The purpose of an Ethics Program is to constantly reinforce honesty and integrity as the foundation for all other business principles, (4) to promote ethical work behavior, individual accountability and responsibility, and to protect employees and the company from any accusation of wrongdoing. Failure to set and protect these high ethical standards can be devastating to a company.

Ethics may be simply defined as a solid commitment to integrity. Integrity, in turn, is defined as a “strict adherence to a moral code.” Because a company’s reputation as an organization of honesty and integrity is so crucial, you need to do more than simply follow the law. You need to avoid even the appearance of inappropriate conduct.

Characteristics of an Ethics Program

Involves everyone
Includes active support of top management down to local supervisors
Provides model of ethical behavior
Provides guidance for ethical dilemmas
Identifies questionable situations before they escalate to a violation
May require a verbal or written acknowledgement of compliance

All employees are expected to act professionally and to tell the truth in all dealings with the company, other employees, customers, and third parties. Employees must be truthful in all statements or entries made in company correspondence or other types of communication, including telephone calls, faxes, and emails. The omission of information may be considered a misrepresentation of the truth—that’s not giving the full story in certain circumstances, or sharing only half of the facts, for example.

Employees share a responsibility to accurately complete all company records. Creating bids, proposals, reports, or any other documents containing inaccurate, false, or fraudulent information may be a criminal violation and could result in criminal prosecution for both the employee and the company. All financial statements and records must also accurately reflect company or customer transactions, and should be properly and promptly recorded.

Anti-trust laws were created to preserve a competitive economy where free enterprise can thrive. Your company is legally obligated to compete fairly and ethically for all procurement opportunities. An anti-trust violation is considered a felony and may incur severe penalties, including significant monetary fines and/or imprisonment.

You should never attempt to inappropriately obtain or possess a competitor’s proposals or proprietary information. Even talking about prices, bids, and proposals with a competitor may be considered a violation. You should also realize that a company who is a customer or supplier in one area of business might actually compete with your company in another business arena. Because any agreement with a competitor to limit competition is a violation of anti-trust law, you must be careful not to take any action which could be construed as an effort to fix prices or terms and conditions, disclose information about a company proposal, or otherwise limit competition. That’s what ‘white collar’ crime looks like.

While companies usually establish their own specific policies, many are similar throughout the private sector.

Purchasing Goods and Services

Purchases should be based exclusively on quality, performance, and price.
Laws prohibit offering, soliciting, or receiving any form of bribe or kickback.
Company legal departments should be advised if any request to engage in such activity is received.

Relations with Non-Government Personnel

Employees may, within reason, furnish meals, modest gifts, and entertainment in conjunction with business discussions.
Employees and supervisors must use discretion to ensure expenditures are appropriate and could not be construed as bribes.
Modest gifts might commemorate a specific holiday or special event.
Companies may enforce a set dollar limit for gifts, such as $100.

General Guidelines

All approved expenditures will need to be fully documented.

Questions regarding specific company policy should be referred to management or the company’s legal department.

Each employee shares the responsibility for avoiding any financial, business, or other arrangement that might not be in the best interests of the company, or cause a conflict with the performance of their duties.

You are entrusted with the use of valuable company assets every day, and are responsible for protecting them from misuse and damage. The company’s assets include property and equipment, such as buildings, vehicles, computers, cell phones, and many other items. Theft of company or customer property, or other associated crimes are grounds for immediate termination of employment and may result in the filing of a criminal complaint.