaints regarding accounting, internal accounting
controls or auditing matters may report their complaints to the Legal Department – Audit, in
writing, by phone or via e-mail.
2. Employee complaints submitted in writing or by telephone may be made on a confidential and
anonymous basis. Due to technical constraints, e-mail submissions may not be made
anonymously.