Statement of Policy
Continuity maintains policies to guide its employees with respect to standards of conduct expected in areas where improper activities could damage the Company’s reputation and otherwise result in serious adverse consequences to the Company and to the employees involved. The purpose of this Policy is to affirm, in a comprehensive statement, required standards of conduct and practices with respect to certain types of behavior, business principles and ethical practices that must be observed and complied with at all times.
It is the policy of Continuity to conduct its business in accordance with applicable laws of the United States and other jurisdictions in which the Company operates, and in accordance with the highest ethical standards of business conduct. All employees shall adhere to this policy and conduct the Company’s business with integrity and fully comply with all applicable laws in a manner that excludes considerations of personal advantage or gain.
As the foundation of the Company’s business is based on trust, we have a responsibility to our clients to assure them that our employees will perform their duties in adherence to Continuity Code of Ethics and the policies contained within the Standards of Conduct.
STANDARDS OF CONDUCT
Honest and Ethical Conduct
The Company expects and requires its officers and employees to act in an ethical manner at all times. Each individual, as a part of his or her professional obligations, must perform his/her duties with honesty and integrity, and must promote honest and ethical conduct in others. All employees owe a duty of loyalty to the Company and are expected at all times to act in the best interest of Continuity.
Officers and Managers
All Officers and Managers of Continuity are responsible for the diligent review of practices and procedures of the Company to help ensure compliance with the Code of Ethics and to:
- Ensure that current and new employees participate in the education and training regarding this Code;
- Regularly stress to all employees the need for a commitment to the principles of this Code;
- Ensure that his or her department operates in accordance with the highest principles of business ethics;
- Ensure that their position within the Company is not used to give preferential treatment to another employee;
- Maintain a work environment that encourages open communications regarding the importance of operating under these principles and reinforce the lines of communication available to employees to resolve concerns related to this Code.
Ethical Obligations of Employees with Financial Reporting Obligations
Continuity requires honest and accurate recording and reporting of information in order to make responsible business decisions. All of the Company’s books, records, accounts and financial statements must be maintained in reasonable detail, must appropriately reflect Continuity’s transactions and must conform both to applicable legal and accounting requirements and to Continuity’s system of internal controls.
All employees are responsible to report any concerns regarding questionable accounting or auditing matters that may come to their attention. This policy also applies to all operating reports or records prepared for internal or external purposes, such as contract proposals. False, misleading or incomplete information impairs Continuity’s ability to make good decisions, undermines trust in the long term and may in some cases be illegal.
The Company’s corporate finance and accounting departments bear a special responsibility for promoting integrity throughout the organization, and have a special role in adhering to these principles themselves in order create a culture throughout Continuity as a whole, that ensures fair and timely reporting of Continuity’s financial results and condition.
Compliance Procedures: Employees of Continuity are expected to act proactively, raising concerns about ethical issues, violations of this Code or governmental rules, laws and regulations. All reports shall be taken seriously. Generally, the Corporate Finance Department, working in conjunction with the Company’s President and the Chief Operating Officer and other appropriate parties, will investigate each allegation and, if substantiated, resolve the issue through appropriate corrective actions and/or discipline. Executive Management in conjunction with the appropriate participating parties will determine and implement appropriate corrective actions to improve processes involved.
Maintain Respectful and Dignified Work Environment
Continuity’s policy is to provide equal employment to qualified individuals regardless of race, color, sex, religion, national origin or age. Differences in backgrounds that each individual brings to the Company are to be respected. Current and prospective employees can be assured that the work environment at Continuity promotes fairness and equal opportunity in the employment process. At Continuity, equal opportunity is provided in all aspects of the employment process, including hiring, work assignment, promotion, transfer, termination, wage and salary administration and selection for training.
All Continuity employees are expected to treat fellow employees, clients, visitors, and all those they encounter, with professional respect and courtesy, regardless of their position, age, race, sex, disability or other differences of a personal nature. In addition, sexual harassment – physical, written or verbal – will not be tolerated in the workplace.
Continuity also provides a work environment that helps prevent discrimination against a qualified individual with a disability in respect to any offer, condition, or privilege of employment. All applicants and employees are assured that all information regarding disability will be kept completely confidential.
ETHICAL BUSINESS CONDUCT
Negotiation and Performance of Contracts
Continuity is committed to competing fairly and ethically for business opportunities. Employees involved in the negotiation of contracts must ensure that all statements, communications and representations of fact to customer representatives are accurate and truthful. No employee shall submit, or concur in the submission of, any claims, bids, proposals or any other documents of any kind that are false, fictitious or fraudulent.
As a Government contractor, the Company is frequently required to provide cost or pricing data, together with a certification that such data are current, accurate and complete. Finance personnel in each operating group will ensure that employees involved in the negotiations are familiar and in compliance with this policy and that all labor costs are accurately identified and charged. Records of labor charges incurred, such as timecards, are a record of the Company and are no different than any other financial record. The Company has a firm commitment to accurate labor charging, and management has the responsibility to advise each employee of the procedures that must be used for proper labor charging.
Procurement
Procurement of needed supplies and services shall be conducted in a manner that fosters the highest ethical standards and services to our clients. Procurement actions will be based on: fair and impartial selections of capable and responsible sources of supply; maximum use of competition where practicable; selection of proper contract types; conformity with all applicable laws, regulations and contractual obligations and an effective system of monitoring procurement procedures and management controls to prevent fraud or other misconduct, such as subcontractor kickbacks.
Favors, Gifts and Entertainment (General)
Employees of Continuity are not permitted to give or receive valuable gifts (including gifts of equipment or money, discounts or favored personal treatment) to or from any person associated with the Company’s vendors or customers. The receipt or conveyance by an employee of a gratuity or gift of more than nominal value might easily be interpreted as affecting the impartiality of Company personnel and is therefore prohibited.
Continuity employees may accept entertainment, gifts, meals and refreshments of nominal value in connection with a business relationship, provided that each of the following criteria is observed:
- They are unsolicited; they are provided infrequently
- They involve reasonable, not lavish expenditures
- They do not create an obligation or expectation
- They take place in a setting reasonable and appropriate for the individuals involved and the business at hand
- And they are consistent with applicable law
Each employee must ensure that his/her acceptance of such favors is proper and could not reasonably be construed as an attempt by the providing party to secure or to reward favorable personal treatment.
This policy is not intended to preclude Continuity from making a gift to a company or organization provided that the gift:
- Is openly given with full knowledge by the company or organization
- Arises in the ordinary course of business
- Involves reasonable, not lavish, expenditures
- Does not obligate the recipient in any manner
- Takes place in a setting reasonable and appropriate for the individuals involved and the business at hand
- Is presented in a manner that clearly identifies Continuity vis a vis the occasion that warrants the presentation and is consistent with applicable law.
Such gifts should be consistent with Continuity’s business practices and should be of such a nature that does not jeopardize or impugn the Company’s integrity or reputation.
In rare circumstances, local customs in some countries may call for the exchange of gifts having more than nominal value as part of the business relationship. In these situations, gifts may be accepted only on behalf of Continuity, not an individual, with the approval of the Company’s Executive Management. Gifts may only be given in accordance with applicable laws, including the U.S. Foreign Corrupt Practices Act.
Favors, Gifts and Entertainment (Government Personnel): Federal, state and local government departments and agencies are governed by laws and regulations concerning their employees’ acceptance of entertainment, meals, gifts, gratuities and other things of value from firms and persons with whom they do business and over whom they have regulatory authority. It is the policy of Continuity to strictly comply with those laws and regulations. A gratuity may include any gift, favor, entertainment, hospitality, transportation, loan, or other tangible item or benefit for which fair market value is not paid by the recipient or the Government. The promise, offer, or delivery to an official or employee of a Federal, state or local government of a gift, favor or other gratuity in violation of these rules would not only violate Continuity’s policy but could also be a criminal offense.
In situations in which an agency’s rules permit its employees to receive certain types of business entertainment, meals or other items of value, these should not be extended unless it is first cleared by an employee’s supervisor and it is understood by both parties that the entertainment is not being offered to influence any official act performed, or to be performed, by the employee or the agency. In any event, Continuity employees should not offer such entertainment if it could be misconstrued and thus embarrass the Government and its employees, or the Company. If there is any doubt, it should not be done. Employees must fully document and record all approved expenditures for meals, refreshments, entertainment and gifts in strict compliance with the Company’s established policies and procedures.
Continuity’s policy also requires full compliance with the Procurement Integrity Act, which prohibits competing contractors and procurement officials from; soliciting, offering or accepting future employment or business opportunities; offering, giving, demanding or receiving any money, gratuity or other item of value; or soliciting, disclosing or obtaining protected procurement-related information during the conduct of a procurement.
Business with Foreign Governments
Continuity will comply with the U.S. Foreign Corrupt Practices Act, which prohibits the giving of money or items of value to any foreign officials to influence any of his/her official acts or decisions or to induce him/her to use his/her influence to affect any act or decision of his/her government, or one of its agencies, for the purpose of obtaining or retaining business. This act further prohibits giving money or items of value to any person or firm where there is reason to believe that it will be passed on to a government official for this purpose. Any questions regarding the application of the Foreign Corrupt Practices Act related to the providing of entertainment, meals or other items of value to government officials should be submitted to the Company’s Executive Management.
Competition and Fair Dealing
The Company seeks to outperform its competitors fairly and honestly. We seek competitive advantages through superior performance, never through unethical or illegal business practices. Stealing proprietary information or inducing disclosures by past or present employees of other companies is prohibited, as is using a third party’s proprietary information for any purpose other than it’s agreed upon use. All Continuity employees are to respect the rights of, and deal fairly with, Continuity’s customers, suppliers, competitors and employees. No Continuity employee is allowed to take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts or any other intentional unfair-dealing practice.
Protection and Proper Use of Company Assets: All Continuity employees are expected to protect the Company’s assets and ensure their efficient use. Theft, carelessness and waste have a direct impact on Continuity’s profitability. All Company assets should be used for legitimate business purposes only. Any suspected incident of fraud or theft should be immediately reported to Executive Management for investigation. Company equipment should not be used for non-company business, though reasonable incidental personal use is permitted.
The obligation of Continuity’s employees to protect Company assets include proprietary information, including intellectual property such as business and marketing plans, databases, records, salary information and any unpublished financial data and reports. This applies to proprietary data developed or purchased by Continuity, as well as to proprietary data pertaining to Government information entrusted to us by suppliers and customers. These restrictions apply irrespective of how the information exists, whether in written form, electronic form or simply known to us. The obligation of Continuity’s staff to protect such proprietary information is contained in the Employee Handbook that all new employees are required to sign.
All employees of the Company who have access to classified Government information have a special obligation to comply with Government laws and regulations that protect national security and safeguard our nation. Continuity employees possessing a valid and appropriate security clearance who require access to specific classified information must ensure that such information is handled strictly in accordance with applicable Government procedures. No one is permitted to seek access to, accept or retain any classified materials for which they do not have the necessary security clearance level and the “need to know”. While such information is in an employee’s possession, he or she must take all the necessary precautions to avoid unauthorized disclosure.
Government information that is classified, procurement-sensitive or source-selection-sensitive, or includes a competitor’s bid proposal information, shall not be accepted from any source, either directly or indirectly, in any circumstances where there is reason to believe the release is unauthorized.
Continuity employees who have access to proprietary and confidential information are obligated to safeguard it from unauthorized access in accordance with the Company’s confidential information policy.
Confidentiality
All Continuity employees must maintain the confidentiality of information entrusted to them by the Company or any third party, except when disclosure is either expressly authorized by Continuity or required by law. Confidential information includes all non-public information, including information that might be of use to competitors, or harmful to Continuity or its clients if disclosed. It also includes, without limitation; financial information; offers and proposals and other transactions; information related to contract proposals; new contracts or the termination of existing contracts; and proprietary intellectual property information. Continuity employees may not disclose, reveal or discuss this information with persons outside of the Company, or use this information for their own direct or indirect benefit or for the direct or indirect benefit of any family member, friend, relative or other recipient of the information. Should any Continuity employee have a question as to whether certain information is considered confidential, he/she should consult with his/her Manager or Executive Management.
Corporate Opportunities
Employees of Continuity are prohibited from taking for themselves opportunities and using them for their personal gain that are discovered through the use of corporate property, proprietary information or position. All Continuity employees owe it to the Company to advance its legitimate interests when the opportunity to do so arises.
Compliance with Laws, Rules and Regulations: All employees of Continuity are expected to obey the laws of the cities, states and countries in which the Company operates, including without limitation, laws relating to Government contracting, campaign financing, civil rights, employment discrimination, health and workplace safety, foreign corrupt practices, foreign boycotts and taxes. No employee of Continuity should at any time take any action on behalf of the Company that he or she knows, or reasonably should know, would violate any law or regulation.
No employee may associate with individuals known or suspected to be involved in illegal drug trafficking or other criminal activity. Furthermore, no employee may knowingly or willfully communicate, furnish, transmit or otherwise divulge privileged, administratively controlled or classified information to an unauthorized person which reasonably could be expected to cause damage to the National Security Act of the United States or would adversely affect the accomplishment of our clients’ operation and mission, or would be contrary to law, regulation or public policy.
Conflicts of Interest
Conflicts of interest are generally prohibited as a matter of Continuity policy. Any associations, interests and business relationships that may cause an employee to act in ways that are not in the best interest of the Company or that might be perceived to cause divided loyalties, will not be permitted unless approved by the Company. A transaction between Continuity and an employee’s outside associations may be permitted only if it is first reviewed and approved by the Company’s Executive Management. If an employee becomes aware of a conflict of interest, or a potential conflict, he or she must bring the matter promptly to the attention of Executive Management.
A “conflict of interest” generally exists when a person has a direct or indirect personal interest in a transaction or situation that affects, or appears to affect, his or her judgment and interferes (or appears to interfere) in any way with the interests of the Company. Conflicts of interest also arise when an employee of Continuity, or members of his or her immediate family, receive improper personal benefits as a result of his or her position with Continuity.
ADMINISTRATION
Time Records & Expense Reimbursements
It is the responsibility of each and every employee of Continuity to complete and submit timecards, expense reimbursement forms, and all other administrative documentation expeditiously in accordance with Company policy.
Employees are required to assign job and or tasks designators to their work hours accurately and honestly in accordance with company policy. All Continuity Managers are responsible for reviewing and approving their staff’s time records and expense reimbursement requests, and to ensure all work hours and reimbursement expenses charged as billable items are accurate and appropriate, in accordance with the provisions of the contract to which they are billed.
Employee Safety
All Continuity employees are prohibited from bringing alcoholic beverages, controlled substances, or items considered contraband by Federal and/ or state laws, onto Company’s premises or into any facility to which they are assigned. Employees shall not use controlled substances that have not been properly prescribed by a licensed physician or properly obtained for the treatment of an illness or condition. Furthermore, the possession or use of any weapon on the premises of the Company and/or its clients, or while engaged in Company business, is strictly prohibited.
Violations of this policy are grounds for discharge or other disciplinary action, in accordance with the circumstances of the particular violation. Continuity’s primary objective is preventing violations and making clear that violations are neither tolerated nor condoned.
Disciplinary action will be taken not only against individuals who authorize or participate directly in a violation of the Policy, but also against;
- Any employee who may have deliberately failed to report a violation of the Policy
- Any employee who may have deliberately withheld relevant and material information concerning a violation of this Policy
- Any employee who fails to report to their supervisor any incident of personally being arrested, taken into custody, held for investigation or detained for questioning and
- The violator’s managerial superiors, to the extent that the circumstances of the violation reflect inadequate leadership and lack of diligence.
Reports and Periodic Reviews
Any employee of Continuity who is requested to engage in any activity which is contrary to this Policy will promptly report such information to the Manager to whom the individual reports, or, if the employee was so directed by the Manager, then to a member of Executive Management.
Any employee of the Company who acquires information that gives the employee reason to believe that any other employee is engaged in conduct forbidden by the Policy will promptly report such information to the Manager to whom the employee reports, or if the Manager is engaged in such conduct, then to a member of Executive Management.