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IAP Worldwide Services, Inc. together with its subsidiaries and partners is committed to conducting business in accordance with all applicable laws, rules and regulations and the highest ethical standards.
IAP, its officers, directors, employees, and agents comply with all applicable anti-bribery or anti-corruption laws, rules and regulations in all of its operations worldwide, including without limitation the following important and overarching laws:
• U.S. Foreign Corrupt Practices Act of 1977, as amended (FCPA)• United Kingdom Bribery Act of 2010 (UKBA)• Anti-Kickback Act of 1986, 41 U.S. Code, Sections 51-58 (Anti-kickback Act)• Local Anti-bribery and Anti-corruption Laws• Anti-Money Laundering Laws
IAP’s Anti-Corruption Policy enhances our overall compliance program, strengthening IAP’s commitment and adherence to important law and regulations governing ethical standards of business conduct. IAP maintains a zero-tolerance policy against any form of corruption or bribery.
While IAP will seek to outperform our competition fairly and honestly, we will comply with the applicable antitrust and competition laws wherever we do business. Using illegal or unethical competitive practices or any other unfair-dealing to obtain competitive information or gain a competitive advantage is against Company policy and in violation of antitrust laws.
IAP recognizes its responsibility to prepare Cost Accounting Standard (CAS) Disclosure Statements that adequately describe its actual cost accounting practices. IAP acknowledges that it is also responsible to maintain disclosure statements that accurately reflect its current cost accounting practices and that the accounting practices must be compliant with applicable CAS.
The U.S. Government has adopted a Government-wide “zero tolerance” policy prohibiting human trafficking in Federal contracting. Employees working outside the U.S. shall comply with all general orders and military listings of off-limits notices prohibiting patronage at particular establishments.
All employees of IAP Worldwide Services, Inc., and its wholly-owned subsidiaries, must avoid any interest or activity that either creates, or appears to create, a personal or organizational conflict of interest. A conflict of interest occurs when the nature of the work performed conflicts with the personal or pecuniary interests of the Company or its employees, resulting in the Company or employee receiving an unfair competitive advantage, impairment in objectivity, or the potential inability to render impartial assistance or advice.
IAP is committed to maintaining a work environment that promotes diversity and is free of discrimination. All decisions regarding personnel matters will be made without regard to non-work-related factors such as age, race, religion, sex, national origin, genetic information (GINA), pregnancy, disability, veteran status, marital status, or sexual orientation.
This policy applies to all employees and job seekers with expressed interest in advertised employment opportunities, and to all aspects of the employment relationship, including recruiting, hiring, promotion, training, transfer, compensation, benefits, termination, and any other terms and conditions of employment.
Qualified job seekers and employees with disabilities who are able to perform the essential duties of the job with or without reasonable accommodations are extended equal employment opportunity consideration in all employment-related decisions regardless of disability or veteran status. Through an interactive dialog process with the job seeker or employee with a disability, IAP will evaluate requests for reasonable accommodations necessary for successful performance of the essential duties of the job. Reasonable accommodations will be provided to job seekers and employees unless the accommodation requirement creates undue hardship for IAP or its customer.
Employees or applicants who wish to register a complaint relative to this policy should contact their immediate supervisor, department manager, project manager, HR department, Employee Relations, or contact the Company’s Ethics Hotline at 877-296-8010 (U.S. and overseas) or at www.iapws.ethicspoint.com.
IAP Worldwide Services, Inc., is committed to delivering a drug free work environment, and is compliant with the federal and state regulations prohibiting unlawful possession, use, or distribution of illicit drugs or alcohol by employees on its property.
NO. 01-02.1; 9 JAN 2015
POLICY STATEMENT
At IAP, we believe that effective Environmental, Safety and Health (ES&H) management is good business and are committed to ES&H excellence. Continuous improvement drives our environmental, safety and health programs.
Our Policy is to comply with all applicable ES&H laws, regulations, and standards in all of our business activities. As an international Company, we are cognizant of, and comply with, host country laws applicable where we conduct business. Where adequate laws do not exist, we apply standards that reflect our commitment to excellence and injury prevention.
We consider ES&H factors in all business decision making in order to maintain balance and minimize risk. We are proactive and forward thinking in our activities and incorporate ES&H principles into all aspects of our business by setting and regularly reviewing ES&H objectives.
The ES&H aspects of our products and services are continuously evaluated. Our goal is to develop and provide products and services that have no undue environmental impact, are safe in their intended use, efficient in their consumption of energy and natural resources, and can be recycled, reused, or disposed of safely.
By working with our customers, subcontractors, and suppliers to improve the efficiency of our operations, we seek to conserve natural resources, prevent pollution, and reduce waste. Developing, using, and sharing good ES&H practices throughout IAP promotes the health and well-being of our employees, subcontractors, clients, and the communities in which we live and work.
We seek sustainable solutions to our needs and our clients’ needs by balancing ES&H, social, and economic considerations. We engage our employees, clients, partners, subcontractors, suppliers, and communities where we work to achieve continual improvement in ES&H performance.
Protecting the health and safety of our employees and the environment is a core and uncompromising value of our Company. All IAP personnel are held responsible for unconditional support of this value and this ES&H Policy.
This document contains trade secrets and proprietary information of IAP. Disclosure of this publication is absolutely prohibited without express written permission of IAP © 2015. Uncontrolled copy of an online document.
Employees shall conduct Company business consistent with applicable laws and regulations. We also strive for something greater; namely, following the Company core values of Respect, Responsibility, and Integrity in the conduct of the Company’s affairs. Consistent with these values, the Company shall establish and maintain an Ethics and Compliance Program (the “Program”) designed to prevent violations of law and enhance and promote ethical conduct. The Program shall include a Code of Ethics and Business Conduct and such implementing policies and processes as may be necessary. All Company directors, officers, managers, and employees, as well as representatives and certain other contractors, shall be bound by the Program at all times.
The Company and any of its wholly or partially-owned subsidiaries will comply with the U.S. Export Administration Act and the Export Administration Regulations promulgated thereunder; the Arms Export Control Act and the International Traffic in Arms Regulations regulations to implement international economic sanctions programs involving particular countries, including regulations promulgated by the Office of Foreign Assets Control of the Department of the Treasury. No business will be transacted nor item exported or imported that is inconsistent with this Policy.
As part of its global operations, the Company may use various business arrangements, including foreign sponsors, representatives, independent contractors, joint ventures, custom brokers, immigration agents, and tax agents to conduct operations.
Information Technology provides software and hardware to IAP Worldwide Services, Inc., employees to conduct the business of the Company. The flow of information between employees, customers, vendors, and suppliers is critical to conducting IAP’s business.
The Notification to the Government requirement ensures compliance with significant U.S. Government contract notification requirements. This policy applies to all business units for application to all US Government contracts.
Policy Requirements: Limitations of Cost or Funds, Notification/Consent to Subcontract, Notification of Changes in Subcontract Effort, Cost Estimating System Requirements, Various Government Approvals
All procurement actions performed by IAP must be conducted ethically, fairly, and in compliance with our Company’s Code of Ethics and Business Conduct program. Any suspected procurement misconduct must be promptly reported to leadership or the IAP Ethics Hotline at 877-296-8010 (U.S. and overseas), or at iapws.ethicspoint.com.
IAP is committed to deliver quality products and services on time that consistently conform to our customers’ requirements. IAP strives to exceed customer expectations and continually improve the effectiveness of our quality management system through customer engagement and monitoring established performance metrics.
As an employer and government contractor, IAP is subject to numerous laws and regulations that govern the way the company conducts business. The laws that regulate employees’ wages and hours are designed to ensure that employees are paid within these regulations.
Each employee has an affirmative duty to report violations to the Chief Compliance Officer by calling the confidential 24 hour toll-free Ethics Hotline, at (877) 296-8010.References include: Code of Ethics and Business Conduct Handbook, Timekeeping Booklet, Timesheet Charging and Reporting, Charging Practices, Indirect vs. Direct, WorkTech Guide,Ethics and Compliance Program, Code of Ethics and Business Conduct Compliance, Ethics and Compliance Program
Company funds are to be used only for authorized and bona fide business purposes. Management must approve, and is responsible for, controlling all expenditures of Company funds.
