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ESI Acquisition Ethics & Anti-Bribery Policy

ESI’s foundation is based upon the trust which our clients and employees have in the performance and integrity of ESI. Such trust depends on the personal conduct and capability of our employees and their desire to jointly create value for our clients and business partners. The following principles represent the minimum standard for our agents and staff.

Conduct of Business

Our employees must comply with all applicable laws, rules, and regulations when conducting business. Our employees must conduct themselves with honesty, fairness, dignity, and integrity, and should avoid any conflict between private and business interests. Our employees should take care that they conduct themselves in their private life in a manner that does not bring ESI into disrepute.

Non-Discrimination

ESI does not tolerate discrimination or harassment in the workplace, based on criteria such as age, disability, ethnic origin, gender, race, political attitude, or workers’ representative activities, religion, or sexual orientation.

Confidential Information

The safeguarding of client related data is an important foundation for the trust of our clients. Confidential, sensitive information and records must be kept secret in a suitable manner from colleagues who do not require such data to properly perform their tasks. This applies equally to third parties. If someone without clear authority consistently tries to obtain confidential information, the involved persons must notify management. Management cooperates with all competent public and regulatory authorities.

The FAR mandatory disclosure rule mandates that government contractors disclose in writing all situations for which they have credible evidence of a potential violation of the civil False Claims Act or Federal criminal law involving fraud, conflict of interest, bribery, or gratuity. Should this arise, notify management who will report to the government.

Communication

All communications of ESI are required to be full, fair, accurate, timely, and understandable. The dissemination of information to the public including social media is to be handled by authorized spokespersons only or at the direction of the President.

Conflicts of Interest

Conflicts of interest can cast doubt on our integrity and professionalism. Potential conflicts of interests must be identified at the earliest reasonable opportunity to management. If they cannot be avoided, any conflict situation must be handled fairly. A conflict of interest occurs whenever our personal interests interfere in any way with our ability to perform our jobs objectively and in the best interests of the company. Members must therefore refrain from entering into relationships or transactions that might impair their judgment as to what is best for the company. Even relationships that create the appearance of a conflict of interest should be avoided. In addition, conflicts of interest cannot be circumvented by acting through someone else, such as a friend or family member. Any member who is presented with a transaction or relationship that could create a conflict of interest must bring the transaction or relationship to the attention of their manager.

No Corruption or Bribery

Bribery is the offering, giving, or receiving of anything of value with the intention of inducing a person to act or to reward a person for having acted. Items of value can include, but are not limited to: Cash and cash equivalents, Gifts, meals, entertainment, and travel, Political contributions, Charitable donations and Job offers.

Corruption includes the solicitation of a bribe, whether or not coupled with a threat of demand if refused. ESI does not tolerate any form of bribery or corruption. Irrespective hereof, situations may arise which do not constitute corruption or bribery but may allow the judgement of our members, clients, and business partners to be compromised. Members are prohibited from accepting any gift that may influence their judgment on company matters as it pertains to the donor.

Acceptance of Gifts and other Benefits

The acceptance of gifts and entertainment by members (including their family members) may present a conflict of interest. While members are permitted to accept gifts of nominal value, they are prohibited from accepting anything that might influence their judgment on company matters affecting the donor or that might be accompanied by any express or implied understanding that the recipient is in any way obligated to take some action that would benefit the donor, to the detriment of the company, in exchange for the gift. Similarly, members may accept entertainment, but only insofar as it is reasonable in the context of the business at hand and facilitates the company’s interests. When practical and appropriate, hospitality should be reciprocated. Members are strictly prohibited from soliciting gifts, gratuities, or business courtesies for the benefit of any family member or friend.

Protection of Company Assets

Safeguarding the company’s assets is the responsibility of all members. Theft, carelessness, and waste have a direct impact on the company’s profitability. Assets should be used efficiently and maintain such assets with care and respect, while guarding against waste and abuse. Look for opportunities to improve performance while reducing costs. The use of company time, materials, assets, or facilities for purposes unrelated to the company’s business, or the removal or borrowing of company property, is prohibited, except where such use or removal is for purposes of supporting the occasional community service activity that has been endorsed by the company and where such use or removal has been approved by a supervisor. For those purposes, the company’s assets include cash, inventory, equipment, computer software, computer data, vehicles, records or reports, non-public information, intellectual property, or other sensitive information or materials, as well as telephone, voicemail, or email communication.

Prevention of Money Laundering and Illegal Activities

ESI is fully committed to the international fight against money laundering and the financing of terrorism and applies a risk-based, “know-your-client” policy in line with applicable laws and regulations. Members must neither be engaged in nor tolerate any illegal activity in connection with ESI in their workplace. This applies in particular to any infringement of anti-trust regulations and any support of tax evasion, including but not limited to, any kind of complicity in tax fraud. Consequences of Non-Compliance Failure to comply can expose members and ESI to reputational as well as legal and regulatory sanctions. Disciplinary proceedings by a regulatory body in the case of severe compliance misconduct may result in a reprimand, fine, withdrawal, or suspension of authorization to conduct business either for the entire unit or members. In addition, failure to comply, which constitutes a breach of members contractual obligations, may result in disciplinary actions by ESI.

Protection of Members in Case of Communication about Illegal or Questionable Activities

If an employee becomes aware of any illegal or questionable activity in ESI, he/she shall inform the agency principal. No member who communicates bona-fide a concern, shall be exposed to retaliation based on this communication, even if the concern eventually proves to be unfounded. Such communications may be made anonymously.

Ethical Conduct of Business

The goals of this Code can only be achieved with the contribution of all. It is everyone’s personal responsibility to adhere to this Code of Conduct. All members are encouraged to contact their agency principal when detecting that someone has done something improperly. This can help to prevent small problems leading to big problems.

Whistleblower Policy Reporting Responsibility

This Whistleblower Policy is intended to encourage and enable employees to raise serious concerns internally so that ESI can address and correct inappropriate conduct and actions. It is the responsibility of all management and employees to report concerns about violations of ESI’s code of ethics or suspected violations of law or regulations that govern ESI’s operations.

No Retaliation

It is contrary to the values of ESI for anyone to retaliate against any manager or employee who in good faith reports an ethics violation, or a suspected violation of law, such as a complaint of discrimination, or suspected fraud, or suspected violation of any regulation governing the operations of ESI. An employee who retaliates against someone who has reported a violation in good faith is subject to discipline up to and including termination of employment.

Reporting Procedure

ESI has an open door policy and suggests that employees share their questions, concerns, suggestions or complaints with their supervisor. If you are not comfortable speaking with your supervisor or you are not satisfied with your supervisor’s response, you are encouraged to speak with Lisa Smith, President.

Supervisors and managers are required to report complaints or concerns about suspected ethical and legal violations in writing to the General Manager who has the responsibility to investigate all reported complaints. Employees with concerns or complaints may also submit their concerns in writing directly to their supervisor or General Manager.

Acting in Good Faith

Anyone filing a written complaint concerning a violation or suspected violation must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation. Any allegations that prove not to be substantiated and which prove to have been made maliciously or knowingly to be false will be viewed as a serious disciplinary offense.

Confidentiality

Violations or suspected violations may be submitted on a confidential basis by the complainant. Reports of violations or suspected violations will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation.

Handling of Reported Violations

The General Manager will notify the person who submitted a complaint and acknowledge receipt of the reported violation or suspected violation. All reports will be promptly investigated and appropriate corrective action will be taken if warranted by the investigation.