Although SiS believes that personnel will be guided to the right decisions by their own personal values, discretion, and good judgment, sometimes a situation may not be clear. It is not always easy to determine the ethical thing to do in a business situation. Personnel must always consider how his or her behavior and actions affect the integrity, credibility, and reputation of the Company.
Accountability
All Company employees handle adherence to the standards of conduct set forth as per SiS Policies and Procedures that govern their employment. All Company employees are also responsible for raising questions that the standards set forth in this Code and other Company Policies and Procedures are not being met.
Anti-Corruption & Anti-Bribery
SiS is committed to conducting business ethically around the world. It is strictly against company policy to engage in or tolerate bribery or any other form of corruption. A bribe or kickback is giving or offering to give anything of value, such as a “facilitation payment,” to a foreign government official (including but not limited to Personnel of government-owned or controlled businesses, Personnel of public international organizations such as the World Health Organization, and candidates for political office) to get or keep business or to secure an improper business advantage. Broadly speaking, the Company prohibits any payment or offer or promise of payment that would violate the U.S. Foreign Corrupt Practices Act (“FCPA”), the UK Bribery Act (“Bribery Act”), or any anti-bribery or corruption law of a country where the Company operates. Compliance with the FCPA and other anti-corruption laws is an important element in the Company’s mission to support U.S. national security and foreign policy interests. It is company policy to compete on the merits of our performance, reputation, and value that we offer.
Unprofessional Behavior
Some of our personnel interact with members of the public or private citizens. Since individuals in the communities we serve may come to us for help, it is imperative that we uphold the SiS culture of respect and inclusion in all these interactions. Each of us plays an important part to ensure the work environment is one of acceptance and inclusion, one where everyone is respected, and one that fosters productive interactions. We expect personnel to conduct themselves professionally and, in a manner, consistent with our values always. Unprofessional behavior or conduct that negatively affects the Company’s business interests or reputation is prohibited.
Compliance Training & Awareness
SiS requires all personnel to take part and complete regular ethics and compliance training as assigned. These include but are not limited to Policies and Procedures that cover the following areas:
- Anti-Corruption & Bribery
- Anti-Retaliation & Whistleblowing
- Anti-Trafficking in Persons
- Delegation of Authority
- Conflicts of Interest
- Data Protection
- Drug, Alcohol, & Substance Abuse
- Employee Discipline
- Export Controls
- Firearms
- Harassment Prevention
- Human Rights
- Incident Reporting
- Political Activities & Lobbying
- Prevention of False Claims
- Records Retention & Management
- Risk Management
- Safety
- Third Party Due Diligence
- Use of Force
