Business Ethics
Sallyport is committed to maintaining the highest standards of business conduct and ethics. As a substantial multi-national company, it has a diverse employee population, drawn from a variety of countries, cultures and business backgrounds. Although it encourages diversity, ingenuity and a ‘can do’ attitude, in terms of business conduct and ethics, it is unwaveringly uniform. Sallyport expects all employees, at all levels, to understand the code and apply it without exception to his or her conduct, behavior and business responsibilities.
Directors, executive management, managers and other supervisors are expected to develop in employees a sense of commitment to the spirit, as well as the letter, of the code. They are also required to ensure that all agents and contractors conform to code standards when working for or on behalf of Sallyport.
The code is a guide to Sallyport’s conduct, activities, and behavior in its day-to-day interaction with the various entities in which it has dealings; co-workers, clients, contractors, vendors, investors, governments, other authorities, and communities. Although it clearly cannot describe every practice or principle related to honest and ethical conduct, it nonetheless establishes Sallyport’s commitment to the highest ethical standards, and provides a template and a guide.
Sallyport works in austere, remote and sometimes politically sensitive environments, and although its core code is inflexible, from time to time, Sallyport may adopt additional policies and procedures with which its employees are expected to comply. Additionally, it is the responsibility of each employee to use common sense, together with his or her own highest personal ethical standards, in making business decisions where there is no stated guideline in the code or in Sallyport’s other policies and procedures.
Sallyport employs more than 2000 people from across the world. All are familiar, and regulated by the code. As a corporation, Sallyport takes its business conducts and ethics seriously, and is vigilant to contraventions. Should an employee violate the standards of the code, it will subject them to disciplinary action, ranging from reprimand, to termination of employment, and, in exceptional cases, civil legal action or criminal prosecution.
SUMMARY OF THE BUSINESS CONDUCT AND ETHICS CODE
- RESPECT FOR PEOPLE AND NONDISCRIMINATION
- LEGAL COMPLIANCE
- ENVIRONMENTAL COMPLIANCE
- RULES OF CONDUCT
- INTERNATIONAL BUSINESS LAWS
- ANTITRUST
- CONFLICTS OF INTEREST
- CORPORATE OPPORTUNITIES
- MAINTENANCE OF CORPORATE BOOKS, RECORDS, DOCUMENTS, AND ACCOUNTS
- FAIR DEALING
- GIFTS AND ENTERTAINMENT
- PROTECTION AND PROPER USE OF COMPANY ASSETS
- CONFIDENTIALITY
- MEDIA AND PUBLIC DISCUSSIONS
- WAIVERS
- COMPLIANCE STANDARDS AND PROCEDURES
Sallyport is an equal opportunity employer. It does not tolerate discrimination against applicants or employees based on race, religion, sex, age, marital status, national origin, sexual orientation, citizenship status, or disability. It is committed to providing a work environment that is free from discrimination or harassment of any type.
Sallyport’s success depends upon each employee’s operating within legal guidelines and cooperating with local, national and international authorities. It expects all employees to understand the legal and regulatory requirements applicable to their business unit and area of responsibility, and holds training sessions on all aspects of legal compliance.
Disregard of the law is not tolerated and violation of domestic or foreign laws, rules and regulations may subject an individual, as well as Sallyport, to civil and or criminal penalties. Sallyport will undertake internal and external audits as necessary, and will assist the authorities in the event of a government investigation or civil litigation.
Sallyport is committed to conducting its business in an environmentally responsible manner that minimizes environmental impact. It endeavors to minimize and, if possible, eliminate the use of any substance or material that may cause environmental damage. It attempts to reduce waste generation and dispose of all waste through safe and responsible methods, to reduce environmental risks by employing safe technologies and operating procedures, and stand ready to respond appropriately to accidents and emergencies.
Federal law imposes criminal liability on any person or company that contaminates the environment with any hazardous substance that could cause injury to the community or environment. Violation of environmental laws can be a criminal offense and can involve monetary fines and imprisonment. We expect employees to comply with all applicable environmental laws.
The Company requires that each employee or contractor must abide by Sallyport’s rules and regulations concerning professional appearance, smoking, liquor or drugs, gambling, violence, neglect of duty, conflicts of commercial interest, use of equipment, safety, and others.
All Sallyport employees are expected to comply with the applicable laws in all countries to which they travel, in which they operate and where they otherwise do business, including laws prohibiting bribery, corruption or the conduct of business with specified individuals, companies or countries. The fact that in some countries certain laws are not enforced or that violation of those laws is not subject to public criticism will not be accepted as an excuse for noncompliance.
Additionally, Sallyport expects its employees to comply with U.S. laws, rules and regulations governing the conduct of business by its citizens and corporations outside the U.S. This include: the Foreign Corrupt Practices Act, U.S. Embargoes, Export Controls, Anti-boycott Compliance, and others.
Sallyport employees are prohibited from all forms of price fixing, formal or informal agreements that harm competition or customers, the acquisition or maintenance of a monopoly or attempted monopoly through anticompetitive conduct. Employees are warned, and trained if necessary, to be aware of exchanging information, however insubstantial, with competitors, and to undertake all business or social interaction as if it were in public view.
Antitrust laws impose severe penalties for certain types of violations, including criminal penalties and potential fines and damages of millions of dollars. Sallyport periodically provides antitrust compliance training for employees in sensitive positions.
Sallyport expects all employees to be free from influences that conflict with the best interests of Sallyport or might deprive Sallyport of their undivided loyalty in business dealings. Even the appearance of a conflict of interest where none actually exists can be damaging and should be avoided. Conflicts of interest may concern competitors, employment, finance, contractor or suppliers, job performance, morale and others.
Sallyport requires that employees do not take personal advantage of opportunities for Sallyport that are presented to them, or discovered by them, as a result of their position in the corporation, or through their use of corporate property or information. This includes private opportunities if related to Sallyport lines of business.
The integrity of Sallyport’s records and public disclosure depends on the validity, accuracy and completeness of the information supporting the entries to its books of account. It is made clear to all employees that Sallyport’s corporate and business records should be completed accurately and honestly. The making of false or misleading entries, whether they relate to financial results or test results, is strictly prohibited.
It is mandatory that its books, records and accounts accurately and fairly reflect, in reasonable detail, the corporation’s assets, liabilities, revenues, costs and expenses, as well as all transactions and changes in assets and liabilities.
Sallyport strives to outperform its competition fairly and honestly. The corporation expects that advantages over its competitors are to be obtained through superior performance of its products and services, not through unethical or illegal business practices. Acquiring proprietary information from others through improper means, possessing trade secret information that was improperly obtained, or inducing improper disclosure of confidential information from past or present employees of other companies is prohibited, even if motivated by an intention to advance Sallyport’s interests.
Sallyport expects all employees to deal fairly with its customers, suppliers, employees and anyone else with whom they have contact with. Employees involved in procurement have a special responsibility to adhere to principles of fair competition in the purchase of products and services by selecting suppliers based exclusively on normal commercial considerations, such as quality, cost, availability, service and reputation, and not on the receipt of special favors.
Business entertainment and gifts are meant to create goodwill and sound working relationships and not to gain improper advantage with customers or facilitate approvals from government officials. Gifts cannot be offered, provided or accepted by any employee unless consistent with customary business practices and approved by the corporation.
These principles apply to Sallyport’s transactions everywhere in the world, even where the practice is widely considered “a way of doing business.” Employees are not allowed to accept gifts or entertainment that may reasonably be deemed to affect their judgment or actions in the performance of their duties. Sallyport makes it clear to its customers, suppliers and the public at large that its employees’ judgment is not for sale.
All employees are expected to protect Sallyport’s assets and ensure their efficient use. Property includes office supplies, computer equipment and software, records, customer information, manpower, logos and trademarks, physical plant and products.
One of Sallyport’s most important assets is its confidential information. Employees who have received or have access to confidential information are required to take care to keep this information confidential. Confidential information may include business, marketing and service plans, financial information, engineering and manufacturing ideas, designs, databases, configuration of Sallyport’s computer systems, customer lists, pricing strategies, marketing materials, personnel data, personally identifiable information pertaining to Sallyport’s employees.
In addition, because Sallyport interacts with other companies and organizations, there may be times when its employees are party to confidential information about other companies before that information has been made available to the public. All employees are required to treat this information in the same manner as they are required to treat Sallyport’s confidential and proprietary information.
It is Sallyport’s policy to disclose material information to the public only through specific limited channels to avoid inappropriate publicity and to ensure that all those with an interest in the company will have equal access to information. All inquiries or calls from Sallyport’s stockholders, financial analysts should be referred to the Chief Executive Officer or President. All media enquiries or requests to approach or respond to the media should be directed through Sallyport’s Media and Marketing department.
Any other form of public disclosure, whether through community forums, web forums, websites, or any other means, is similarly bound to be authorized and directed by senior management.
Any waiver of Sallyport’s Business conduct and ethics code for executive officers (including, its principal executive officer, directors, principal financial officer, principal accounting officer or controller, or persons performing similar functions, requires authorization by the board of directors or a committee of the Board, and will be disclosed as required by applicable laws, rules and regulations.
To facilitate compliance with this code, Sallyport has implemented a program of code awareness, training and review. In addition to fielding employee questions or concerns with respect to potential violations of this code, its supervisors are responsible for investigating possible violations, overseeing the training of new and existing employees, and updating the code as needed to reflect changes in the law, or Sallyport’s operational necessities.
