BT Government Code of Conduct

Section 1: Commitment to Employees, Customers, Communities, and a Culture of Integrity

BT Government is committed to helping our Employees make the most of their skills and talents – so they can shine brightly and help the Company do the same. We trust each other, support each other, learn from each other, and seek to build a community of professionals who own each other’s outcomes, win for each other, keep an open mind, are trusted resources, sharpen our saws, and share a common success. BT Government’s Code of Conduct is simply an extension of these core values. We believe personal integrity, ethical business practices and holding each other accountable to the same results in development, growth, and our ultimate success story. The Code of Conduct is a resource for our Employees and anyone who represents BT Government.

It is through our business behaviors that the integrity of BT Government is built and maintained. BT Government provides multiple avenues and processes through which we have the right, responsibility, and obligation to raise questions, seek clarifications and report potential compromises. Through our commitment to use these processes, BT Government’s strong ethical culture is continually reinforced. BT Government Employees, consultants, and anyone with whom we do business are expected to uphold the following BT Government standards:

• We are dedicated to continuous improvement, development, and growth.
• We embrace different ideas and perspectives. We observe and support all applicable laws and regulations concerning equal employment opportunities and do not tolerate race, color, religion, national origin, sexual orientation, disability, gender, gender identity or expression, or age discrimination as well as discrimination in any other protected classification.
• We hold ourselves accountable to each other.
• We are committed to providing a safe and healthy work environment for all employees and visitors.
• We observe all laws and regulations governing business transactions, engage in fair competitive actions, and use company funds only for legitimate and ethical purposes.
• We report any suspected fraudulent activities of which we may learn or observe.
• We value the local communities in which we operate and are regular and active contributors to the needs of our communities.

It is each Employee’s responsibility to be aware of the regional requirements that may have a global impact. For example:

• Employees may be subject to the laws, rules, and regulations of different countries and organizations.
• BT Government is a corporation organized in the United States, and U.S. law may apply even when business activities are conducted outside of the U.S. Similarly, other countries may apply their laws outside of their boundaries.

How to Raise Questions or Concerns

Employees are encouraged and expected to raise any concerns they have regarding the practices of the company, its Employees or agents and are expected to report any suspected violations or suspected violations of applicable U.S. laws, regulations, or company policies. Avenues for raising questions and/or concerns include top management, Human Resources, and the Legal Department.

When reporting an ethics concern:

• You will be treated with dignity and respect.
• Your communication will be protected to the greatest extent possible.
• Your concerns will be seriously addressed and, if not resolved at the time you call, you will be informed upon resolution.
• You need not identify yourself. If you do identify yourself, you may request that your identity not be disclosed to others.
• There is no penalty for reporting or making an inquiry and there will be no retribution. If anyone tries to stop you, or retaliates because you do, they are subject to disciplinary action.

Consequences for Failure to Adhere to Company Policies, Procedures, or the Code of Conduct

BT Government has developed policies and procedures. The Code of Conduct and BT Government policies and procedures apply to all Employees and BT Government subsidiaries. Due to the nature of our business, there are additional work rules and policies that must be followed within specific work groups. All Employees are expected to be familiar with the intent of these policies and procedures and to fully understand those that apply to their job duties. Violation of any of these rules, company policies, procedures, or the Code of Conduct may result in disciplinary action up to and including termination.

BT Government takes the commitment to business integrity seriously and will take appropriate action in response to all violations of our Code, company policies or procedures. Allegations of misconduct are thoroughly investigated and if the investigation substantiates that a violation occurred, appropriate disciplinary or corrective actions are initiated.

BT Government may choose to take disciplinary action depending on the individual circumstances of any given situation including, but not limited to, disciplinary actions such as verbal warnings, written warnings, suspension, or immediate termination of employment, which may be taken in any order. There is no progressive disciplinary process, and no Employee is guaranteed the right to receive discipline before being terminated. Obviously, it is not possible to list every type of conduct which may result in disciplinary action. The following kinds of conduct are absolutely prohibited and may result in immediate termination:

• Abuse, mistreatment, or threatening another Employee, either physical, verbal, or psychological;
• Loafing or sleeping on the job during the Employee’s working hours;
• Dishonesty;
• Violation of any and all safety rules;
• Poor attitude or disrespect to your People Leader, customers, or visitors to the Company;
• Violating the Company’s policies on Equal Employment Opportunity or Anti-Harassment;
• Failing to attend a scheduled meeting;
• Falsification of time or work records, failing to properly report all hours worked, or working overtime without authorization;
• Abusing, defacing, or destroying BT Government property or the property of customers or fellow Employees;
• Unauthorized possession, use, copying or disclosure of any confidential information or trade secrets about the Company, its customers, or vendors;
• Unprofessional conduct, such as gambling or fighting on the Company property, coercion, intimidation, or threats of any kind against people leaders, fellow Employees, customers, or guests; making false statements about the Company, its Employees, or its customers;
• Falsification of any employment records while applying for employment or at any time during employment;
• Interfering with or hindering work schedules, failing to work a shift as scheduled, or arranging your own replacement on a shift without the permission of your People Leader;
• Failure to return to work on a timely basis following expiration of an approved leave of absence;
• Theft (unauthorized removal), attempted theft or misappropriation (unauthorized storage, transfer, or use) of BT Government, Employee, or customer property, including items found on the Company premises. All articles found must be turned into your People Leader;
• Refusal to allow periodic security inspections of BT Government property within Employee control and Employee property brought onto Company premises;
• Refusing to obey the direct request of a People Leader, unless such request is illegal;
• Refusing to cooperate with a BT Government investigation, or failing to report a violation of BT Government policies and procedures;
• Dishonest, immoral, illegal, or indecent conduct, soliciting persons for immoral purposes, violating BT Government’s Anti-Corruption Policy or the aiding, and/or abetting of any of these activities;
• Failure to comply with the Substance Abuse Policy; and/or
• Failure to comply with the Company’s Electronic Devices, Equipment, and Confidential Data policies.

Section 2. Our Commitment to a Safe, Diverse, and Respectable Work Environment

Providing a Non-Discriminatory and Hostile-Free Workplace

BT Government is committed to maintaining a work environment that respects the dignity and contribution of each individual and permits us to work free from intimidation, coercion, or unlawful harassment, including sexual harassment.

Preventing harassment, discrimination and threats are a matter of respecting each other’s rights and dignity. Discrimination harassment infringes on an individual’s right to work environment that is free from intimidating or offensive behavior, and BT Government does not tolerate such actions. We must take all such issues seriously and promptly report them to management, Human Resources, and/or the Legal Department without fear of retaliation.

It is our policy to foster a diverse workplace and environment of inclusion. Any behavior that reflects unlawful discrimination violates BT Government values and will not be tolerated, as it undermines our ability to work as a cohesive team. In addition, we do not tolerate acts of verbal or physical behavior that could lead to or cause workplace violence.

Maintaining Diversity & Being an Ally

Embracing our unique ideas, perspectives and capabilities promotes the best outcome for everyone. We recognize the attributes and talents of a diverse workplace committed to winning for each other and being allies to one another strengthens and expands our business opportunities. BT Government is committed to equal employment and contractual opportunities without regard to race, color, religion, sex, national origin, gender, gender identity or expression, age, medical condition or disability, sexual orientation, veteran status, or any other characteristic protected by law. For more information, please reference the Handbook.

Consultants, Representatives, and Third Parties

BT Government does business with consultants, representatives, and third parties who share our values and commitment to business integrity, as their actions can impact the reputation of our organization. It is our expectation that consultants, representatives, and third parties must certify their willingness to comply before entering into a business relationship.

Section 3: Our Commitment to Environmental Safety, Sustainability, and Stewardship

BT Government is committed to the health and safety of Employees, clients, and the community. To this end, BT Government makes reasonable efforts to minimize risks associated with operations and to ensure a healthy and productive workplace. BT Government is committed to a work environment that is safe, secure, and free from violence, threats of violence, harassment, intimidation, and other disruptive behavior. All reports of incidents will be taken seriously and dealt with appropriately. Individuals who commit such acts may be removed from the premises and may be subject to disciplinary action, up to and including termination, criminal penalties, or both.

Safety is an integral part of each Employee’s job. All Employees are responsible for working carefully and maintaining a general safety awareness of their surroundings, to use good judgment and common sense, to follow proper procedures and to comply with OSHA (Occupational Safety and Health Administration) standards and BT Government safety rules. Employees who are subject to or become aware of unsafe working conditions or other workplace health and safety issues should report those to their People Leader or the Human Resources team by contacting [email protected] immediately. No adverse action will be taken against any Employee who, in good faith, reports a suspected safety issue or unsafe working conditions. Remember, if you see something, say something!!

Safety Protocol Guidelines:

• Notify your People Leader or the Human Resources team of any emergency. Employees who are injured or become sick at work, no matter how slightly, must inform their People Leader or the Human Resources team as soon as possible;
• Understand your job fully and follow instructions. Employees who are not sure of the correct, safe procedure to follow should not guess but should ask your People Leader;
• Do not circumvent, disconnect, or render any safety or protective device inoperable. Do not operate equipment that is unsafe.

If you witness, become aware of, or experience workplace violence or if there is a situation where you feel physically uncomfortable, you must immediately notify the Human Resources team by contacting [email protected]. The Human Resources team is here to support all Employees. In case of emergency, please contact emergency services by calling 9-1-1.

Reports can be made to the Human Resources team by contacting at [email protected].

Employees should limit as much as possible the use of mobile technology, including cellular phones, while driving for work purposes and must not send or read text messages or e-mails, dial cellular phones, view television, videos or DVDs and must avoid inputting data into laptop computers, personal digital assistants or navigation systems while driving. Employees must comply with all federal, state, and local laws and regulations regarding the use of mobile technology devices including cellular phones.

In support of BT Government’s commitment to workplace safety, BT Government also has a no weapons policy. No Employee, visitor, guest, vendor, or anyone else dealing with BT Government may possess, transport, or use a weapon of any kind while on BT Government property, in a BT Government vehicle, or at any BT Government sponsored event. The only exception to this rule is in the case of a firearm locked in a Employee’s personal vehicle pursuant to state and/or local law. Employees are prohibited from removing such firearms from their vehicles while on BT Government property for any reason except lawful defensive purposes. Company vehicles may not be used to transport weapons. Weapons include all firearms, knives with blades longer than four (4) inches, explosives, or any device which is likely to produce bodily harm and which BT Government, at its discretion, deems dangerous.

Any People Leader who becomes aware of any safety concerns, incidents or alleged incidents of workplace violence, or other unsafe working condition is required to immediately report the matter directly to the Human Resources team by contacting [email protected].

Environmental, Social, and Governance (ESG) Commitment

We are committed to providing a safe and healthy work environment. Each of us is responsible for compliance with environmental, health and safety laws and regulations. We consistently seek to reduce, minimize, or eliminate the generation of waste or the release of potentially hazardous materials into the environment. We must strive to create a company culture in which environmental concerns are recognized as priority considerations in all our decisions, as well as recognize and respond to community concern.

Section 4: Our Commitment to Ethical Business Practices

BT Government and its Employees shall strive to act with honesty, integrity, and the utmost of ethical business practices. Failure to do so may not only place the Employees at issue at risk of termination, but it may jeopardize BT Government’s relationship with its customers and could expose both the company and any individual Employees involved to substantial fines or penalties. Violations could also lead to the company or individual Employees being suspended or debarred from being awarded or receiving payment on contracts with the Government.

Personal Conflicts of Interest

We are all expected to make decisions that are in the best interest of BT Government and/or its customers, without any consideration to personal gain. Any current or future activity which is or could create a conflict of interest, either in practice or appearance, must be disclosed to the Legal Department for approval. This applies to Employees, Employee spouses, children and/or parents. Displaying favoritism or having conflicts of interest runs counter to BT Government’s values and ethical culture. All actions made in the performance of our jobs must be done with integrity, honesty, and fairness. Representative examples of personal conflicts of interest (not all-inclusive) include:

• Employment by a competitor or potential competitor;
• Engaging in outside employment or non-employment activities, such as self-employment, that are in conflict with your commitment to BT Government or our interests or that is conducted on Company property, during business hours, or for targeting coworkers for solicitation;
• Placement of business with a firm owned or contracted by a Employee or Employee family member;
• Acting as a consultant to or conducting personal side business with a current or potential BT Government customer, supplier, vendor subcontractor, and/or competitor;
• Maintaining a financial interest in or relationship with a customer, supplier, competitor, distributor, or any other organization that would create a conflict of interest;
• Romantic relationships between a People Leader (including those involved in hiring, promotion, termination, discipline, and compensation decisions) and any Employee they supervise, whether directly or indirectly, are prohibited. Reporting of romantic relationships is mandatory and must be made by both Employees to the Human Resources team by contacting [email protected]. If a romantic relationship exists, the individuals involved may be moved to separate work groups, or BT Government may require one or both to decide who will remain employed, as deemed necessary by BT Government; and/or
• Supervision of relatives by People Leaders (including those involved in hiring, promotion, termination, discipline, and compensation decisions) is prohibited. Reporting of employment of relatives is mandatory and must be made to the Human Resources team by contacting [email protected]. If relatives are employed, the individuals involved may be moved to separate work groups, or BT Government may require one or both to decide who will remain employed, as deemed necessary by BT Government.

Organizational Conflicts of Interest

An “Organizational Conflict of Interest” may exist where BT Government has, or may appear to have, interests that may make it difficult to honestly, objectively, and effectively perform its duties and responsibilities on its government contracts. For example, an Organizational Conflict of Interest may arise where:

• The nature of the work to be performed by BT Government may result in an unfair competitive advantage for the company; or
• The company had unequal access to nonpublic information or data related to the work; or
• The company’s objectivity in performing the work is impaired or the company is otherwise unable to render impartial assistance or advice to the Government.

Procurement Integrity Laws

The company is committed to competing fairly and ethically for business opportunities. The Procurement Integrity Act protects the process by which federal agencies acquire goods or services by using competitive procedures to award contracts. Under the Act, company Employees may not receive “source selection information” from current or former government officials who attempt to improperly influence the bidding process. “Source Selection Information” includes:

• Bid prices for sealed bids or lists or prices;
• Source Selection plans;
• Technical evaluation plans;
• Technical evaluations of competing proposals;
• Competitive range determinations;
• Rankings of bids, proposals, or competitors;
• Cost or price evaluations;
• Source Selection Board reports and evaluations;
• Source Selection Advisory Board recommendations;
• Proposed costs or prices submitted; and/or
• Any other information marked as “Source Selection Information”

Also under the Act, company Employees may not improperly obtain contractor bid and proposal information – that is, non-public information submitted to a federal agency as part of or in connection with a bid or proposal. Such information includes:

• Cost or pricing data;
• Indirect costs and direct labor rates;
• Information about manufacturing processes, operations and techniques when marked “proprietary” or “source selection information” in accordance with the law or regulation;
• Information marked as “contractor bid or proposal information”; and/or
• Any other material or information related to a specific procurement which a company making a bid deems proprietary

Employees involved in the negotiation of contracts must ensure that all statements, communications, and representations of fact to client representatives are accurate and truthful. No Employee shall submit any claims, bids, proposals or any other documents of any kind that are false, fictitious, fraudulent, or misleading. Similarly, when required, the company will provide cost or pricing data, together with a certification that such data are current, accurate and complete. Personnel involved in the negotiations are expected to be familiar with this policy and the requirements of the Truth in Negotiations Act.

Bribes, Gifts and Gratuities, Kickbacks and Facilitation Payments

Anyone representing BT Government must conduct business with customers, subcontractors and suppliers on the basis of service, quality, performance, and price without giving or accepting anything that could influence or appear to influence the business transaction decision, whether paid by company or personal funds.

In the United States it is illegal to provide, offer, or accept a kickback or bribe. A kickback or bribe may be defined as any money, fee, commission, credit, gift, gratuity, thing of value or compensation of any kind that is provided, directly or indirectly, and that has as one of its purposes the improper obtaining or rewarding of favorable treatment in a business transaction.

For customers and suppliers in or from foreign countries, similar restrictions on the giving or receipt of bribes and kickbacks apply. The Foreign Corrupt Practices Act and foreign country laws prevent the giving of anything of value, including money, fee, commission, credit, gift, gratuity, thing of value or compensation of any kind that is provided, directly or indirectly, to individuals and agents associated with foreign governments for the purpose of obtaining or retaining business in foreign countries. Included in this prohibition is the provision of anything of value to third-party intermediaries (otherwise known as “facilitation payments”) for the sole purpose obtaining or retaining business or favorable treatment in foreign countries. The engagement of third-party intermediaries is not always prohibited, and each scenario or engagement should be treated on a case-by-case basis. If you have any questions or concerns regarding the engagement of a third-party intermediary, please contact BT Government’s Legal Department.

BT Government does not permit the offering or receipt of kickbacks and bribes. Employees are responsible for consulting and understanding the laws, regulations, and applicable policies before providing anything of value, including consulting contracts, to Employees or agents of foreign governments.

Business Courtesies

Within the commercial business world, the giving and receipt of business courtesies can be considered part of a normal business relationship. The term “business courtesies” includes, but is not limited to, gifts, services, meals, entertainment, hospitality, or other things of value. BT Government does not provide or accept business courtesies from or to customers, actual or potential suppliers, service providers, or contractors that could be considered inconsistent with typical marketplace practices, frequent in nature, lavish or extravagant or otherwise obligate or appear to obligate us to act in any way contrary to the law, the company’s business interests, or our core values or ethical business practices.

It is the responsibility of each company Employee to inquire about prohibitions or limitations of the recipient's organization before offering any business courtesy. When considering accepting a business courtesy, be aware that we all have personal responsibility to ensure that our acceptance could not reasonably be construed in any way as an attempt by the offering to secure favorable treatment.

Gifts and Gratuities in Government Business

Federal, state, and local government departments, agencies and their Employees are governed by differing laws and regulations concerning acceptance of meals, gifts, gratuities or any other item of value from firms or persons with whom they do business or over whom they have regulatory authority. What may be considered an acceptable business courtesy in the commercial business world could be unacceptable, or even illegal, for individuals or companies involved in state, local or federal jobs.

Company Employees may not give any gift, gratuity, loan, meal, entertainment, hospitality, or any other thing of value to government Employees or agents.

Donations/Charitable Contributions and Political Contributions

Employees are not prohibited from making personal donations or contributions to charitable organizations; however, all such donations or contributions made on behalf of the Company or in the name of the Company must be pre-approved by relevant Company executives. Please contact the Human Resources or Marketing departments for further inquiries.

Employees are not permitted to make political contributions on behalf of, or in the name of, BT Government. Political contributions are anything of value given, loaned or advanced for the purpose of influencing or funding an election or political campaign. Not only are federal government contractors (which designation may apply to the Company) prohibited from making contributions or expenditures in connection with federal elections, but there are many federal and state laws governing political contributions. We encourage Employees who have any questions or concerns with respect to political contributions to contact the Legal Department.

Submitting Accurate Certifications and Billing, Pricing and Performance Information

BT Government is committed to making proper certifications and providing accurate information regarding its billing, pricing, and performance practices to its customers. Failure to provide proper certifications or accurate information regarding billing, pricing or performance may be considered fraud or a false claim. Fraud and false claims generally include situations where a person misrepresents information provided to, or conceals information from, the Government. State and Federal False Claims Acts prohibit submitting any false invoice (or claim) to the Government, including misrepresenting, or concealing information from the Government in order to get an invoice paid. False Claims Act violations include, but are not limited to, such things as: submitting false or inaccurate invoices to the Government (i.e. mischarging or overbilling for products or services), accepting and keeping overpayments from the Government for products or services, making false or inaccurate statements in a certification, delivering substituted products or services without Government permission, and providing false information/data regarding compliance with contractual requirements or other quality, testing, or inspection requirements.

Compliance with Antitrust laws

BT Government is committed to fair competition and compliance with free-trade and antitrust laws. Antitrust laws are federal and state laws that protect the free enterprise system and prohibit agreements and practices that restrain or restrict trade. Examples of improper practices under these laws include, but are not limited to, price fixing, bid rigging, agreements among companies not to bid or to pursue certain opportunities, theft or conspiracy to gain use of confidential competitor information, making false statements about competitors, and boycotting suppliers or customers. Anytime we deal with a competitor, we are expected to know that federal and state free-trade or antitrust laws may apply to our activities, and we have a responsibility to educate ourselves regarding actions that can be taken.

Compliance with Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act (UKBA)

Pursuant to the Foreign Corrupt Practices Act of 1977 and the UK Bribery Act of 2010, it is unlawful to: Use corporate or subsidiary funds or assets, either directly or indirectly, or authorize their use, for:

• Any improper or unlawful purpose, such as paying or offering to pay anything of value to a foreign official, political party, third party intermediary or private party for the purpose of exerting influence in obtaining or retaining business when such payment is illegal in the U.S., UK or other foreign jurisdiction;
• Payment of bribes or kickbacks to obtain privileges, concessions, special benefits or other improper advantage; or the support of any political party or candidate except as permitted by local written law.

The following actions are also prohibited:

• Accepting payment or anything of value whether characterized as a bribe, kickback, or otherwise, and whether intended to be for BT Government or personal use, if payment and/or receipt of such is illegal or is designed to cause you to grant a privilege, benefit, concession, or other improper advantage to the payer.
• Establishing for any purpose, an undisclosed or unrecorded fund or asset of BT Government or any of its subsidiaries.
• Failure of an employee to report any suspected breach of the FCPA or UKBA.

Under the FCPA and UKBA, the company must maintain books, records, accounts, and controls so that:

• All transactions have management’s general or specific authorization.
• Transactions are recorded in conformity with Generally Accepted Accounting Principles (GAAP) and assets are accounted for (even petty cash).
• Access to assets is only in accordance with management’s authorization.
• Recorded assets are reviewed periodically for conformance to existing/actual assets.

A company can violate the Record Keeping provisions of FCPA and UKBA if a foreign subsidiary creates false records to conceal a corrupt payment and the company subsequently incorporates the subsidiary’s information into its books and records.

Violators of the FCPA face serious criminal penalties:

• Fines up to $2,000,000 for companies (officers, directors, or agent of the company may face imprisonment).
• Fines up to $100,000 per violation for individuals (cannot be reimbursed by the company), plus up to five years in prison.
• Under the Alternative Fines Act, penalties can result in fines up to twice the gain or loss from the offense.

Violators of the UKBA face serious criminal penalties:

• Fines for companies and individuals with a maximum fine of £5,000 per summary offense increasing to unlimited fines for an individual found guilty on indictment.
• Imprisonment of an individual up to 12 months per summary offense increasing to up to 10 years for an individual found guilty on indictment.
• Senior directors and officers of a company found guilty of a bribery offense may also be subject to fines and imprisonment.

Violators of the FCPA also face significant civil fines of $10,000 per violation for companies and individuals (officers, directors, employees, agent of the company, or stockholder acting on behalf of the company.

Violation of the FCPA or UKBA may result in disciplinary action up to and including termination.

Compliance with Antiboycott Laws

U.S. antiboycott laws prohibit U.S. companies and their subsidiaries from participating in or cooperating with any international boycott unless the boycott has been approved by the U.S. government. One important boycott that is not supported by the U.S. government is a boycott of Israel enforced by certain member countries of the Arab League.

Because BT Government is a U.S. based company, all BT Government operations worldwide must comply with U.S. law.