CODE OF ETHICS AND BUSINESS CONDUCT
INTRODUCTION: DRC Emergency Services, LLC strives to provide the most dependable, honest, customer-centric services in the industry, while upholding the highest standards of ethical conduct and compliance at all times. To better ensure our continued compliance with law and rules and regulations, DRC's senior management has established a formal code of business conduct. By implementing these guidelines, DRC is fully demonstrating its commitment to adhere to the highest professional standards and to act as a trustworthy source of unique capabilities to our public and private contracting partners. In addition, we expect that all contractors and individuals who work with us while serving our public and private customers, shall also adhere to the highest ethical business conduct standards.
Kristy Fuentes, DRC's Chief Compliance Officer, oversees the Corporate Compliance Program, functioning as an independent and objective body that reviews and evaluates compliance issues/concerns within the organization as well as external issues relating to DRC's interaction with Customers. The position ensures the Board of Directors, Management, our employees and our Customers are in compliance with the rules and regulations of regulatory agencies, that company policies and procedures are being followed, and that behavior in the organization meets the company's Standards of Conduct. The Chief Compliance Officer acts as staff to the CEO and as an independent report to the Board of Directors and General Richard Bednar (DRC's independent third party compliance consultant). The CCO monitors and reports results of the compliance/ethics efforts of the company and provides guidance for the Board and senior management team on matters relating to compliance. The Chief Compliance Officer, together with General Bednar, is authorized to implement all necessary actions to ensure achievement of the objectives of an effective compliance program.
The Corporate Compliance Office exists:
- As a channel of communication to receive and direct compliance issues to appropriate resources, including DRC's independent third party compliance consultant, for investigation and resolution, and
- As an independent conduit to the Board of Directors regarding Company activities
- As a final internal resource with which concerned parties may communicate after other formal channels and resources have been exhausted.
- As a resource to our individual Customer base regarding contract compliance, environmental compliance and any and all issues involving contract performance.
“AT WILL" EMPLOYMENT: This Code sets forth policies and practices regarding the conduct of all DRC employees. You are required to comply with this Code as a condition of your employment. This document does not provide you with any guarantee of continued employment at DRC. Unless covered by express written employment agreement or by applicable law, all employees of DRC are employed on an “at will" basis. This means you or DRC can end the employment relationship at any time with or without cause, and without prior notice, for any reason not prohibited by law. This Code may be unilaterally modified by DRC at any time.
VISION: DRC Emergency Services, by virtue of its preparedness, responsiveness, demonstrated comprehensive competency, ethical business conduct and fair pricing aspires to be the “first in response" for natural and physical disasters requiring an urgent response team.
OUR CORE VALUES:
Tell the Truth. In all business matters we are committed to finding the truth and telling the truth. Truth telling is a fundamental obligation of the DRC Emergency Services executive leadership and all employees.
Use Common Sense and Good Judgment. We rely on the integrity of our employees and expect that they apply common sense and good judgment even when no one is watching.
Work Hard. We expect all employees to give the full measure of honest effort to their working responsibilities, while maintaining a healthy life balance with wholesome off-duty interests and activities.
Be Prepared. The nature of our emergency services work demands that all of us be in a continuing state of readiness. Responding to urgent calls for our help with the right personnel and equipment assets sets us apart from the competition.
Be Accountable. We are accountable for everything we do or fail to do. We take ownership of our actions and stand up to the consequences of those actions whether positive or harmful to our customers or our Company.
Show Courtesy and Respect. Our culture is built on the initiative, strengths and dedication of our people. We treat each other with respect, honesty, courtesy and fairness. We value the different skills, perspectives and experiences of our people.
Protect Privacy: The privacy and integrity of customer and employee records and information is part of showing respect. Personal or private information should be disclosed only after conferring with and receiving permission from the individual or customer.
HOW ARE THESE CORE VALUES APPLIED?
We apply our core values to the constituencies with whom we interact.
- To our customers we place highest priority on the timeliness of our response, our practical effectiveness, and the quality of our services and solutions.
- To our fellow employees we look out for their welfare, safety and health. We promote an environment that encourages new ideas, doing the right thing, enjoyment of work and equal opportunity for advancement.
- To our suppliers and subcontractors we are fair and professional in all our dealings. We honor our commitments to our business partners. We select business partners who will adhere to ethical standards.
- To our neighbors wherever we work we are responsible citizens who respect the laws and customs of the communities in which we work.
WHO IS REQUIRED TO COMPLY WITH THIS CODE?
Every employee—including supervisors, managers and officers—must comply with this Code of Business Conduct. DRC Emergency Services personnel are required to report any observed or suspected violation of this Code to their supervisor or to the Ethics and Compliance Officer or directly to Mark Stafford, Chief Executive Officer.
COMPLIANCE WITH LAWS, RULES AND REGULATIONS:
This Code cannot cover every situation our employees may encounter. Our default requirement is simple: use common sense, good judgment and do the right thing. We strive to ensure our employees know the laws, rules and regulations that apply to their job responsibilities. All employees are required to comply with all laws, rules and regulations applicable to us wherever we work. This Code is supplemented by our Employee Handbook, which is required reading for all full-time and temporary employees.
IF YOU HAVE QUESTIONS OR CONCERNS ABOUT THE LAWS, RULES AND REGULATIONS APPLICABLE TO YOUR JOB AND RESPONSIBILITIES STOP AND IMMEDIATELY CONTACT MARK STAFFORD (CELL: 504-415-7945)
While we desire to address our employees' concerns internally, nothing in this Code or otherwise published by the Company should discourage any employee from reporting any illegal activity, including violations of law, rules or regulations, to the appropriate governmental authority. Nothing in this Code or otherwise published by the Company is intended to prohibit employees from reporting, testifying or otherwise assisting in any state, federal or municipal judicial, administrative or legislative proceeding or investigation.
PRACTICAL GUIDANCE IN MAKING ETHICAL DECISIONS:
Most people know intuitively what the “right thing to do" is. But all of us sometimes need to pause and consult our “gut" before we are confident that what we are about to do or say is ethically correct. Some people find it helpful to ask themselves questions to be confident they are on the right track.
Would I be embarrassed to have to explain this decision to my spouse or partner or mother? How would I feel if someone acted the same way toward me? Would I be glad to see this written up in the newspapers?
There are two parts to ethical decision making. First, to know it is the right thing to do. Second, to have the self-discipline to act appropriately.
STANDARDS OF CONDUCT:
We want DRC Emergency Services to be known as an organization of the best people who work as a team to provide solutions to our customers' urgent problems, while always doing the right thing. We recognize that
how we do our work is as important as what work we do. What we do and how we do it deserve our best efforts every day. We will not tolerate any short cuts when it comes to our ethical values and standards of conduct.
The following are the most common matters in which ethical issues may arise:
- Accurate and Daily Time Charging. Employees are personally responsible to ensure that their labor costs are properly recorded. This means maintaining an accurate, daily record of time spent by task and certifying a timesheet each week. Inaccuracies in time charging records could constitute a violation of law and expose the employee and the Company to serious fines and other penalties. Managers are personally responsible to review their employees' timecards for accuracy and to challenge questionable entries. Managers are required to certify the accuracy of each employee's timesheet by signing or initialing the card.
- Drug-Free Work Environment. Employees are not permitted to drink alcoholic beverages while on Company time or on any Company premises, except if served at a Company-sponsored event. Alcohol consumption at a Company-sponsored event is completely voluntary and should be in moderation. Any employee who, on Company time or premises, uses, transfers, sells, manufactures or possesses illegal drugs or controlled substances or who abuses legal drugs will be subject to disciplinary action, up to and including dismissal, as well as referral for possible criminal prosecution.
- Prohibited Items in Work Areas. Employees are prohibited from having the following items in any area in which our work is being performed:
- Firearms, weapons, explosives, incendiary devices or illegal articles or substances, and anything that may be used to threaten or inflict bodily harm or to intimidate.
- Controlled substances, such as illegal drugs, associated drug paraphernalia and unlawfully obtained prescription drugs.
- Contraband – meaning, anything that is illegal to possess.
Violations of this rule may result in severe discipline, up to and including immediate dismissal.
- Harassment and Hostility-Free Working Environment. Our Company is committed to promoting a work environment free of sexual harassment or other harassment based on age, race, national origin, religion, gender, disability, sexual orientation or any other legally protected category under federal, state or local law. Harassment in any form, especially sexual harassment, is prohibited. Harassment includes unwelcome conduct that:
- Creates an intimidating, hostile, or offensive work environment; or
- Is sufficiently pervasive to interfere with an employee's work performance; or
- Is made an explicit or implicit condition of employment or is the basis of an employment decision; or
- Threatens the use of force or intimidation against another employee or another employee's family.
Conduct which can contribute to an offensive work environment includes but is not limited to: unwelcome sexual advances; innuendoes; requests for sexual favors; physical contact; unwelcome or repeated propositions; unwelcome flirtations; epithets; slurs; offensive jokes or pranks; and offensive verbal, visual or physical conduct of a sexual nature, whether spoken, written or communicated electronically. Each employee is personally responsible for treating others with respect, dignity and fairness, and ensuring that their conduct is free of any actions that constitute or give the appearance of unlawful discrimination or sexual harassment.
- Diversity and Equal Employment Opportunity. Our Company provides and inclusive environment where employees with diverse skills, attributes and perspectives are respected and welcomed. Our Company is committed to equal employment opportunity and encourages the establishment and maintenance of a workplace that fosters trust, equality and teamwork. We expect those with whom we conduct business to observe similar standards respecting workplace diversity and equal employment opportunity. Is the policy of DRC to comply fully with all laws providing equal opportunity to all persons without regard to race, gender, age, color, religion, national origin, sexual orientation, disability, marital status, veteran status, citizenship status, or any other protected category under federal, state or local law
- Conflicts of Interest and Moonlighting. Our policy is based on the proposition that no one can fairly serve two masters at the same time. Conflicts exist when there is a potential for divided loyalties; you may act to further your interests – or those of your friends or family – instead of the interests of the Company. We expect all of our employees to perform their duties with exclusive allegiance to the best interests of DRC Emergency Services. Conduct and actions by our employees are expected always to be in the best interest of the Company and not influenced by personal interests or the interests of your family, personal relationships, allegiances, benefit or gain. All employees who are concerned they may have or are about to have a personal conflict of interest are required to bring the matter to the attention of our Ethics & Compliance Officer for discussion and resolution. Because personal conflicts of interest may reflect adversely on the Company, we expect our employees to avoid even the appearance of a conflict of interest and to bring potential conflicts of interest to the attention of our Ethics & Compliance Officer for discussion and resolution. For example:
- You should remove yourself from any partner or vendor selection process that includes a partner/vendor in which you have, directly or indirectly, a personal interest.
- Do not accept or give anything as a “quid pro quo," that is for doing something in return for the gift or entertainment.
- Do not accept or give anything that could be viewed as a bribe, payoff or improper Influence.
- Never use your position in any way to obtain anything of value from prospective or existing clients, suppliers, vendors or persons to whom you refer business.
- Never provide gifts or entertainment to an existing or prospective client, supplier or vendor not recorded properly in the company books and records.
If you have any doubt about whether a conflict exists, treat the situation as if there is a conflict until you have disclosed and resolved the issue. Outside employment by our full time employees is discouraged for the reason that outside employment may raise the appearance of a conflict of interest for DRC Emergency Services or its customers. Only the CEO has authority to approve requests for outside employment; no employee may have outside employment without prior CEO approval.
- Conducting our Business with Integrity. Our executives and employees are expected to deal honestly and fairly with our customers, suppliers, competitors, regulators and with each other. Statements regarding our solutions, services and capabilities must be truthful, avoiding all potential for deception and falsity. We do not take unfair advantage of anyone through manipulation, concealment or misrepresentation. In doing business with federal, state and local governments we adhere to their rules and regulations that touch our work and our business conduct.
- Business Courtesies. Our business relationships must be free from all perceptions that favorable treatment is being sought, received or given as a result of or because of a gift or gratuity. We do not give or accept any gift or business courtesy from anyone in federal, state or local government for any reason or purpose. We expect our employees to apply common sense and good judgment in giving or accepting business courtesies to and from commercial customers.
- Kickbacks, Bribes and Fraud. We strictly comply with the law prohibiting the giving or accepting of any money, credit, gift or anything of value for or because of favorable treatment in connection with a government prime contract or subcontract. Our employees are prohibited from soliciting or accepting kickbacks from customers, vendors or subcontractors.
- Proper Use of DRC Emergency Services Funds, Equipment and Physical Assets. We require our employees to protect the Company's funds, equipment and other physical assets. Theft, waste, or unsafe and careless use of these assets is strictly prohibited. Company funds, equipment and other physical assets may be used only for legitimate business purposes and not for any personal benefit or the benefit of anyone else.
- Company Books, Records and Public Reports. DRC Emergency Services strongly believes in honest and accurate recording and reporting. Our books, records and accounts must be maintained in compliance with all applicable regulations and acceptable accounting standards and must accurately reflect the truth of the transactions. We provide full, fair, accurate, understandable and timely disclosure in reports.
- Confidential Information and Intellectual Property. Private, proprietary and confidential information and intellectual property belonging to or in the care of DRC is of great value to the Company and to others and must not be disclosed without proper legal process or used for non-business purposes. This information includes company pricing and proposals; terms of contracts; billing information and quantities of service; employee information, including individual compensation; proprietary information provided to the Company in connection with a non-disclosure or non-disclosure agreements; and similar information. When not in use, confidential information must be securely stored. Any attempt by an unauthorized person to obtain confidential information, should be reported immediately to your supervisor or the Ethics and Compliance Officer.
- International Operations. There will be times when employees are required to conduct business internationally. Should you be required to travel outside of the United States on behalf of DRC, consult with the Ethics and Compliance Officer for guidance regarding our legal obligations and Company policies. No employee may engage in any such business without appropriate training, including full coverage of the Foreign Corrupt Practices Act.
DRC Emergency Services Employees shall comply with this Code and all other DRC Emergency Services work rules and other publications. Employees are required to report all observed or suspected violations of law or of this Code (including violations involving fraud, conflicts of interest, bribery, gratuities, false claims and overpayments on federal, state or local contracts). Reports may be made openly or confidentially to the employee's manager, the Ethics & Compliance Officer, Don Johnson (251-343-3581), the DRC Emergency Services Hotline (844-240-0005) or to the Chief Executive Officer. All reports of observed or suspected misconduct will be investigated within the Company and such action and discipline will be taken as is appropriate.
DRC Emergency Services does not tolerate retaliation in any form against individuals who, in good faith, report concerns, raise questions or participate in the investigation of suspected misconduct. Retaliation against employees for good faith reporting of misconduct or for participating in an investigation is a serious breach of this Code and will result in disciplinary action up to and including dismissal.
Policy Encouraging a “Speak Up" Culture: This Policy encourages Employees to report observed or suspected misconduct, provides the mechanism for doing so and protects those that report perceived misconduct from retaliation.
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Ethics and Compliance as an Element of Performance Standards: This Policy establishes the baseline for ethical conduct and compliance with the law.
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Policy Regarding Employment of Suspended or Debarred Individuals: This Policy sets a standard for only employing personnel and consultants that are not excluded from Federal Procurement Programs and employing only persons that demonstrate honesty and integrity.
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