ACS Code of Ethics and Business Conduct

Committed to Procurement and Contract Performance Integrity

Dear Employee and Valued Business Partner,

At Assured Consulting Solutions ("ACS"), we are committed to our core values and demonstrate integrity, innovation, safety, and excellence in everything we do. We never allow our ethics or integrity to be compromised by our desire to succeed, regardless of the circumstances of our business. Your partnership with us allows us to jointly live out our values through our business relationship and ensure our diligence in upholding our commitment to procurement and contract performance integrity.

ACS is a high-performance company. We take our values and policies very seriously and enforce them throughout the company at all levels and in all business relationships. We hold ourselves to a high standard and expect the same from our valued partners. This high standard requires operating honestly, meeting commitments, using fair business practices, delivering value, and ensuring that your employees act in a like fashion. This is a condition of doing business with ACS.

This guide offers you a copy of our Code of Conduct ("Code"). We flow down all applicable Government ethics requirements as a normal practice and ensure compliance as part of our normal subcontract and supplier contract administration.

We have succeeded in earning our clients' trust by delivering outstanding customer service and acting ethically in all that we do. Integrity guides us as we conduct our business. Each of us is obligated to act with the highest degree of integrity and in full compliance with the law.

We rely upon our Code to help us understand the ethical and legal guidelines that must direct our business activities, and we update it periodically so that it remains timely and relevant. Our Code is not a substitute for good judgment, nor does it cover every situation that you may encounter or every law that may apply. It does, however, outline the basic legal guidelines that we must follow and the general ethical principles that will help each of us make the right decisions when conducting business. It serves as the most basic building block for our future success.

If you find yourself in a situation in which you are unsure how to act, believe that a violation of the Code could or has occurred, or have a question about a particular issue, please seek assistance. Our Code contains a number of resources that you may use to resolve or report any issue related to ethics and compliance without fear of retaliation. ACS will help and assist you in doing the right thing. Continuing to conduct our business in an ethical manner will help ensure long-term success for our company and our clients. 

If you become aware of any improper business conduct or ethics concern on the part of our employees, please contact me directly at 703-662-5062 x700 or via email at ethics@assured-consulting.com.

Thank you for your attention to this very important matter. We look forward to a successful business relationship.

Sincerely,

Erin Willett
ACS Ethics & Compliance Officer
ACS Managing Partner

About ACS

Our Mission

We empower our people to partner in solving our customer's’ most important and complex problems, advance the mission, and deliver value through actionable strategy.

Our Vision

We are committed to becoming an industry-recognized leader in the integration and application of technology, engineering, and innovation, as measured by our clients’ success, the brilliance of our people, and our Mission-First philosophy.

Our Values

Our core values are the guiding principles behind how we act. They define how we behave as an organization, how we expect employees to behave while no one (or everyone) is watching, and how we all behave when decisions are difficult.

A TRUSTED PARTNER

Acting as a honest broker for our clients, we provide the right information and critical feedback to support their mission. We value commitment to the right outcome for the mission and have no other interests.

THE DOMAIN EXPERT

We help our clients open their technology aperture through coupling and converging technologies and offering consultant-level insights. Our philosophy emphasizes that the whole once integrated is greater than the sum of its parts.

RAISING THE LEVEL OF EXCELLENCE

We value the application of technical, operational, and managerial excellence to provide objective solutions to critical problems of national interest. We invest in and foster topnotch infrastructure, technology, management, and people
and encourage continual improvement at all levels.

PASSIONATE SUPPORT

Passion engenders excitement from the person sitting across the table.

OUTCOME-BASED TENACITY

In service delivery and customer support, we are invested in the loyalty and commitment necessary to see initiatives to fruition.
We at ACS are “in it for the long haul” and recognize that the successes of our customers are our successes as well.

ELEVATING THE COMMUNITY

ACS has the responsibility to influence positive change for the community in which we live and thrive. Through active involvement, directed outreach, and monetary contributions, ACS is a steward for the underserved population.

We are Committed to Diversity, Equity & Inclusion

Inclusion is key to our success. We are a talented, proud, diverse cast of characters from all walks of life. ACS is committed to equity for all, enabling us to attract, develop, inspire, and reward top talent. And it creates an environment that allows our team to perform at their very best in a culture in which everyone feels they have an equal opportunity to belong and build a career.

We are Committed to Quality

We provide each employee with strategy, tools, access to corporate resources, and value structure to create a path to quality service delivery defined by outcome-based value and continual improvement.

Integrity in Everything We Do

At ACS, we are committed to doing the right thing in all that we do. Our commitment to integrity has made our company an industry leader, and will continue to support our growth in the years ahead. Our Code addresses our professional, ethical, financial, and social values. It sets forth what is expected of all ACS employees and vendor partners, wherever we conduct business. Our Code also represents our commitment to our clients, partners, and the communities in which we live and work.

Our Core Values are the foundation for this Code. The following principles set forth the guidelines of behavior that we must follow:

  • Ethical behavior is the basis for everything we do.

  • ACS is committed to treating its employees fairly, and providing each individual with opportunity for advancement and growth.

  • Teamwork, mutual respect and trust, and open communications are the foundations of the ACS culture.

  • ACS strives to be a responsible corporate citizen in the communities in which we operate.

  • Meeting clients' needs through our Mission-First philosophy is of utmost importance.

  • We are committed to compliance with the laws, rules, and regulations applicable everywhere we conduct business.

Our Code is meant to provide guidance regarding these principles. However, one document cannot possibly address every law, rule, policy, or scenario we may encounter in our daily work. Nor is our Code a substitute for exercising common sense and good judgment, or seeking guidance when it's needed. To help you determine whether a particular action is
appropriate, ask yourself the following questions:

  • Would my action comply with the spirit and purpose of ACS' policies?

  • Would I feel comfortable about doing this, or would it violate my personal standard of conduct?

  • Is this action honest in all respects?

  • How might this action affect others?

  • Would this action embarrass me or ACS if it became known to my clients, coworkers, professional colleagues, family, or friends?

If you have any questions about our Code or any doubts about a particular course of action, you should consult with the ACS Ethics and Compliance Officer (ethics@assured-consulting.com).

We Uphold the Law

Our commitment to integrity begins with complying with laws, rules, and regulations where we do business. Further, each of us must have an understanding of the company policies, laws, rules, and regulations that apply to our specific roles. If we are unsure of whether a contemplated action is permitted by law or ACS policy, we should seek the advice from an ACS Managing Partner. We are responsible for preventing violations of law and for speaking up if we see possible violations.

We Rely on Our Honesty

We Value Fair Competition

We are dedicated to ethical, fair, and vigorous competition. We sell ACS products and services based on their merit, superior quality, functionality, and competitive pricing. We make independent pricing and marketing decisions and do not improperly cooperate or coordinate our activities with our competitors. We do not offer or solicit improper payments or gratuities in connection with the purchase of goods or services for ACS or the sales of its products or services, nor do we engage or assist in unlawful boycotts of particular customers.

We must never engage in or support unfair or predatory business practices or any activities that would improperly restrain fair business. Similarly, it is critical that we avoid any activity that may violate or give the appearance of violating competition laws. While laws may vary where we conduct business, these types of conduct are generally prohibited:

  • Agreeing on the prices, terms, or conditions of sale for competing services or products.

  • Dividing or allocating customers, bids, markets, or territories for competing services or products.

  • Agreeing to refuse to do business with particular third-parties.

These rules apply to informal understandings as well as to formal agreements. In order to make sure that we are competing fairly, we should refrain from discussing any of these activities with our competitors — or from discussing any other matters that could be seen as an attempt to limit competition. Behavior that violates these rules should be reported.

Handling Competitive and Proprietary Information

We strive to out-perform our competition fairly and competitively. Advantages over our competitors are obtained through superior performance of our services and products, not through unethical or illegal business practices. At times, we may need information about our competitors. We may use publicly available information, but must always make sure that we only acquire information about our competitors in a legal, ethical, and responsible manner. For example, we must never pressure anyone to breach a confidentiality agreement, such as by asking a colleague to reveal confidential information about a previous employer. We also should never attempt to gather information about our competitors through deceptive or misleading actions. If confidential information about a competitor is deliberately or inadvertently disclosed to you, discuss the issue with the ACS Ethics and Compliance Officer and do not use it without express permission from an ACS Managing Partner.

Selective Disclosure

We do not selectively disclose (whether in one-on-one or small discussions, meetings, presentations, proposals, or otherwise) any material non-public information with respect to ACS, its business operations, plans, financials, results of operations, or any development plan. We are particularly vigilant when making presentations or proposals to customers to ensure that our presentations do not contain non-public information.

Combating Trafficking In Persons

In accordance with FAR 52.222-50 Combating Trafficking in Persons, we expect our suppliers to not engage in the use of forced, bonded (including debt bondage) or indentured labor, involuntary prison labor, slavery, or trafficking of persons. This includes transporting, harboring, recruiting, transferring, or receiving vulnerable persons by means of threat, force, coercion, abduction, or fraud for the purpose of exploitation.

Avoiding Conflicts of Interest

To ensure our continued success, it is crucial that we avoid conflicts of interest, whether actual, potential, or perceived. A "conflict of interest" occurs when we use our position at ACS, business relationship with ACS, or information we have acquired during the course of doing business with ACS in a way that may create a conflict between our personal interests and those of our company or its customers. In other words, if a situation arises that makes it difficult to act in an unbiased, objective manner on ACS' behalf, a conflict of interest may be present. If a conflict of interest — or the potential for one — arises, you must disclose it to ACS Management, ACS Human Resources, or the ACS Ethics and Compliance Officer at once for review.

Of course, not all possible scenarios giving rise to a conflict of interest can be listed here. However, the following examples are some of the more common situations you are likely to encounter in your day-to-day business:

  • Business with Family and Friends: Our decisions about selecting suppliers, customers, and other persons doing or seeking to do business with ACS must be impartial. The basis of our business decisions must be whether ACS' and our clients' best interests are advanced. If a family member or close friend has an interest in a company with which we seek to conduct business, you must remove yourself from the selection process and disclose the conflict immediately.

  • Corporate Opportunities: At times, we may learn of business opportunities through our employment or the course of doing business at ACS. We may not take personal advantage of those opportunities or refer them to a third party, unless ACS has had a chance to evaluate the prospect and has decided not to pursue it.

  • Outside Employment: Being employed by or consulting with another organization could also create a conflict of interest. In general, those under ACS' employ may not accept another job that interferes with their ability to do work for ACS. Outside business may never be conducted during designated ACS work hours, and the use of ACS property, equipment, or information for another business is prohibited. Further, ACS employees cannot accept employment from a supplier or competitor of ACS without an express written waiver from an ACS Managing Partner.

  • Investments: ACS does not seek to control the personal financial decisions of our employees. However, some outside financial interests may improperly influence — or could be perceived by others to influence — the decisions we make for ACS. Investments in ACS' competitors, customers, suppliers, or other business partners are generally acceptable. Further, the amount of the investment must not be so significant to you that it would affect your business judgment on behalf of ACS. If you or a member of your household own or seek to own any such financial interest, you must promptly disclose the matter and seek approval from an ACS Managing Partner.

  • Personal Relationships: Supervising anyone with whom you have a family or romantic relationship could give rise to the appearance of favoritism. Therefore, we should never be in a position where a personal relationship is also a reporting relationship. Close relatives, partners, those in a dating relationship, or members of the same household are not permitted to be in positions that have a reporting responsibility to each other. Close relatives are defined as husband, wife, domestic partner, father, mother, father-in-law, mother-in law, grandfather, grandmother, son, son-in-law, daughter, daughter-in law, uncle, aunt, nephew, niece, brother, sister, brother-in-law, sister-in-law, step relatives, cousins, and domestic partner relatives. If you find yourself in a position to supervise or otherwise make employment decisions regarding family or partner, disclose the situation immediately.

  • Serving on a Board of Directors: At times, employees may seek to sit on a board of directors outside of ACS. While impacting the community by serving on a board of directors for a non-profit organization is encouraged and does not require prior approval, employees may only accept this position if it does not interfere with their ability to do their job. However, serving on the board of directors for an outside company that does business with ACS requires advance approval from an ACS Managing Partner. Always contact ACS Management, ACS Human Resources, or the ACS Ethics and Compliance Officer before accepting such a position, to include sitting on public commissions or taking public service appointed positions.

Remember that prompt and full disclosure is required for all circumstances that you believe might constitute, or appear to constitute, a conflict of interest. If you are unsure, seek guidance. Never engage in any conduct involving a possible or apparent conflict of interest unless you receive prior written approval from an ACS Managing Partner.

Gifts, Gratuities, and Business Courtesies

ACS is committed to competing solely on a merit of our products and services. We should avoid any actions that create a perception that favorable treatment of outside entities by ACS was sought, received, or given in exchange for personal business courtesies. Business courtesies include gifts, gratuities, meals, refreshments, entertainment, or other benefits from persons or companies with whom ACS does or may do business. We will neither give nor accept business courtesies that constitute, or could reasonably be perceived as constituting, unfair business incentives that would violate law, regulation, or polices of ACS or customers, or would cause embarrassment or reflect negatively on ACS' reputation.

Accepting or giving occasional gifts, meals, or entertainment with business partners is allowed under some circumstances. However, we must act in a manner consistent with our core values, various laws that govern our actions, and contract requirements. Any gift that could create an obligation or influence the business relationship should never be offered, provided, or accepted. Our clients, suppliers, and others should know that our employees' judgment is not for sale. For these reasons, we may only offer, provide, or accept gifts, meals, or entertainment in accordance with applicable law and our gift and entertainment policies, or after first consulting with an ACS Managing Partner.

Employees who award contracts, can influence the allocation of business, create specifications that result in the placement of business, or who participate in negotiation of contracts must be particularly careful to avoid actions that create the appearance of favoritism or that may adversely affect the ACS' reputation for impartiality and fair dealing. The prudent course is to refuse a courtesy from a supplier when ACS is involved in choosing or reconfirming a supplier or under circumstances that would create an impression that offering courtesies is the way to obtain ACS business.

We will not offer, give, solicit, or receive any form of bribe or kickback. A kickback is any money, fee, commission, credit, gift, gratuity, thing of value, loan, entertainment, service, or compensation of any kind that is provided, directly or indirectly, to any prime contractor, prime contractor employee, subcontractor, or subcontractor employee for the purpose of improperly obtaining or rewarding favorable treatment in connection with a prime contract with the US, or a subcontract in connection with a prime contract with the US. These are criminal acts under the laws of many countries, including the United States.

Meals, Refreshments, and Entertainment

We may accept occasional meals, refreshments, entertainment, and similar business courtesies that are shared with the person who has offered to pay for the meal or entertainment, provided that:

  • They are not inappropriately lavish or excessive.

  • The courtesies are not frequent and do not reflect a pattern of frequent acceptance of courtesies from the same person or entity.

  • The courtesy does not create the appearance of an attempt to influence business decisions, such as accepting courtesies or entertainment from a supplier whose contract is expiring in the near future.

  • The employee accepting the business courtesy would not feel uncomfortable discussing the courtesy with his or her manager or co-worker or having the courtesies known by the public.

Gifts

Employees may accept unsolicited gifts, other than money, that conform to the reasonable ethical practices of the marketplace, including:

  • Flowers, fruit baskets, and other modest presents that commemorate a special occasion.

  • Gifts of nominal value, such as calendars, pens, mugs, caps, and t-shirts (or other novelty, advertising or promotional items).

Generally, employees may not accept compensation, honoraria, or money of any amount from entities with whom ACS does or may do business. Tangible gifts (including tickets to a sporting or entertainment event) that have a market value greater than $25 may not be accepted unless approval is obtained from an ACS Managing Partner.

Employees with questions about accepting business courtesies should talk to their manager or an ACS Managing Partner.

Offering Business Courtesies

Any employee who offers a business courtesy must assure that it cannot reasonably be interpreted as an attempt to gain an unfair business advantage or otherwise reflect negatively upon ACS. An employee may never use personal funds or resources to do something that cannot be done with ACS resources. Accounting for business courtesies must be done in accordance with approved company procedures.

Other than to our Government customers, for whom special rules apply, we may provide non-monetary gifts (i.e., company logo apparel or similar promotional items) to our customers. Further, management may approve other courtesies, including meals, refreshments, or entertainment of reasonable value, provided that:

  • The practice does not violate any law or regulation or the standards of conduct of the recipient's organization.

  • The business courtesy is consistent with industry practice, is infrequent in nature, and is not lavish.

  • The business courtesy is properly reflected on the books and records of ACS.

Reporting Concerns

It's Up to You to Ask Questions and Report Concerns

Why Is Reporting Important?

It is important to raise questions and come forward with our concerns. Doing so reinforces our commitment to act ethically in every business decision we make. Early detection also allows ACS to address concerns before they become widespread problems, and to take corrective action if necessary. Above all, ACS is committed to maintaining a culture where each of us feels comfortable asking questions, speaking up, and working toward solutions.

How Do I Raise Concerns?

ACS treats all reports confidentially to the extent we are able to. We do so consistent with the law, company policy, and the requirements for conducting a thorough investigation. To raise a concern or make a report, reach out to any of the following resources via email, phone, letter, or in person:

  • Your supervisor or someone in management

  • ACS Human Resources
    Email: hr@assured-consulting.com
    Phone: 703-662-5062 x1

  • ACS Ethics and Compliance Officer
    Email: ethics@assured-consulting.com
    Phone: 703-662-5062 x700

  • Mail or In-Person:
    Assured Consulting Solutions
    ATTN: Ethics & Compliance
    11800 Sunrise Valley Drive, Suite 1212
    Reston, VA 20191

What Happens Next?

ACS promises to investigate all reports promptly, thoroughly, and consistent with applicable law. Investigations will be kept confidential to the extent possible. If necessary, ACS may report certain investigations to the appropriate authorities. Our company will take appropriate corrective or disciplinary action for Code violations whenever necessary.

Our Commitment to Non-Retaliation

ACS does not tolerate acts of retaliation against anyone who makes a good faith report of a possible violation, or who participates in an investigation of possible wrongdoing. Acting in "good faith" means that you come forward with all of the information you have and believe you are giving a sincere and complete report. Simply stated, it does not matter whether your report actually uncovers unethical behavior, but you must have honest intentions in making it.

At any time, you may in good faith report a suspected violation of our Code, company policy, or the law without fear of retaliation or any adverse impact on your employment. Individuals who take action against a person for making a report or participating in an investigation will face disciplinary action, up to and including termination. Likewise, anyone who makes a report not in good faith will be subject to disciplinary action.

Waivers

In rare cases, ACS may waive compliance with this Code. This means that waivers to this Code may be permitted in certain instances. Such waivers will only be granted on a limited basis, and will be considered case-by-case. Only an ACS Managing Partner may issue a waiver of this Code. Any waiver of this Code will be promptly disclosed as required by applicable law.

Privacy and Security

Protecting Company Property and Data Privacy

We have worked hard to acquire our valuable assets, both physical and intangible. ACS' physical property includes its buildings, facilities, vehicles, equipment, computer systems,
resources, and records. We are responsible for protecting such property from loss, damage, misuse, theft, and waste. We can do this by using company resources wisely and only for
business purposes.

It is also important to protect our intangible assets — things like our reputation in the communities in which we operate. Such assets also include our confidential information, like business plans, intellectual property, proposals, technical innovations, designs, inventions, patents, financial information, client lists, and other information we produce as part of our work for ACS. We may never reveal ACS' confidential information to any outside parties unless we are properly authorized or legally required to do so. In addition, we may not disclose such information to our colleagues who do not have a legitimate business "need to know" without express written permission from an ACS Managing Partner. When there is a business need to disclose such information to a colleague or third party, the appropriate confidentiality agreement must be in place. Remember, the obligation to protect confidential company information continues even after your employment or business relationship with ACS ends.

We also have a duty to protect employee data in accordance with applicable legal requirements. No one should access prospective, current, or former employee records—such as payroll, group insurance, benefits, and files —without proper authority.

If you discover or suspect the unauthorized use or disclosure of confidential information, you should notify an ACS Managing Partner immediately. In addition to protecting the confidential information of ACS, we must also afford this same respect to the confidential information of our employees, clients, partners, and other third parties.

Using Company Computer Systems

Just as we have a duty to protect our company's assets, we share an obligation to use ACS' computer resources, networks, Internet, and email systems responsibly and securely. These resources are provided for business purposes, and are intended to be used for such. While ACS allows incidental, occasional personal use of its Internet/email system, it must be kept to a minimum and not detract from our work. When using ACS IT resources, users are not authorized to:

  • create, copy, transmit, or re-transmit greeting cards, video, sound, or other large file attachments that can degrade the performance of the entire network;

  • utilize "push" technology on the Internet and other continuous data streams that can also degrade the performance of the entire network. "Push" technology refers to the data distribution method in which data is automatically delivered to a computer or mobile device in real time or at periodic intervals;

  • access pornography or hacker sites;
    Note: This policy statement does not apply to any users working in an official capacity that may require access to certain sites in support of an investigative case or audit.

  • use Government systems as a staging ground or platform to gain unauthorized access to other systems;

  • use ACS IT resources for activities that are illegal, inappropriate, or offensive to fellow employees or the public. Such activities include, but are not limited to: hate speech, or material that ridicules others on the basis of race, creed, religion, color, sex, disability, national origin, or sexual orientation;

  • create, download, view, store, copy, or transmit sexually explicit or sexually oriented materials;

  • create, download, view, store, copy, or transmit materials related to any gambling (legal and illegal), illegal weapons, terrorist activities, and any other illegal activities or activities otherwise prohibited, etc.;

  • download, copy, and/or play computer video games;

  • ACS IT resources for commercial purposes or in support of "for-profit" activities or in support of other outside employment or business activity (e.g., consulting for pay, sales or administration of business transactions, sale of goods or services), including using ACS IT resources to assist relatives, friends, or other persons in such activities (e.g., employees may not operate or participate in the operation of a business with the use of ACS' IT resources);

  • engage in any prohibited outside fundraising activity, endorse any product or service, participate in any lobbying activity, or engage in any prohibited partisan political activity;

  • post non-public ACS information to external news groups, bulletin boards, social media (e.g. Facebook, Twitter) or other public forums without authority. This includes any use that could create the perception that the communication was made in one's official capacity as an ACS employee or agent, unless appropriate ACS approval has been obtained or the use is not at odds with the mission or position of ACS or its customers;

  • acquire, use, reproduce, transmit, or distribute any controlled information, including computer software and data, that includes privacy information, copyrighted, trademarked, or material with other intellectual property rights (beyond fair use), proprietary data, or export controlled software or data; and

  • download files, for example music or other inappropriate material, for the purpose of forwarding them to another individual. This activity, also known as "file sharing," is considered outside the scope of limited personal use. Furthermore, the use of file sharing technology creates a substantial computer security risk in that it may facilitate the spread of computer viruses.
    Note: ACS provides web filtering software to monitor and track user browser activity in real-time on ACS IT systems. Should an ACS employee have a valid business need for accessing a particular web site in support of an investigative case or audit, the employee may request access by submitting a request to gethelp@assured-consulting.com.

If you are aware of or suspect the inappropriate use of ACS technologies or electronic communications, notify management or ACS Human Resources immediately.

Performance Excellence

Providing Quality Products and Services

The foundation of ACS' reputation is the high quality of the products and services we provide. In order to keep our standards high, we must each comply with all quality control procedures and follow contract specifications at all times. Make sure to familiarize yourself with the standards and specifications that apply to the projects you work on. We must each be aware of and follow the policies and procedures designed to protect the quality and safety of our products. For guidance, consult Management or an ACS Managing Partner. Raise any quality or safety issues you spot with your supervisor immediately.

We further guarantee quality services to our customers through proper supply chain due diligence, monitoring, and enforcement. ACS takes great care in choosing our suppliers, contractors, agents, consultants, and other business partners. We aim to do business only with companies that match our high standards of ethical business conduct. Ultimately, our goal is for all of our business partners to comply with our Code and operate in an ethical and lawful manner.

For these reasons, we conduct due diligence when selecting our suppliers and other business partners. We firmly hold our suppliers accountable for assuring the quality of the goods and services they provide us. If you have reason to believe that a supplier has failed to provide quality products and/or services, contact Management or an ACS Managing Partner immediately.

Charging Time

Each of us has a responsibility to ensure that our time reports accurately reflect the hours worked on a specific project. Time worked on a project must be charged to that project and no other. Government regulations and many clients' contracts also mandate complete and accurate records. All employees are required to complete daily time sheets in accordance with the requirements established by ACS-0001, Time and Pay Policy. Supervisors are responsible for ensuring that all timesheets they approve are accurate and reflect the hours worked by the employees who report to them.

Falsification of timesheets is a serious offense which can subject ACS and the responsible individual to criminal and civil liability.  If anyone directs or suggests that time be charged in a manner other than in accordance with this policy, it is the responsibility of the employee or business partner to inform an ACS Managing Partner immediately.

Accurate Books and Records

We must each do our part to make certain that the financial documents our company discloses to the public are accurate and honest. Even if maintaining financial data is not your primary job duty, each of us contributes to record keeping in some form, such as by completing timesheets, submitting travel and expense reports, or keeping safety records. The information we record provides an accurate view of our operations and allows our company to make well-informed business decisions. Therefore, every piece of information that we submit in company records of any kind must be absolutely honest, accurate, and complete. Each of us is responsible for knowing and following ACS' internal controls and any applicable accounting requirements when recording this data. We also must submit appropriate contract documentation at all times.

Our commitment to ethical business conduct requires our business transactions to be authorized and legitimate. To be clear, we may not engage in any of the following activities:

  • Making false representations on behalf of our company, either verbally or in writing.

  • Hiding company funds.

  • Circumventing internal controls.

  • Mischaracterizing company transactions.

  • Creating undisclosed or unrecorded fund accounts.

  • Knowingly allowing similar illegal activities to occur.

If you notice any accounting or auditing irregularities, or incidents of fraud by individuals responsible for our company's accounting or financial reporting, you should report your observation to Management, the ACS Ethics and Compliance Officer, or an ACS Managing Partner. Please keep in mind that you will be protected from any retaliation that results from a good faith report.

Records Retention

Keeping our records in order helps us to build trust with our clients and regulators. This commitment applies to both paper and electronic documents, including files such as email and images. In short, we must take care with all the records we create, receive, or maintain in order to do our jobs. Effectively managing these records allows us to ensure they are available when needed. In addition, it helps us comply with all applicable laws and regulations and preserve any documents that may become relevant in audits, investigations, or litigation.

If you believe that anyone has improperly concealed, altered, or destroyed a record, you should report it to the ACS Ethics and Compliance Officer or an ACS Managing Partner.

Audits and Investigations

During your employment or business relationship with ACS, a company or government official may ask you to take part in an audit or investigation of ACS or certain employees. It is important to cooperate with such a request, but if a government official requests information or documentation, contact an ACS Managing Partner before providing any records. As with all our activities, we must be forthright when we deal with audits or investigations. At no time may we conceal, alter, or destroy any requested records. In addition, we must never attempt to exert improper influence on the results of an investigation or audit.

How We Work

We are Committed to Diversity

Inclusion is key to our success. We're a talented, proud, diverse cast of characters from all walks of life. An inclusive work environment and employee resource groups help us keep it that way. We are committed to a diverse workforce and a safe and healthy work environment for all employees. We are committed to providing employment for qualified individuals with a wide diversity of talent and backgrounds, whether in race, ethnicity, religion, color, sex, age, national origin, or disability. Having a diverse workforce strengthens our skills set, gives us better understanding of our customers, and promotes our social goals. ACS encourages reporting of all perceived incidents of discrimination or harassment. It is the policy of ACS to promptly and thoroughly investigate such reports. ACS prohibits retaliation against any individual who reports discrimination or harassment or who participates in an investigation of such reports.

We are an Equal Opportunity Employer

ACS proactively fulfills its role as an equal opportunity employer. We do not discriminate against any employee or applicant for employment because of race, color, sex, religion, age, sexual orientation, gender identity and expression, national origin, marital/parental status, pregnancy/childbirth or related conditions, physical or mental disability, genetic information, status as a Disabled Veteran, Recently Separated Veteran, Active Duty Wartime or Campaign Badge Veteran, Armed Forces Services Medal, or any other characteristic protected by law. We will not discharge or in any other manner discriminate against employees or applicants because they have inquired about, discussed, or disclosed their own pay or the pay of another employee or applicant.

The policy of equal employment opportunity (EEO) and anti-discrimination applies to all aspects of the relationship between ACS and its employees, including Recruitment, Employment, Promotion, Transfer, Training, Working Conditions, Wages and Salary Administration, Employee Benefits and Application of Policies

The policies and principles of EEO also apply to the selection and treatment of independent contractors, personnel working on our premises who are employed by temporary agencies, and any other persons or firms doing business for or with ACS.

Legal Status to Work

The Immigration Reform and Control Act requires all United States employers to verify the identity and employment eligibility of all employees hired to work in the US after November 6, 1986. As a federal contractor, ACS participates in E-Verify® to confirm the identity and employment eligibility of all persons hired.

At-Will Employment

All employees of ACS are at-will employees and, as such, are free to resign at any time without reason. ACS, likewise, retains the right to lawfully terminate an employee's employment at any time, with or without reason or notice. This manual or any other document is not intended to guarantee employment or any benefit to the employee for any specified period.

Americans with Disabilities Act and American with Disabilities Amendments Act

ACS complies with all applicable provisions of the Americans with Disabilities Act (ADA) and the American with Disabilities Amendments Act (ADAA). Furthermore, it is our company policy not to discriminate against qualified individuals with disabilities concerning application procedures, hiring, advancement, discharge, compensation, training or other terms, conditions, and privileges of employment.

ACS will reasonably accommodate qualified individuals with a disability so that they can perform the essential functions of a job unless doing so causes a direct threat to these individuals or others in the workplace and the threat cannot be eliminated by reasonable accommodation and/or if the accommodation creates an undue hardship to ACS. It is the responsibility of an employee's employer to provide a required accommodation – not the customer. Any employee requiring an accommodation should contact ACS HR directly with any questions or requests for accommodation (hr@assured-consulting.com).

We Have Zero Tolerance for Harassment

ACS is committed to a work environment in which all individuals are treated with respect and dignity. Everyone has the right to work in a professional atmosphere that promotes equal employment opportunities and prohibits discriminatory practices, including harassment. Therefore, ACS expects that all relationships among persons in the workplace or while on business travel will be business-like and free of bias, prejudice, and harassment.

We are committed to zero tolerance regarding incidents of harassment. ACS prohibits harassment of any kind, including sexual harassment, and will take appropriate and immediate action in response to complaints or knowledge of violations of this policy. For purposes of this policy, harassment is any verbal or physical conduct designed to threaten, intimidate, or coerce an employee, co-worker, or any person working for or on behalf of ACS. The following examples of harassment are intended to be guidelines and are not exclusive when determining whether there has been a violation of this policy:

  • Verbal harassment includes comments that are offensive or unwelcome regarding a person's national origin, race, color, religion, gender, sexual orientation, age, body, disability or appearance, including epithets, slurs and negative stereotyping.

  • Nonverbal harassment includes distribution, display or discussion of any written or graphic material that ridicules, denigrates, insults, belittles or shows hostility, aversion or disrespect toward an individual or group because of national origin, race, color, religion, age, gender, sexual orientation, pregnancy, appearance, disability, sexual identity, marital status or other protected status.

Sexual Harassment

Sexual harassment may take different forms. The following examples of sexual harassment are intended to be guidelines and are not exclusive when determining whether there has been a violation of this policy:

  • Verbal sexual harassment includes innuendos, suggestive comments, jokes of a sexual nature, sexual propositions, lewd remarks, and threats; requests for any type of sexual favor (this includes repeated, unwelcome requests for dates); and verbal abuse or "kidding" that is oriented toward a prohibitive form of harassment, including that which is sexual in nature and unwelcome.

  • Nonverbal sexual harassment includes the distribution, display, or discussion of any written or graphic material, including calendars, posters, and cartoons that are sexually suggestive or show hostility toward an individual or group because of sex; suggestive or insulting sounds; leering; staring; whistling; obscene gestures; content in letters, notes, facsimiles, e-mails, photos, text messages, tweets, and Internet postings; or other forms of communication that are sexual in nature and offensive.

  • Physical sexual harassment includes unwelcome, unwanted physical contact, including touching, tickling, pinching, patting, brushing up against, hugging, cornering, kissing, fondling, and forced sexual intercourse or assault.

Courteous, mutually respectful, pleasant, non-coercive interactions between employees that are appropriate in the workplace and acceptable to and welcomed by both parties are not considered to be harassment, including sexual harassment.

Responding to Conduct in Violation of Policy

Employees. If an employee feels that he or she is being subjected to discrimination or harassment, he or she may immediately inform the harasser that the conduct is unwelcome and needs to stop. If the inappropriate conduct does not cease, or if the employee is unable to or uncomfortable with addressing the alleged harasser directly, he or she should report the incident to his or her own supervisor or to ACS HR. It is helpful, but not required, to provide a written record of the date, time, and nature of the incident(s) and the names of any witnesses.

It is important to report all concerns of harassment or inappropriate conduct to a supervisor/manager or to ACS HR as soon as possible. Management must be made aware of the situation so that it can conduct an immediate and impartial investigation and take appropriate action to remediate or prevent the prohibited conduct from continuing.

Managers and supervisors. Managers and supervisors must deal expeditiously and fairly when they have any knowledge of discrimination or harassment within their departments, whether or not there has been a written or formal complaint. As an ACS manager, you must:

  • Take all complaints or concerns of alleged or possible discrimination or harassment seriously no matter how minor or who is involved.

  • Report all incidents to ACS HR immediately so that a prompt investigation can occur.

  • In collaboration with ACS HR, take appropriate action to prevent retaliation or prohibited conduct from recurring during and after any investigations or complaints.

Managers and supervisors who knowingly allow or tolerate discrimination, harassment, or retaliation, including the failure to immediately report such misconduct to HR, are in violation of this policy and subject to discipline.

Human Resources. Acting for HR, the ACS Managing Partner for Corporate Infrastructure is responsible for:

  • Ensuring that both the individual filing the complaint (complainant) and the accused individual (respondent) are aware of the seriousness of a discrimination or harassment complaint.

  • Explaining ACS' anti-harassment policy and investigation procedures to all parties involved.

  • Exploring informal means of resolving complaints.

  • Notifying the police if criminal activities are alleged.

  • Arranging for an investigation of the alleged harassment and the preparation of a written report.

  • Submitting a written report summarizing the results of the investigation and making recommendations to designated company officials.

  • Notifying the complainant and the respondent of the corrective actions to be taken, if any, and administering those actions.

The ACS Managing Partner for Corporate Infrastructure will determine if an in-house investigation will be conducted or if a third party will be contracted to complete the investigation.

We Provide a Safe and Productive Work Environment for All Employees

ACS is committed to providing a safe and productive work environment for all employees. Alcohol and drug abuse pose a threat to the health and safety of employees and to the security of our equipment and facilities. For these reasons, ACS is committed to the elimination of drug and/or alcohol use and abuse in the workplace.

Drug-Free Policy

We prohibit the unlawful manufacture, distribution, dispensing, possession, or use of a controlled substance on a Government facility or any ACS location. To comply with the Drug-Free Workplace Act and to protect your safety and the safety of all of our employees, we will enforce this policy. On occasion, ACS will have alcoholic beverages on the premises for use in celebrations or recognition of a special event or after-hours social gatherings. In these instances, we ask that our staff use common sense in their consumption of these beverages.

Employees should report to work fit for duty and free of any adverse effects of illegal drugs or alcohol. This policy does not prohibit employees from the lawful use and possession of prescribed medications. However, employees must consult with their doctor about the medication's effect on their fitness for duty and ability to work safely, and promptly disclose any work restrictions to their manager. Employees should not disclose underlying medical conditions unless directed to do so.

Smoke-Free Policy

ACS is committed to a smoke-free/tobacco-free work environment. Use of any tobacco products, smoking, chewing, or vaping is not permitted inside of ACS offices and facilities or on client work sites where ACS clients have a similar policy. Usage of smoking cessation products such as gum or patches are permitted as long as they do not emit a by-product.

Violence-Free Policy

All employees, customers, vendors, and business associates must be treated with courtesy and respect at all times. Employees are expected to refrain from conduct that may be dangerous to others. We prohibit any language or actions on the part of employees that could have any coercive, intimidating, or threatening effect on another employee, visitor, customer, or vendor. Likewise, no visitor, customer, or vendor is permitted to create an unfriendly, intimidating, or threatening effect against a Company employee.

Indirect or direct threats of violence, incidents of actual violence, and suspicious individuals or activities should be reported as soon as possible to a manager, security personnel, Human Resources, or any member of senior management. When reporting a threat or incident of violence, the employee should be as specific and detailed as possible. Employees should not place themselves in peril, nor should they attempt to intercede during an incident. Employees should promptly inform the Human Resources department and Security personnel of any protective or restraining order that they have obtained that lists the workplace as a protected area.

ACS prohibits the possession of firearms, fireworks, or other weapons on its premises. Any employee witnessing behavior which is erratic, abusive, threatening, or otherwise troublesome by anyone on ACS or client premises is required to report it immediately to any management personnel. Any employee who engages in threatening or violent behavior, or who behaves in a way that could provoke violence, may be disciplined to include termination and may be subject to criminal prosecution.