Ethical Standards Policy and Compliance Training Program

1. Ethical Standards Policy and Compliance Training Program

2. ISIS’ Ethical Standards Policy... • Meet the Policy Document • ISIS’ Published commitment to: Honesty Integrity Respect Accountability Transparency Create your first document ...and Compliance Training Program. ISIS, ISIS, inc. inc. Ethical Standards Policy and Compliance Training Program Ethical Standards Policy and Compliance Training Program Integrated Systems Improvement Services, Inc. 4116 Avenida Cochise, Suite Q Sierra Vista, Arizona 85635-5841 www.isishq.com Integrated Systems Improvement Services, Inc. 4116 Avenida Cochise, Suite Q Sierra Vista, Arizona 85635-5841 www.isishq.com

3. Why an Ethical Standards Policy? • Effective December, 2007, the Federal Acquisition Regulation (FAR) was modified... • FAR Part 3 now includes Subpart 3.10, “Contractor Code of Business Ethics and Conduct.” • Contains requirements that mandate government contractors performing contracts of $5 million or more and with a PoP of 120 days or more to have an ethics policy and training program, and a mechanism for reporting violations. • ISIS welcomes the opportunity to provide guidance to its employees regarding ethical conduct in the workplace. It is the right thing to do. Create your first document

4. ISIS’ Compliance... • Create a written Ethical Standards Policy and Compliance Training Program/Establish Awareness/Promote Compliance • Create a Method of Reporting Ethical Misconduct or Abuse such as a Hotline or Other Means • Create and Display an ISIS Hotline Poster for Reporting Information, or Use and Display an applicable Government Poster • Create an Internal Control System for Appropriate Responses and Solutions to Ethical Issues (Hotline and CAPA) • As of June 30, 2008, Congress Enacted Legislation that will Require Contractors to Report Violations of Federal Criminal Law, Violations of the Civil False Claims Act, or Overpayments in Connection with Awards of Covered Contracts and Subcontracts. Create your first document

5. ISIS’ Ethics Officer • ISIS has a designated Ethics Officer to serve our employees and to meet the criteria set forth by the government within the Federal Acquisition Regulation pertaining to government contractors’ ethics policies. Calls to the ISIS Ethical StandardsHotline at 520-459-5012, ext. 52 are only accessible by the Ethics Officer and Ethics staff person. If a need arises to report an Ethical Standards violation, your anonymity will be Safeguarded. CorrectiveAction/PreventiveAction(CAPA) serves as the ISIS’ Internal Control System for Ethics issues. CAPA Ethics Entries are protected and anonymous. Create your first document ISIS’ Ethics Officer is Renee Knoll, Human Resources Manager.

6. Meet the document...

7. “ISIS Employees Do Not Lie, Cheat or Steal.” • A Simple Ethics Statement Ethical Standards Statement “ ISIS employees do not lie, cheat or steal.” ISIS and each of its employees shall maintain the highest ethical standards in all business practices and in personal conduct as well. ISIS, Honesty Integrity Respect Accountability Transparency inc.

8. Define these values... • Honesty-Truthfulness, Fairness, Uprightness, Justness, Free from Fraud, Unadulterated.. • Integrity- The Possession of, and Strict Adherence to, High Moral Principles and Standards. • Respect - to Show Consideration, Equality, and Thoughtfulness toward Another. • Accountability- Purposefully Exposing One’s Actions to Others for Open Critique and Analysis. • Transparency- Clarity, Openness, Hiding Nothing. Honesty Integrity Respect Accountability Transparency Create your first document ISIS’ Professional Values

9. ISIS’ Employee Expectations... Individuals who work in a Company are the Company. What youdo effects how wedo as a business. Employee Conduct Drugs and Alcohol No ISIS employee, consultant, or applicant may use, possess, sell, transfer, trade and/or offer to sell alcohol, illegal drugs, or intoxicants while on duty, while conducting business for ISIS, while applying for an ISIS position, while on ISIS property, or while operating ISIS equipment, machinery, or vehicles. ISIS’ Reputation is the Sum of our Employees’ Reputations. Create your first document

10. ISIS’ Ethical Standard: Professionalism • ISIS employees shall not harass any person while representing ISIS or while conducting ISIS business. • ISIS personnel shall be respectful, truthful and professional at all times during the conduct of business. Professionalism: Relationships established and nurtured through ethical conduct and truthful communication. Harassment in any form of a fellow ISIS employee, within or without the workplace, is prohibited. ISIS requires that all personnel conduct interactions with other employees, customers, government representatives, suppliers, or any other individual or entity with respect and common decency. Create your first document

11. Harassment is... • Unwelcome conduct that is sexual in nature • Racial slurs • Threatening harm of any kind • Remarks regarding age, gender, disability, religion, or sexual orientation R E S P E C T Create your first document

12. Trustworthiness ISIS’ assets may not be utilized for personal benefit. ISIS shall maintain trust, confidentiality and loyalty to her customers and business associates. • Company Assets • ISIS employees may not misuse • company property or assets for • personal benefit or gain. Email, printers, copiers, telephones, computers, the Internet, vehicles, and all other • ISIS property and electronic media may not be utilized for anything other than • company business. • ISIS personnel are obligated to protect • customer and company data, and sensitive information, from unauthorized distribution or misuse. • (See also Security and Insider Trading under Government Contracts and • Business Activities.) Create your first document

13. Loyalty to ISIS As ISIS is loyal to itsemployees, ISIS’ employees are expected to be loyal as well. Conflicts of Interest ISIS employees are not allowed to enter into situations which may present a personal or professional conflict of interest, including acquiring financial interests in competitors and suppliers. Outside employment that conflicts with ISIS’ business activities is also prohibited. Create your first document

14. Government Contracts and Business Activities • TINA • All ISIS personnel shall comply with the TRUTH IN NEGOTIATIONS ACT (TINA) regarding all government contracting activities. The TRUTH IN NEGOTIATIONS ACT is defined as “A public law enacted for the purpose of providing for full and fair disclosure by contractors in the conduct of negotiations with the Government. The most significant provision included in TINA is the requirement that contractors submit certified cost and pricing data for negotiated procurements above a defined threshold.” (http://www.lectlaw.com/def2/t063.htm) Other Governance All ISIS employees shall follow any regulations, rules and laws that regulate government contracting. ISIS employees shall not knowingly give inaccurate statements, communications, representations, or untruthful information. The acquisition of any information about competitors’ bids or proposals most times is restricted and/or prohibited by the Procurement Integrity Regulations and other statutes and regulatory agencies. Create your first document

15. A Gift...for me? Gratuities/Gifts in Domestic Business Interaction Certain governmental regulations exist that guide contractors in their relationships with government personnel and the giving/receiving of gratuities and gifts. While there are nominal limits set on the acceptable values of gifts, gratuities, services, entertainment and the like, a good general rule of thumb is this: Gratuities, gifts or any items of value that are exchanged with the intent, or seemingly with the intent, to influence decisions regarding company business, are prohibited. There are specific and complicated guidelines for U.S. Government employees regarding limits on the value of gifts they may receive. There are also laws that stipulate what you may give and receive as gifts and items of value. Create your first document If you’re in doubt, check it out.

16. Would you please accept this gift...? • Gratuities/Gifts in Foreign Business Interaction • ISIS employees shall not accept or give any items of value, gifts, services, entertainment, gratuities, etc. intended to influence ISIS business activities or a government official. ISIS’ Ethical Standards Policy applies globally as well as domestically. Never offer improper gratuities or gifts to foreign government officials. Remember, if it even appears that you gave or received a gift that is intended to influence an official of a foreign government or any ISIS business, it is forbidden. Create your first document

17. Would you like to work for ISIS? Violating laws that govern recruiting current or former government employees may lead to severe penalties for the employee and ISIS. Hiring Government Workers Laws and regulations exist that regulate the recruitment, employment solicitation, discussions regarding hire, and employment offers for post-government employees, including military officers. It is best to leave these activities in the hands of ISIS’ authorized Human Resources employees to ensure ISIS abides by all required laws and regulations. Create your first document

18. Accuracy in Reporting Any failure to maintain financial integrity negatively impacts ISIS’ professional reputation and customer confidence. • Cost Recordation • Contracts, laws and regulations mandate business financial activities and records. Any misuse or misappropriation of finances shall not be tolerated. Costs shall be charged to the appropriate contract or account, no matter the status of the budget. Falsifying time sheets, charging direct costs to indirect accounts, or knowingly charging labor or material costs to the wrong account shall not occur. Timesheets shall be completed accurately and on time, using correct hours and charge codes. IntegrityPays

19. Know the culture you are in... • International Business Practices • ISIS employees working in foreign countries must comply with the laws, rules and business regulations of those countries. They shall also comply with all business regulations and personnel policies set forth by ISIS, including those within the • Ethical Standards Policy and Compliance Training Program. • No form of trafficking in substances controlled by American law shall be tolerated in foreign nations. There shall be no trafficking in persons, no debt bondage, no involuntary servitude, and no other crimes against people or property while under employment with ISIS. Create your first document

20. Protect ISIS... • ...and our customers! ISIS’ employees areprohibited from sharing information that is owned by ISIS or any of the company’s customers both during and after employment with ISIS. ISIS may be legally liable if proprietary information is not protected. ISIS sometimes enters into legal agreements with other entities to disclose proprietary information, but all employees are required to confirm authorization before releasing that information. Do not share another company’s proprietary information with ISIS. Proprietary Information can be technical or non-technical. Create your first document Questions about Proprietary Information should be directed to your supervisor or the ISIS Ethics Officer.

21. Political Activities Federal law does not allow corporations to directly or indirectly donate services, corporate funds or material goods to a candidate for federal office. • ISIS encourages all employees to engage in the American political process. However, employees must do so during their own personal time and never during work hours. Employees are prohibited from representing ISIS in any lobbying efforts that have not been internally approved, that follow all applicable ISIS policies, and that comply with all legal requirements, regulations, registrations and reporting requirements. Political party donations and donations to any political organizations shall not be made by an employee on behalf of ISIS. Political party donations and donations to any political organizations shall not be made by an employee on behalf of ISIS. Create your first document

22. Is it Classified? Security Legal procedures are in place regarding employees with security clearances and their access to, and handling of, classified information. All ISIS employees are required to follow those laws and guidelines. ISIS’ vast majority of personnel have security clearances. Know the laws that govern security procedures. Always act with integrity. Create your first document

23. Report Violations... • Anti-Trust • ISIS employees shall not engage in any activities that violate United States anti-trust laws. No agreements or understandings with competitors to control or fix pricing, to limit services, to boycott customers or suppliers, or to earmark or set aside market territories shall be tolerated. Any ISIS employee with knowledge of such activities shall report them immediately to the ISIS Ethical Standards Hotline at 520-459-5012, ext. 52 or to the Ethics Officer. Never Enter into Agreements or Understandings with Customers to: Never Enter into Agreements or Understandings with Competitors to: • Create Divisions within a Competitive Market by Allocating Territories or Markets, and Limit Products or Product Lines. • Control or Fix prices • Target Customers or Suppliers for Boycotts • Make the Sale or Purchase of Products Conditional upon Not Doing Business with a Competitor Create your first document

24. Is it publicly known? Never speculate in securities with knowledge affecting the subject company’s business that is not known to the public, and never pass the information to another who has no need-to-know. Insider Trading Any information regarding the award of contracts, divestitures, business acquisitions, the purchase or sale of shares, or any other trading information not known to the public shall not be used for an employee’s personal monetary advantage, especially in the event ISIS becomes a public company. No such information shall be passed to outside parties unless permitted by regulations and laws, and authorized by ISIS upper management. Create your first document

25. Environmental Ethics Compliance ISIS and its employees shall make every effort to ensure compliance with environmentally safe practices as they may apply, including the recycling of paper waste and the efficient use of resources. Create your first document ISIS goes Green

26. Test your knowledge... The following questions provide an opportunity to review your comprehension of the information just presented. Answer each, considering any scenarios that might present themselves during your career with ISIS. If any issues are unclear, please ask or contact your Ethics Officer at 520-459-5012, ext. 52 for clarification. Knowing the difference between ethical and unethical behavior is easy. It is the moral characteristic of sound and consistent ethical practices that sometimes presents a challenge. Create your first document ...and understanding.

27. Test Scenario 1: • I have received the ISIS’ Ethical Standards Training. • Do I understand it? • Have I received the ISIS Ethical Standards Policy and Compliance Training on-line? • Have I asked any questions I had, and gotten sufficient answers, from our ISIS Ethics Officer? *The ISIS Ethical Standards Policy and Compliance Training booklet is available on the ISIS web portal for your reference under Publications. Create your first document

28. Test Scenario 2: • I’m aware of some issues that violate the ISIS Ethical Standards Policy. But I don’t really want to be a “snitch” at work. It’s really none of my business what someone else does, is it? Workplace ethics is everyone’s business and concern. ISIS could be sued and criminally prosecuted if found to have knowingly or negligently violated someone’s civil rights or pertinent local, state or federal laws. ISIS could lose contracts, and its reputation, because of violations addressed within the ISIS Ethical Standards Policy. Create your first document

29. Test Scenario 3: • I came across some information that obviously violates our ISIS Ethical Standards Policy. Do I know who to call to report it, or do I know what to do if I have a general question about ethics in the workplace? • Contact the Ethics Officer for any questions you may have. • Telephone the ISIS Ethics Hotline • at 520-459-5012, ext. 52 to anonymously report an ethics violation. The ISIS reporting process ensures anonymity. Create your first document Call the ISIS Ethics Hotlineat 520-459-5012, ext. 52

30. Test Scenario 4: • I’m working in Qatar, so do I need to abide by the • ISIS Ethical Standards Policy here, too? Are there geographical limits regarding adherence to the ISIS Ethical Standards Policy for employees? The ISIS Ethical Standards Policy offers guidance regarding the reach of the policy. Whether in-country or out, as an ISIS employee, you must adhere to the ethical standards set forth in the policy. Create your first document

31. Test Scenario 5: • This is the second time Bob, my co-worker, has arrived at work smelling of alcohol and exhibiting slurred speech. • I like the guy and hate to get him in trouble. • What should I do? • Could Bob have an abuse or addiction problem for which he needs help? • Is this a safety or security issue? This very well may be a violation of ISIS Ethical Standards. But beware. Some medical conditions and/or medications can cause slurred speech and imbalance. Create your first document Contact your Ethics Officer with the information to be safe.

32. Test Scenario 6: • I‘m going to buy some stock in our prime contractor’s company. My CEO told me in a confidential conversation that they are selling out to Monopoly Contracting, but they are keeping it really quiet. No one else knows about it. • My CEO and I are going to make a bundle! • We’re buying a lot of shares before all this goes public. Is this employee’s conduct in line with the ISIS Ethical Standards Policy? No, the employee would be violating the Insider Trading laws and become subject to criminal charges. Create your first document

33. Test Scenario 7: • I need 150 color copies of a flyer my daughter made for her lost kitten. May I use the ISIS color printer? Is this compliant with the ISIS Ethical Standards Policy? No. It violates the policy regarding the Use of Company Assets Policy. Create your first document LOST...

34. Test Scenario 8: • I would like to purchase a special gift for a government employee who has assisted us with ISIS contracts, above and beyond what was expected. • May I purchase a gift for him? Question 1: Would it be perceived that the gift would be an enticement to show ISIS favoritism for upcoming work? Question 2: What are the statutory monetary limits for a gift given to a person holding the particular government position your proposed recipient holds? There are specific guidelines that must be followed under certain circumstances. To avoid legal problems, always check with your Ethics Officer first. Create your first document

35. Test Scenario 9: • I would like to see a friend of mine, who is currently • employed by the government, come onboard with ISIS. • Should I speak with her now or should I let the • ISIS Human Resources personnel approach her first? What is your best course of action according to the ISIS Ethical Standards Policy? Review the policy regarding Recruiting Government Employees. To be sure ISIS remains compliant with statutory requirements, allow Human Resources to conduct negotiations with potential employees from the government arena. Create your first document

36. Test Scenario 10: • ISIS sent me to DC for a business conference. • My hotel long-distance phone bills are never scrutinized. • I think I’ll take this opportunity to catch up with all my friends I knew in Hawaii. My company will never know the difference, • and it will be great hearing all their voices again. Is this compliant with the ISIS Ethical Standards Policy? Create your first document No. It violates the policy regarding Recording Costs.

37. Test Scenario 11: • There was a Security Breech last night at the SCIF • I’m assigned to. My supervisor said she isn’t going to • report it because she doesn’t want to get into trouble. • What should I do? Is this compliant with the ISIS Ethical Standards Policy? No. It violates the policy regarding Security. Report the Security Breech immediately. Create your first document

38. Test Scenario 12: • I had lunch today with one of the contract • people over at Established Contract Systems. • She wants to team with us to go after the new • work everyone is talking about. • But she wants me to get our management staff to promise we won’t ever team with • Monopoly Contracting before she will • agree to sign with us. • I’m not sure we can do that. Can we? Is this compliant with the ISIS Ethical Standards Policy and federal Anti-Trust law? No. It violates the ISIS policy and federal statutes regarding Anti-Trust activities. Create your first document

39. Test Scenario 13: • I took some of our prime subcontractor’s proprietary information on the DDIS contract down to the • printer to publish. • I think I’ll make my own copy and • take it to my cousin over at his contracting business. • It could help him with that project • he was asking me about. Is this compliant with the ISIS Ethical Standards Policy? No. It violates the policy regarding Protecting Proprietary Information. Proprietary Create your first document

40. Test Scenario 14: • I’ve just begun to help raise funds for my uncle who’s running for mayor. I have about an hour before I get off work. I think I’ll go ask all the ISIS employees for donations to help him get elected. Is this compliant with the ISIS Ethical Standards Policy? Create your first document No. It violates the policy regarding Political Activities.

41. QUESTIONS....? • Is there anything you would like to ask? • ? Create your first document

42. The ISIS Ethical Standards... Report Suspected Violations of theISIS Ethical Standards Policyor any Ethical Abuse or Misconduct to: ...H o tl i n e! • (520) 4 5 9 - 5 0 1 2, ext. #5 2 Your anonymity will be protected.