For any business, as for any person, reputation is a priceless asset.
At ellwood Technology Incorporated (“eTI”) we value above all the reputation as a responsible company, with the highest standards of excellence. This must be earned, maintained, and safeguarded if our organization is to grow and prosper.
To maintain the trust and confidence our clients place in us, we must assess every decision and every action on eTI’s behalf in light of whether it is right, legal and fair. Ethical lapses at any level in the organization can quickly destroy that trust and confidence. This is all the more true given eTI’s close association with the legal profession and law enforcement. Both are highly sensitive to legal and ethical rectitude.
eTI operates internationally and must maintain a sterling reputation both inside and outside of its home base in Canada. Any lapse could have consequences that could threaten eTI’s very existence.
This Employee Code of Conduct (“Code”) is a roadmap to guide eTI employees to make decisions that meet the highest standards of integrity, professionalism, and ethical conduct. It has been carefully formulated by the eTI’s leadership and counsel. It sets out guidelines for conducting the business of eTI consistent with the highest standards of business excellence and ethics. It requires a higher standard than required by commercial practice or applicable laws, rules or regulations. Why? because eTI aims for the higher standard.
The Code is entitled “Employee Code”, but it applies to everyone – employees, directors, officers, contractors, consultants alike.
Thank you for your ongoing efforts on behalf of eTI, and for helping to establish and preserve our reputation as a responsible corporate citizen offering the highest level of service in IT support.
COMPLYING WITH THIS CODE
Complying with the Code is an essential condition of employment with and working for eTI. Every employee agrees to read and be bound by the Code. Every employee, as a term of his or her employment Agreement with eTI agrees to a set of binding terms and conditions in relation to the Code. (Please refer to your employment Agreement with eTI for details.)
Compliance with this Code is not only important, it is mandatory for all employees. By setting high standards as a condition of employment at eTI, we will continue to promote a culture of integrity and excellence. This will benefit us all, and contribute not only to our bottom line, but to the quality of our work experience at eTI.
SEEKING HELP & INFORMATION
As your employment Agreement with eTI makes clear, this Code is not a comprehensive rulebook. It does not and cannot address every situation you may face.
If you feel uncomfortable about a situation, or if you have doubts about whether you are complying with the Code: seek help. We encourage you to do so.
Contact your supervisor for help first. If your supervisor cannot answer your question, or if you do not feel comfortable contacting your supervisor, contact an eTI Principal.
Always act with fairness, honesty, integrity and openness. Respect the opinions of others. Treat all with dignity.
Act in accordance with all policies, standards, laws and regulations that apply to your work. Comply with both the letter and the spirit.
Provide a positive experience for those inside and outside eTI.
Promote the standards and objectives of eTI in all dealings. We aim to be the leader in our field.
Every eTI employee has the obligation to understand and comply with the relevant policies, standards, laws and regulations.
Take responsibility for your actions and decisions. Communicate honestly and promptly with your colleagues and superiors. Follow reporting lines to help resolve problems. Ensure that you do not exceed the authority of your position.
eTI pursues fair employment practices in every aspect of its business.
eTI employees must not harass or discriminate in any way (more below). They must not interfere with others’ freedom of association, privacy or collective bargaining rights.
Failure to comply with fair employment practices can result in civil and criminal liability against you and eEI, as well as disciplinary action by eTI, up to and including termination of your employment.
You should contact an eTI Principal if you have any questions about fair employment practices.
DISCRIMINATION & HARASSMENT
eTI believes in and is committed to a trusting, safe work environment, free from discrimination and harassment. Any act of discrimination or harassment is unacceptable.
Discrimination means intolerant behaviour towards individuals or groups. The intolerant behaviour may be direct, for example, denying people equal or fair treatment because of their colour, nationality or religion. It may be systemic, for example denying people equal or fair treatment because of culturally-biased tests. Individuals may discriminate. But there can be discrimination through systems and attitudes as well.
Harassment is either sexual or personal:
- Sexual harassment is any conduct, comment, gesture or contact of a sexual nature that is unwanted or unwelcome by any individual, or that might reasonably be perceived by that individual as placing a condition of a sexual nature on his or her employment or career development.
- Personal harassment is any verbal or physical discriminatory behaviour directed at an individual, that is unwanted or unwelcome and causes substantial distress in that person and serves no legitimate work-related purpose.
Discrimination and harassment occur on three levels:
- staff-to-public or client
- public or client-to-staff.
The prohibited grounds of discrimination and harassment include age, gender, marital status, ancestry, place of origin, citizenship, political affiliation, colour, race, creed, record of offences, ethnic origin, sex, pregnancy, family status, sexual orientation and handicap.
Examples of harassment and discrimination that are not tolerated in eTI are: verbal or physical abuse, threats, derogatory remarks, jokes, innuendo or taunts related to any grounds of discrimination and harassment.
eTI also does not tolerate the display of pornographic, racist or offensive
signs or images, practical jokes related to any grounds of discrimination and harassment, and unwelcome invitations or requests, whether indirect or explicit.
Employees have a responsibility to:
- ensure the eTI work environment is free from harassment and discrimination;
- refrain from engaging in any behaviour that is reasonably perceived as harassment or discrimination;
- report incidents of harassment and discrimination or retaliation.
An employee who feels he or she, while performing job responsibilities, has been harassed or discriminated against by an eTI employee or client, or by a member of the public, should:
- make his or her disapproval known to the harasser and request all offensive behaviour cease;
- maintain a personal written record of the nature of the alleged harassment or discrimination, including dates, times, nature of the behaviour, and names of witnesses;
- make a written complaint to their supervisor or a Principal of eTI as soon as possible. The supervisor or the Principal will investigate the complaint and, in consultation with the complainant, determine the appropriate response.
Any employee who violates eTI policy against harassment and discrimination will be disciplined in accordance with the seriousness of their actions. The penalty may include dismissal.
False harassment or discrimination charges will not be tolerated. An employee found to have fabricated a charge will be disciplined. The penalty may include dismissal.
All harassment and discrimination complaints and investigations will be handled as confidentially as practical and appropriate, in the circumstances. eTI will make every reasonable effort to safeguard the confidentiality of all records relating to complaints and investigations.
ALCOHOL & DRUGS
eTI is committed to maintaining a workplace free of drugs and substance abuse.
Alcohol: Drinking or being under the influence of alcohol is prohibited while on duty or on eTI premises, except at eTI sanctioned events.
Drugs: Possessing, using, selling or offering illegal drugs and other controlled substances is prohibited under all circumstances while on duty or on eTI premises.
The safety and security of eTI employees is a top priority. eTI will not tolerate violence or threats of violence in, or related to, the workplace.
Employees who experience, witness or otherwise become aware of a violent or potentially violent situation on eTI’s property, or that affects eTI’s business, must immediately report the situation to their supervisor or to an eTI Principal.
eTI does not permit any weapons of any kind on eTI property or vehicles, while on the job or off-site on eTI business. This applies even if you have legal permits to carry weapons. The only exception is for security personnel specifically authorized by eTI management to carry weapons.
ENVIRONMENT, HEALTH, AND SAFETY
eTI is committed to providing a safe and healthy working environment for its employees and to avoiding adverse impact and injury to employees, the environment and the communities in which we do business.
eTI employees must comply with all applicable environmental, health and safety laws, regulations, policies and standards. It is your responsibility to understand and comply with the laws, regulations, policies and standards that are relevant to your job. Failure to comply can result in civil and criminal liability against you and eTI, as well as disciplinary action by eTI, up to and including termination of employment.
You are expected to understand and comply with all laws, rules, regulations, policies and standards that apply to your job position. If you have any doubts or questions, talk to your supervisor. If you have a concern about unsafe conditions or tasks that present a risk of injury, please report these concerns immediately to your supervisor.
ACCEPTABLE TECHNOLOGY USE POLICIES
As a technology-based company, eTI is dependent upon software, hardware, the Internet and multiple technology and communications platforms (collectively, “technology”), both for its day-to-day business and for the development and introduction of new products and services. So, it is essential that eTI protect and maintain the availability, integrity, confidentiality and security of its technology.
You must read and understand these acceptable use policies related to technology. If you have any doubts or questions, talk to your supervisor.
Passwords are a crucial part of security. A poorly chosen password may result in unauthorized and unlawful access to eTI’s resources. This could have disastrous consequences for eTI and its clients.
All employees are responsible for selecting and securing their passwords. All eTI employees must observe best practices for doing so, and ensure they have strong, protected, impenetrable and frequently changed passwords.
Your passwords must be long and complex, to deter brute force attacks by increasing the number of possible passwords. eTI passwords must meet these complexity criteria:
- your account name has three or more consecutive alphanumeric characters, delimited on both ends by white space (such as space, tab and return), or any of the following characters: comma (,), period (.), hyphen (-), underscore (_), or number sign (#)
- your password is at least twelve characters long
- it does not contain all or part of your name
- it contains a mix of characters from all of these four categories:
- Latin uppercase letters (A through Z)
- Latin lowercase letters (a through z)
- Base 10 digits (0 through 9)
- Non-alphanumeric characters such as: exclamation point (!), dollar sign ($), number sign (#), or percent (%)
You must change your password at least every 365 days. Each password used to access a system or service in any way related to eTI must be unique. The same password must not be used on two separate systems.
Wherever it is possible to use multi-factor authentication (e.g. Office 365 and DropBox), you must use it. If the multi-factor authentication system is cumbersome and inhibits your work, eTI management may dispense the specific system you’re working on from multi-factor authentication, but the dispensation must be in writing.
Lists of passwords must never be stored in unencrypted form. eTI requires you to use the firm’s Enterprise version of Lastpass for all passwords.
HARDWARE AND SOFTWARE
eTI provides hardware and software to its employees to enable them to do their job, and to develop understanding of technology.
These resources are eTI’s property. They are to be used for eTI business. Employees have no expectation of privacy when using eTI resources, even if the use is for personal purposes.
You must use eTI-issued software strictly in accordance with its license agreement. Unless the license says otherwise, duplicating copyrighted software (except for backup and archival purposes approved by eTI) is a violation of copyright law. It will also be treated as a violation of this Code. To ensure compliance with software license agreements, these principles apply:
- all software used on eTI computers will be purchased through eTI approved procedures. Purchasing will be handled by an eTI Principal;
- all employees acknowledge they do not own software or its related documentation;
- employees will not make copies of software, or re-install or give it away to anyone, even within their own department, unless authorized in writing by eTI. Only an eTI supervisor or Principal can authorize copying software with volume licensing arrangements;
- eTI prohibits the unauthorized duplication of software. Employees wrongfully reproducing software will be subject to disciplinary action, including possible termination. They may also be subject to civil and criminal penalties including fines and imprisonment;
- employees who knowingly make, acquire, or use unauthorized copies of computer software licensed to eTI, or who places or uses unauthorized software on ellwood Associates Inc.’s premises or equipment will be subject to disciplinary action, including possible termination;
- the installation or use on eTI systems of software that is not directly related to the performance of employee’s duties or eTI business is discouraged. While an employee may choose to install non-copyrighted software on their systems at their discretion, this software must in no way affect the performance, speed or reliability of eTI computers, networks or resources;
- the installation of any security circumventing software, or resource intensive is strictly prohibited, without prior written authorization from an eTI supervisor or Principal;
- if eTI in its sole discretion determines that any installed software is interfering with its systems, or is unauthorized, an eTI Principal may direct, without notice to any employee, that the software be removed partly or entirely;
- employees must have prior written authorization from a supervisor to use software at home. In such cases, eTI will make available or buy an additional software copy or license. Such additional copies or licenses for home use are the sole property of eTI. Every employee undertakes to safeguard and return the software to eTI when not in use;
- employees who suspect or become aware of software misuse must notify their supervisor immediately.
You may use your own hardware (BYOD in the industry jargon,) or software, or you may use eTI software on your own hardware. Every practice and policy that applies to eTI hardware and software, applies to your hardware and software, if you use it for eTI business. Employees have no expectation of privacy when using their own hardware or software for eTI purposes.
To maintain the highest level of security, integrity and compliance, and to guarantee eEI, its employees and clients the highest level of security, integrity and compliance:
- eTI reserves the right, and you agree that eTI has the right, to inspect fully, without notice, any hardware or software eEI has given you, and any hardware or software you use in your work for eTI, including your own hardware or software;
- when eTI feels it is necessary to do so, in its sole unfettered discretion, and by any means it deems necessary, eTI can look at and monitor the contents, regardless of medium, of any hardware or software eTI has given you, and any hardware or software you use in your work for eTI, including your own hardware or software;
- you agree and voluntarily consent to give eTI immediate access to any hardware or software you use in your work for eTI upon request from eTI;
- if, for any reason, after being requested to do so, you do not or cannot give eTI access to hardware or software you use in your work for eTI, you hereby authorize eTI to take possession of your hardware in order to inspect it;
- you agree and voluntarily consent to giving eTI all your logins, passwords and all other tools and information necessary to access your hardware and software, immediately upon being asked by eTI to do so;
- you hereby authorize eTI to delete or wipe, remotely or by any means it deems necessary, the contents of any hardware you use in your work for eTI, when eTI feels it is necessary to do so, in its sole unfettered discretion.
Everyone using eTI systems must use multi-factor authentication (for example, Microsoft’s Two Step authentication process), unless it is not available. This applies regardless of how the system is accessed, be it from an internal system, or from a personal mobile or home computer.
eTI reserves the right to suspend your access to technology at any time, in its sole unfettered discretion.
eTI accepts that you may have some personal use of hardware and software. However, this personal use must be reasonable. It must not conflict with your work or duties, or with eTI’s business affairs. eTI reserves the right to decide, in its sole unfettered discretion, what is reasonable. At all times, eTI has the sole unfettered discretion to forbid your personal use of eTI hardware or software.
It is not possible to give precise examples of what is or is not reasonable personal use. In general, though, if you have any doubt about the acceptability of using of eTI hardware or software, talk to your supervisor.
EMAIL, NETWORK, INTERNET, AND INTRANET
eTI provides employees and certain other individuals with electronic mail (“email”), network, Internet and Intranet services.
These services are designed to improve service to eTI customers, enhance internal communications, and reduce paperwork.
eTI’s email, network, Internet and Intranet access are for business use only. Employees may access these services for personal use during non-working hours, and during work-hours only if such access, in eTI’s sole judgement, does not adversely affect eTI productivity or resources, and complies strictly with this Code.
Email sent through eTI systems is subject to these policies:
- Employees will exercise the utmost caution to ensure that they use the correct email address for their intended recipient(s).
- Employees will exercise the utmost care to adhere to the provisions of the Duty of Confidentiality in their eTI employment Agreement.
- Employees will use good judgment and attention to detail when sending or replying to an email that is going out to a listserv, message board, social media site or other public forum.
- Any work-related message sent by email, from any device whatsoever (computer, tablet, phone, or other device), to a recipient outside of eTI must contain the eTI standard signature as approved by your supervisor. This will include, at a minimum, the employee’s full name and contact information. eTI reserves the right to stipulate a mandatory signature to be attached automatically to any communications leaving the eTI servers.
- Employees will exercise the utmost caution when sending sensitive, privileged or confidential information electronically. External parties can intercept it. Information related to legal matters should be labeled as “Privileged and Confidential” and should not be forwarded or distributed without authorization from the sender or your supervisor.
- Proprietary, confidential, or trade secret information must not be posted to external sources.
- Employees will exercise sound judgment when distributing messages. Client-related messages must be carefully guarded and protected. Employees must also abide by copyright laws, ethics rules, and other applicable laws.
- Employees are prohibited from sending any of the following information by email, unless it is encrypted:
- social insurance numbers;
- any information which is prohibited to be disseminated by law;
- any internal corporate financial information, unless authorized in writing by an eTI Principal.
- Employees must not use the eTI systems to mass email anyone outside of the company, unless authorized to do so in writing by an eTI Principal, and, if authorized, they use the “bcc” (blind carbon copy) option.
- Employees must use professional and appropriate language in all their emails. eTI’s harassment and discrimination policies apply to emails. Employees are prohibited from sending or forwarding abusive, harassing, intimidating, threatening, discriminatory, or otherwise offensive messages via email. Any employee who sends such emails, as determined by eTI, will be subject to disciplinary action, up to and including termination.
- Employees are prohibited from sending or forwarding messages that disclose personal information without eTI authorization. This includes accessing, transmitting, receiving, or seeking confidential information about clients or fellow employees without eTI authorization in writing.
- Emails that are in any way malevolent (e.g. spam, phishing, chain, malware), must be deleted immediately, and must not be forwarded or replied to under any circumstances unless requested by supervisor. If in doubt, you should ask your supervisor.
- Employees are prohibited from using eTI systems to send emails soliciting for any purpose, without the written consent of eTI.
- Employees must use the standardized signature line in all their eTI-related emails
Every eTI employee expressly agrees that they will not allow any system used to access eTI email, network, Internet and Intranet to save the login and password information into cache. Where multi-factor authentication one-time/one application password is used on a device, you must ensure that device is secured with both a screen saver password which engages after no more than 30 minutes of inactivity and requires a password which adheres to the eTI password policy above to log back into the system.
All data in or on the eTI email, network, Internet and Intranet services is the property of eTI. By using eTI email, network, Internet and Intranet, you expressly waive any right to privacy. No data of any kind stored in or on the eTI email, network, Internet and Intranet services environment is private.
eTI reserves the right to monitor and inspect such data fully, without notice, regardless of medium, when eTI feels it is necessary to do so, in its sole unfettered discretion. If eTI asks you to do you, you must immediately surrender all data in your control or possession in or on the eTI email, network, Internet and Intranet services.
eTI reserves the right to disclose any data in or on its email, network, Internet and Intranet services to law enforcement agencies or other third parties without your consent. If that consent is required, your acceptance of this Code, as evidenced by signing your employment Agreement with eTI, shall be your good and sufficient consent.
eTI reserves the right to suspend your access to eTI email, network, Internet and Intranet services at any time, in its sole unfettered discretion.
CONFLICTS OF INTEREST
Everyone at eTI has an obligation to always do what’s best for the company and our clients.
When you are in a situation in which competing loyalties could cause you to pursue a personal benefit for you, your friends or your family at the expense of eTI or our clients, you may be faced with a conflict of interest. A conflict of interest can occur when an employee’s private interest interferes, or appears to interfere, with the interests of eTI.
All of us should avoid conflicts of interest and circumstances that reasonably present the appearance of a conflict.
When faced with a potential conflict of interest, ask yourself:
- Would this activity create an incentive for me, or be reasonably perceived by others to create an incentive for me, to benefit myself, my friends or my family, or an associated business at the expense of eTI?
- Would this activity harm my reputation, negatively impact my ability to do my job at eTI, or potentially harm eTI?
- Would this activity embarrass eTI or me if it showed up on the front page of a newspaper or a blog?
If the answer to any of these questions is “yes,” the relationship or situation is likely to create a conflict of interest. You should avoid it.
These are the areas in which conflicts of interest often arise:
- outside employment, advisory roles, board seats, and starting your own business;
- business opportunities found through work;
- friends and relatives / co-worker relationships;
- personal investments;
- accepting gifts, entertainment and other business courtesies;
- use of eTI products and services.
In each of these situations, the rule is the same – if you are considering entering into a situation that creates a conflict of interest, don’t. If you are in a situation that may create a conflict of interest, or the appearance of a conflict of interest, review the situation with your supervisor.
If you have a conflict of interest, or something that others could reasonably perceive as a conflict of interest, you must report it to your supervisor. Your supervisor will work with you to determine if you do you have a conflict of interest and, if so, how best to address it.
Although conflicts of interest are not automatically prohibited, they are not desirable and may only be waived by a Principal of eTI in writing.
Finally, remember: as circumstances change, a situation that previously didn’t present a conflict of interest may evolve so as to present one.
OUTSIDE EMPLOYMENT, ADVISORY ROLES, BOARD SEATS, & STARTING A BUSINESS
Avoid accepting employment, advisory positions or board seats with eTI competitors or business partners when your judgment could be, or could appear to be, influenced in a way that could harm eTI.
Additionally, because board seats come with fiduciary obligations that can make them particularly tricky from a conflict of interest perspective, you should notify your supervisor before accepting a board seat with any outside company.
Finally, do not start your own business if it will compete with eTI. If you leave eTI with the intention of starting a competing business, please review the restriction and conditions to which you agreed in your employment Agreement with eTI.
BUSINESS OPPORTUNITIES FOUND THROUGH WORK
Business opportunities discovered through your work here belong first to eTI, except as otherwise agreed, in writing, by eTI.
FRIENDS, RELATIVES/ CO-WORKER RELATIONSHIPS
Take great care when there is a potential or existing eTI business relationship involving your relatives, spouse, partner or close friends.
To be clear, just because a relative, spouse, partner or close friend is involved doesn’t mean there is a conflict of interest. However, if you are also part of the eTI business relationship, it can be very sensitive. The right thing to do in that situation is to discuss the relationship with your supervisor.
Finally, romantic relationships between co-workers can, in some circumstances, create an actual or apparent conflict of interest. If a romantic relationship does create an actual or apparent conflict, it may require changes to work arrangements or even the termination of employment of either or both individuals involved.
Developing or helping to develop outside inventions that:
- relate to existing or foreseeable eTI products and services,
- relate to your position at eTI, or
- are developed using eTI resources
may create conflicts of interest and be subject to the provisions of the Duty of Confidentiality in your eTI employment Agreement. They are also subject to the Intellectual Property in your eTI employment Agreement.
If you have any questions about potential conflicts or intellectual property ownership involving inventions or other intellectual property, please consult your supervisor.
Avoid making personal investments in companies when the investment might cause, or appear to cause, you to act in a way that could harm eTI.
ACCEPTING GIFTS, ENTERTAINMENT, AND OTHER BUSINESS COURTESIES
Accepting gifts, entertainment and other business courtesies from an eTI competitor or business partner can easily create the appearance of a conflict of interest, especially if the value of the item is significant.
There is more on this topic in 17. Gifts and Entertainment, below. If you have any doubts about any gift or courtesy, talk to your supervisor.
USE OF eTI PRODUCTS & SERVICES
Avoiding potential conflicts of interest also means that you should not use eTI products, services or information in a way that improperly benefits someone you know, or creates the appearance that you have conferred unfair advantage on a user outside of eTI.
It is crucial for the development of eTI that its employees be at the forefront of current technology, practices and trends in our business. Every employee should view Continuing Professional Development (“CPD”) as a key part of their duties and obligations. CPD enhances the work, professionalism and credibility of eTI and its employees.
CPD may be defined as the systematic maintenance, improvement and broadening of knowledge and skills, and the development of personal qualities necessary for the execution of professional and technical duties.
To encourage you to follow best CPD practices, eTI will lend you funds to pay for all CPD expenses on these terms:
- your supervisor must approve, in advance, the course or program you propose to take;
- you must provide eTI proof that you have passed and successfully completed the course or program;
- 12 months after the successful completion of the course or program, and not before, eTI will pay you 50% of the costs of taking the course or program, if you are still employed by eTI. This money will be used to pay down your eTI education loan;
- 24 months after the successful completion of the course or program, and not before, eTI will pay you the remaining 50% of the costs of taking the course or program, if you are still employed by eTI. This money will be used to pay down your eTI education loan;
- if you quit eTI or are terminated for cause, you will forego any CPD payment that has not yet been paid to you and you will owe eTI the balance outstanding in your education account;
- if you fail to pass and successfully complete a program, you alone are responsible for the cost and will immediately owe eTI any funds we advanced to cover costs associated with taking the course or program.
Go and learn.
Accurate and reliable records are crucial to eTI’s business. Our records are the basis of our billings, earnings statements, financial reports and disclosures. They guide our business decision-making and strategic planning. Company records include time dockets, work logs, travel and expense reports, electronic and paper communications, accounting and financial data, measurement and performance records, electronic data, and all other records maintained in the ordinary course of our business.
Be forthright and candid at all times. No employee should misstate or omit any material information from any eTI record. Exercise extreme care in maintaining records for and allocating costs.
Every eTI employee must keep complete, accurate and reliable records in all material respects. You are responsible for understanding and complying with our record keeping policy. Ask your supervisor if you have any questions.
COMPLIANCE WITH LAWS AND REGULATIONS
Each employee must comply with all laws, rules and regulations applicable to the regions in which eTI operates. These include, without limitation, laws covering bribery and kickbacks, copyrights, trademarks and trade secrets, information privacy, political contributions, antitrust prohibitions, foreign corrupt practices, offering or receiving gratuities, environmental hazards, employment discrimination or harassment, occupational health and safety, false or misleading financial information or misuse of corporate assets.
You are expected to understand and comply with all laws, rules and regulations that apply to your job position. If you have any doubt about whether a course of action is lawful, talk to your supervisor.
COMPLIANCE WITH ANTITRUST LAWS
Antitrust laws of Canada and other countries are designed to protect consumers and competitors against unfair business practices and to promote and preserve competition. eTI’s policy is to compete vigorously and ethically, while complying with all antitrust, monopoly, competition or cartel laws in all countries, states or localities in which eTI conducts business.
Violations of antitrust laws carry severe consequences and may expose eTI and employees to substantial civil damages, criminal fines and, in the case of individuals, prison terms. Whenever any doubt exists as to the legality of an action or arrangement, it is your responsibility to contact your supervisor promptly for assistance, approval and review.
GIFTS AND ENTERTAINMENT
The giving and receiving of gifts is a common business practice. Appropriate business gifts and entertainment are welcome courtesies designed to build relationships and understanding among business partners.
However, gifts and entertainment should not compromise, or appear to compromise, your ability to make objective and fair business decisions.
Extending or receiving occasional gifts having a maximum retail value of $250 as a gesture of goodwill is acceptable, unless prohibited by any policies of the company receiving or giving the gift. Gifts in the form of cash payments, services, or pleasure trips for an employee or their family members are not allowed, regardless of amount. Gifts in the form of tickets to sporting events and other forms of entertainment are not subject to the $250 limit. All entertainment worth more than $250 requires notification to a Principal of eTI.
It is your responsibility to use good judgment in this area. As a general rule, you may give or receive gifts or entertainment to, or accept it from clients or suppliers, only if the gift or entertainment would not be viewed as an inducement to or reward for any particular business decision. All gifts and entertainment expenses should be properly accounted for on expense reports. The following specific examples may be helpful:
MEALS AND ENTERTAINMENT
You may occasionally accept or offer meals, refreshments or other entertainment if:
- the items are of reasonable value;
- the purpose of the meeting or attendance at the event is business related; and
- the expenses would be paid by eTI as a reasonable business expense, if not paid for by another party.
ADVERTISING AND PROMOTIONAL MATERIALS
You may occasionally accept or give advertising or promotional materials of nominal value.
You may accept or give personal gifts of reasonable value that are related to recognized special occasions such as a graduation, promotion, new job, wedding, retirement, or a holiday. A gift is also acceptable if it is based on a family or personal relationship and unrelated to the business involved between the individuals.
GIFTS REWARDING SERVICE OR ACCOMPLISHMENT
You may accept a gift from a civic, charitable or religious organization specifically related to your service or accomplishment.
If you are working with eTI clients in or from other countries, you must be particularly careful that gifts and entertainment are not construed as bribes, kickbacks or other improper payments.
You should make every effort to refuse or return a gift that is beyond these permissible guidelines. If it would be inappropriate to refuse a gift or you are unable to return a gift, you must promptly report the gift to your supervisor. If you have any questions about whether a gift or something else of value is appropriate, contact your supervisor.
You should not exchange any gifts, gratuities or favors with, or pay for meals, entertainment, travel or other similar expenses for, any employees of the U.S. or Canadian, federal, state, provincial or local governments. If you have any questions, contact your supervisor.
Maintaining a professional, business-like appearance is important to the success of eTI.
Each employee projects the reputation of eTI. Part of this impression depends on each employee’s choice of dress.
So, eTI has a dress code. This allows eTI to present a unified image to our clients that reassures them they have employed a highly professional organization.
The eTI dress code policy can be broadly described as Business Casual or better. Employees must abide by this code.
Employees are expected to use good judgment and high standards in following this dress code.
Employees who fail to follow this dress code will be disciplined.
Contact your supervisor or an eTI Principal if you have any questions at all about the eTI dress code.
REPORTING VIOLATIONS OF THE CODE
All employees have a duty to report any known or suspected violation of this Code, including any violation of the laws, rules, regulations or policies that apply to eTI.
If you know of or suspect a violation of this Code, immediately report it to your supervisor. If you do not feel comfortable reporting the conduct to your supervisor or you do not get a satisfactory response, contact an eTI Principal directly.
All reports of known or suspected violations of the law or this Code will be handled sensitively and with discretion. Your supervisor and eTI will protect your confidentiality to the extent possible, consistent with law and eTI’s need to investigate your concern.
It is Company policy that any employee who violates this Code will be subject to appropriate discipline, which may include termination of employment. This determination will be based upon the facts and circumstances of each situation.
If your conduct does not comply with the law or with this Code, there may be serious consequences for both you and eTI. Employees who violate the law or this Code may expose themselves to termination of their employment, substantial civil damages, criminal fines and prison terms. eTI may also face substantial fines and penalties and may incur damage to its reputation and standing in the community.
POLICY AGAINST RETALIATION
eTI prohibits retaliation against an employee who, in good faith, seeks help or reports known or suspected violations of the law or this Code.
Any reprisal or retaliation against an employee who, in good faith, has sought help or filed a report will be subject to disciplinary action, including potential termination of employment.
WAIVERS OF THIS CODE
This Code is binding.
Waivers of all or part of this Code for eTI employees may be made only by a Principal of eTI, in writing.
This Code sets out general guidelines for conducting the business of eTI, consistent with the highest standards of business ethics. If you have any questions about the Code, please contact your supervisor or an eTI Principal.
This Code forms a part of your employment Agreement with eTI. You must follow it. eTI reserves the right to amend, supplement or discontinue this Code, without prior notice, at any time. It is your obligation to be aware of and familiar with the most recent version of the Code.
Thank you again for being part of the eTI team. We all look forward to growing together as a responsible corporate citizen offering the highest level of IT support.