365INO
‘IT PROJECT MANAGEMENT CONSULTING’
365INO
[A] 7901 4th St. N. | Suite 4540 | St. Petersburg, FL 33702 | [P] 727-819-4456 | [F] 813-475-6665
Page | 1
Ethics and Business Conduct
365 Innovations Corporation (365INO)
formally adopted a vision and values
statement that acts as a moral
compass for the way we work within
the walls of 365INO and interact with
our co-workers, partners, customers
and communities. As an organization
and individually, 365INO’s employees
are responsible for acting with integrity, treating others with
dignity, respect, being honest and fair in all transactions and
striving to "do the right thing". And we shall not waiver from this!
1. INTRODUCTION
The code of conduct is our general statement of ethical
business conduct and point of reference for our employees.
To whom does the code apply?
Those with leadership roles have additional responsibilities!
Where should we turn for guidance?
What are the consequences for failing to act ethically?
2. CONFLICTS OF INTEREST (COMMONLY FACED BY EMPLOYEES)
Family members and close personal relationships
Business gifts, entertainment and outside activities
Seek guidance and assistance
3. CORPORATE OPPORTUNITIES (OUR RESPONSIBILITIES)
To Each Other
Respect
Diversity
Employee health and safety
To Consumers
Product quality and safety
Consumer information
Advertising and promotions
To Shareholders
Protecting 365INO’s assets
Accuracy of records, public reports and communications
Recording and retaining business communications
Investors, insider information and securities trading
To Business Partners
Doing business with others and fair dealings
Responsible manufacturing and distribution practices
Purchasing practices
Government customers
To Fair Competition
Gathering competitive information
Fair competition and antitrust
To Communities
Community service
Environment
Communication to the media
To Government and Compliance with the Laws
Which law applies?
Political activity and anti-corruption laws
Money laundering and international trade
4. COMPLAINTS ABOUT ACCOUNTING OR AUDITING
How to Get Help and Raise Concerns (General)
INTRODUCTION
365INO’s Core Values are as follows:
Fairness
Act with integrity and trust each other
Treat each other with respect and dignity
Be accountable for your actions and decisions
Togetherness
Work together as a team to realize full potential
Enrich the communities where we work and live
Create lasting partnerships and productive relationships
Passion
Work with unparalleled innovation and creativity
Commitment, confidence and ingenuity for change
Passion and enthusiasm to sustain high achievements
Growth
Pursue inventive thinking and take smart risks
Reward innovation in every part of our business
Be leaders, deliver superior quality and surpass goals
365INO
‘IT PROJECT MANAGEMENT CONSULTING’
365INO
[A] 7901 4th St. N. | Suite 4540 | St. Petersburg, FL 33702 | [P] 727-819-4456 | [F] 813-475-6665
Page | 2
The Values Statement. Includes a
commitment to act with unwavering
integrity on all occasions. This
includes an obligation to obey the
law of the communities in which
we do business. As a consulting
company conducting business in the
United States (US), 365INO’s
operations are subject to the laws of
the US. We must comply with all applicable laws, rules
and regulations wherever 365INO does business. While the
Code of Conduct outlines our broad responsibilities, we also
have more specific guidelines and company policies for various
activities. All company policies and the underlying procedures
established must be consistent with the standards of ethical
behavior outlined in the Code of Conduct. All employees are
required and expected to comply with the Code of Conduct
and policies that govern our activities.
To Whom Does The Code Apply?
Unless stated otherwise, the Code of Conduct applies to all
365INO employees (including temporary, part-time, and
seasonal employees). Those employees with leadership roles
will have additional responsibilities. Leaders should foster an
environment of ethical behavior by: a.) Acting as role models
b.) Demonstrating ethical behavior in the performance of their
own duties c.) Making sure that employees understand that
business results are never more important than compliance
with the standards for ethical behavior d.) Ensuring that
employees are familiar with the standards for ethical behavior
as outlined in the Code of Conduct and the company policies
that are relevant to the performance of their duties
e.) Encouraging open communication regarding business
practices and ethical issues f.) Acting to address incidents of
unethical behavior (incl. training, counseling and disciplinary
actions) g.) Recognizing and rewarding ethical behavior.
Where Should We Turn For Guidance or To Raise Concerns?
When questions arise regarding the Code of Conduct, company
policy or conduct that may violate these standards, we should
first consult our supervisors or the Human Resources Department
(HR). As an alternative, 365INO has additional policies and
procedures in place to raise concerns or report violations of the
Code of Conduct or Company Policies. Employees can remain
anonymous, but are encouraged to identify themselves and to
provide as much information as possible in order to facilitate an
efficient and effective investigation. All questions and concerns
will be handled fairly and discreetly.
What Are The Consequences For Failing To Act Ethically?
Failures to act ethically and violations of the Code of Conduct
and company policies can impact 365INO’s business and
reputation, and can have serious consequences for all 365INO
stakeholders, including employees, consumers, investors,
business partners and our communities. Whenever 365INO
becomes aware of a violation of the Code of Conduct, company
policy or the law, we will act to correct the problem and prevent
future occurrences. Depending on the circumstances, the
corrective and preventive steps might include training,
counseling and disciplinary actions up to and including
termination of employment and civil or criminal prosecution.
If anyone believes they are in a situation which they believe may
violate or lead to a violation of the Code of Conduct, company
policy or law, we encourage them to follow the guidelines
detailed in our Ethics Training.
CONFLICTS OF INTEREST
Employees and Executives must act in the best interests of
365INO, without consideration for our personal interests or the
potential for personal benefit. A conflict of interest arises any
time our personal interests (including relationships, investments
or activities) might affect our judgment as to what is in the best
interest of 365INO, or make it difficult to perform our work for
365INO objectively and effectively. It is very important to
consider the appearance of conflicts of interest, since perceived
conflicts can be as damaging to our reputation as actual conflicts.
We’ll be diligent in recognizing actual and potential conflicts.
Situations Commonly Faced By Employees
It is not possible to anticipate all situations which could present a
conflict of interest, and only some of the more common are listed
here. 365INO may also at any time require reporting by
employees of activities that could present conflicts of interest.
365INO
‘IT PROJECT MANAGEMENT CONSULTING’
365INO [A] 7901 4th St. N. | Suite 4540 | St. Petersburg, FL 33702 | [P] 727-819-4456 | [F] 813-475-6665
Page | 3
Family Members and Close Personal Relationships
Jobs and work assignments will be awarded on the basis of
skills, qualifications, and achievement, and not family or
personal relationships. Work assignments involving employees
who are related, or who have close personal relationships,
could lead to actual or perceived favoritism, lack of objectivity
and poor employee morale among co-workers. Employees will
not be eligible for positions that present a conflict of interest,
such as a direct reporting relationship. H.R. should be advised
when a family or personal relationship between employees
could present an actual or perceived conflict.
Business Gifts and Entertainment
In some circumstances business gifts and entertainment can
be used to strengthen business relationships. In no event
should a gift, favor or entertainment be accepted or provided
if it will obligate or appear to obligate the recipient as such
gifts, favors or entertainment can constitute commercial bribery
and are illegal. Requesting or soliciting personal gifts, favors,
entertainment or services is unacceptable. We should not
exploit our position at 365INO to solicit vendors to provide
individual preferential treatment in pricing, terms or loans.
Gifts
When considering whether to accept or offer a gift or other
business courtesy, we should use prudent judgment and
moderation. We should not accept inappropriate gifts from any
person or organization with whom 365INO does business or is
in competition, and in no event should we accept gifts that
exceed $100.00 in value. We may accept gifts that do not
exceed (or that the recipient reasonably believes do not exceed)
$100 in value from a single source during any year and do not
involve commercial bribery as discussed above. Gifts in excess
of this value should be returned to sender with a letter of
explanation. However, if it would be impractical or discourteous
to refuse a gift, it should be donated to charity through
365INO’s Philanthropy Programs. Accepting a gift of cash or
cash equivalents (such as checks, savings bonds, stock or other
corporate securities) of any value is strictly prohibited. Certain
gift certificates and gift cards that allow the recipient to choose
from a wide range of goods and services may be considered
cash equivalents. For this reason, employees should consult HR
before accepting a gift certificate or gift
card. We should not offer a gift unless it is a gift that is given
as a common courtesy or gesture, is customary business practice
and is proper and reasonable in the circumstances. A gift should
not be offered if the gift would violate known customer business
practice or could be deemed a kickback or commercial bribery.
Special restrictions apply to government officials in most
countries, and we should always consult the Legal Department
before offering any gifts to any government officials (see the
discussion on Anti-Corruption Laws).
Entertainment
We may accept or provide business entertainment and meals
that are reasonable in the context of the business and advance
the Company's interests, for example attending a local cultural
event, a sporting event or a business meal with a business
associate (customer or supplier). However, accepting tickets
to an event (business associate not also present) should not
be considered business entertainment, but should instead be
considered a gift, subject to the limitations described above.
Outside Activities
All 365INO activities deemed “outside” activities shall be subject
to compliance under our Ethics and Business Conduct policies.
Secondary Employment
365INO expects the complete commitment of its employees,
and therefore, discourages outside employment. We must
obtain the approval of the HR Department
before accepting a second job, commencing a business venture
or personal project, or agreeing to act as an advisor, consultant,
officer or Executive under circumstances that may conflict
with our ability to fulfill our job duties or may raise a potential
conflict of interest. We must be sure the skills we learn and
use at 365INO are not used in a way that could hurt 365INO’s
business. Providing services in any capacity to an organization
that competes with 365INO in any manner presents an actual
conflict of interest, and is prohibited. Providing services in any
capacity to suppliers or customers of 365INO will be closely
scrutinized because of the ‘high’ potential for conflicts!
365INO
‘IT PROJECT MANAGEMENT CONSULTING’
365INO
[A] 7901 4th St. N. | Suite 4540 | St. Petersburg, FL 33702 | [P] 727-819-4456 | [F] 813-475-6665
Page | 4
Investments
Our personal investments should not influence, or appear to
influence, our business decisions. Ex.) If we are in a position to
make decisions on behalf of 365INO that could have a significant
impact on the business of a supplier or customer, we should
avoid any investment in the supplier or customer of such value
that it might affect, or appear to affect, our business decisions
regarding the supplier or customer. We should also avoid any
investment in a competitor which might affect, or appear to
affect, our business decisions.
Serving Non-Profit or Community Organizations
365INO supports non-profit or community organizations
through Philanthropy Programs with financial contributions,
gift donations, organized volunteer activities, volunteer
engagements, or the use of 365INO’s resources. 365INO
encourages employees to participate in Philanthropy Programs,
and to support charitable organizations and our communities
generally, by taking an active role in volunteer activities.
However, we should not allow our volunteer activities to
interfere with the conduct of 365INO’s business.
Use of 365INO’s Authority for Non-365INO Purposes
When engaged in activities that are not related to 365INO
business or volunteer activities in support of 365INO’s
Philanthropy Programs, we should not use our position in
365INO in a manner that would lead outsiders to believe that
we are acting on 365INO’s behalf, or that 365INO is actively
involved in or sponsors these activities.
Seek Guidance and Assistance
We should discuss any questions about Conflicts of Interest
with our supervisors and HR representative,
and consult the Legal Department. Specific guidelines on
these situations, as well as reporting requirements, are
provided in the Conflict-of-Interest Policy.
CORPORATE OPPORTUNITIES (OUR RESPONSIBILITIES)
Employees and Executives should not compete with 365INO, or
pursue for personal benefit opportunities (for example, relating
to products, inventions or investments) that are discovered
through the use of corporate property, information or position.
We should not use corporate property, information or position for
personal gain. Employees and Executives should seek to advance
the legitimate interests of 365INO when the opportunity arises.
Our Responsibility To Each Other
Respect
We will treat others as we want to
be treated! With RESPECT, DIGNITY,
and FAIRNESS. We have the right to
work in environments free from
discrimination and harassment
based on race, color, religion, sex
(including pregnancy, childbirth or
other related medical conditions),
sexual orientation, gender identity,
national origin, ancestry, social origin, age, disability, marital
status, veteran status or other protected characteristics. We
should respect our co-worker’s rights, and remember that such
discrimination and harassment will not be tolerated. We should
speak out and report to HR when the conduct of a coworker
makes us or others uncomfortable (incl. harassment or
discrimination).
Diversity
365INO recognizes diversity as an asset, and is committed to
actively seeking and promoting diversity in the workforce. We
value the different perspectives, insights and experiences of
diverse individuals and cultures, and we aspire to create a
company culture that encourages an expression of, and a
respect for, diverse viewpoints. We provide equal employment
opportunity for all applicants and employees, without regard
to factors such as race, color, religion, sex (incl. pregnancy,
childbirth or related medical conditions), sexual orientation,
gender identity, national origin, ancestry, social origin, age,
disability, marital status, veteran status or other protected
characteristics. We make employment decisions to meet
our business needs (qualifications, skills and achievements).
365INO
‘IT PROJECT MANAGEMENT CONSULTING’
365INO [A] 7901 4th St. N. | Suite 4540 | St. Petersburg, FL 33702 | [P] 727-819-4456 | [F] 813-475-6665
Page | 5
Employee Health and Safety
365INO is committed to providing a safe, healthful and
environmentally responsible workplace, and has established
safety programs to provide information and training for safe
practices in the normal conduct of business and for emergencies.
We are responsible for observing safety and health rules, for
taking appropriate precautionary measures and for reporting
unsafe or hazardous conditions to our supervisors or 365INO’s
Security personnel. In order to maintain our high standards for
quality, productivity and safety, we should be in suitable mental
and physical condition at work. Possessing, buying or selling,
using or being under the influence of illegal drugs or engaging
in any other activities which create an unsafe work environment
while on duty, or when on 365INO’s premises or contractor
work environments, are expressly prohibited. The consumption
of alcohol while on duty, working on 365INO’s contracts or
when on 365INO’s premises is prohibited except during
approved 365INO social functions, or during business meals.
Our Responsibility To Consumers
Product Quality and Safety
365INO is continually building a reputation for quality and is
amongst its most valuable assets. Our commitment to quality is
an integral part of our processes, and is essential to the success
of our business. We will meet or exceed legal requirements and
industry standards for quality. We strive every day to earn our
consumers’ trust through our dedication in these areas.
Employees have an obligation to immediately report any
concerns about quality to 365INO’s Executive Leadership.
Client Information
We respect the confidentiality of client information consistent
with applicable privacy and data protection laws and regulations.
We don’t share, sell or trade private or sensitive personal
information obtained online without prior consent or unless
compelled by the legal process.
Advertising and Promotions
365INO’s brand and product promotion activities should be
conducted in a manner consistent with applicable laws and
with our reputation for honesty and integrity. We adhere to
high standards of commercial fairness in ads and promotions.
We must accurately portray the features, quality and performance
of our products in all advertising media. We do not misstate
facts or provide misleading or deceptive information about
365INO’s products and services, or the products and services
of our competitors. We should be diligent in safeguarding the
reputation of 365INO by being selective about promotional
opportunities, such as event sponsorship and other joint
promotions, avoiding association of 365INO’s name with any
product, service or activity which might be considered unsafe.
Our Responsibility To Shareholders
Protecting 365INO’s Assets
All employees and Executives share in the responsibility to
protect 365INO’s assets, including physical assets, financial
assets, intellectual property and proprietary information from
theft, loss, damage, misuse or waste. Those of us who have
custody of company property, such as vehicles and laptop
computers, should take appropriate measures to ensure their
proper security and use at all times, when items are in their
possession. Company assets should not be used for illegal
purposes, or for personal benefit. (Except as may be allowed in
company-approved compensation arrangements). Incidental
personal use of company assets, such as telephones, personal
computers and photocopying machines, is permitted as long
as such use does not interfere with the employee's duties, is not
done for monetary gain, does not conflict with 365INO’s business
and does not violate any 365INO policy or applicable law. The
security of computer systems and electronic data should be
protected by allowing access only by authorized persons.
Commitments and Expenditures
365INO has established policies that grant authority and
establish review and approval requirements for commitments
and expenditures. These guidelines apply to all financial
expenditures (including capital expenditures), and to all
agreements that commit 365INO’s resources and define its
business activities. Licensing agreements, joint ventures or
other strategic agreements, and contracts for the engagement
of services, investments, acquisitions, or the lease or sale of
corporate assets are examples of commitments subject to these
guidelines. Only officers of 365INO (generally those having a
title at or above the VP level) are authorized to enter into
365INO
‘IT PROJECT MANAGEMENT CONSULTING’
365INO
[A] 7901 4th St. N. | Suite 4540 | St. Petersburg, FL 33702 | [P] 727-819-4456 | [F] 813-475-6665
Page | 6
agreements on behalf of 365INO, and this authority is to be
exercised only in compliance with the guidelines. We are
each responsible knowing these guidelines, understanding
the scope of our authority, and ensuring that we don’t make
commitments (including oral) that exceed our authority.
Intellectual Property and Confidential Information
365INO’s intellectual property, including trademarks, trade
names, copyrights, patents, software (code), internet domain
names and similar rights or interests are among its most
important assets. Improper use of intellectual property in
advertising, packaging, correspondence and contracts can
erode 365INO’s rights. Questions regarding the proper use of
365INO’s intellectual property should be referred to the legal
department. Confidential information is any information not
generally known to the public that is useful to 365INO, that
would be useful to its competitors or other third parties or
that would be harmful to 365INO or its customers if disclosed.
Confidential Information. Includes
revenue and profit information and
projections, information regarding
potential acquisitions, divestitures
and investments, new product
information, marketing plans,
design and development efforts,
manufacturing processes, and other
trade secrets. Employees and
Executives should not discuss confidential information with those
who are not obligated to maintain the information in confidence
or in public places where the information is not likely to be kept
secret, such as planes, restaurants and elevators. In view of the
competitive nature of 365INO’s business and the significant
impact of the theft or unauthorized use of 365INO’s intellectual
property on 365INO’s business and consumers, the protection of
365INO’s intellectual property is one of the most important
responsibilities of employment with 365INO. This obligation
continues even after employment ends. 365INO recognizes and
respects rights in intellectual property and confidential
information owned by third parties. 365INO’s employees should
protect the confidential information of 3
rd
parties from theft,
misuse or unauthorized disclosure with the same degree of care
used to protect confidential information.
Company Records, Public Reports and Communications
365INO is committed to provide full, fair, complete, accurate,
timely and understandable disclosure of information, including
financial information. Financial books, records and accounts
must be maintained in reasonable detail, accurately reflect
transactions and events and conform to applicable legal and
accounting requirements and to 365INO’s system of internal
controls. In order to fulfill our responsibility for sound
decision-making, we require honest and accurate recording
and reporting of business information, including quality, safety
and personnel data records, as well as financial transactions and
records. Falsification of any record or financial report, such as
quality and project information, time reports or expense reports,
will result in immediate disciplinary action.
Recording and Retaining Business Communications
Communications (even those we may consider "private" or
"personal") may become public, so all correspondence should
be clear and accurate. We should avoid exaggeration,
inappropriately colorful language and derogatory
characterizations. These guidelines apply to communications
of all kinds (email, text messaging and video).
Our Responsibility To Business Partners
Doing Business With Others
We are committed to expanding and improving 365INO’s
business through business alliances, including customers,
suppliers, vendors, subcontractors, licensees, agents, joint
ventures, etc. We will build productive relationships with
business partners based on integrity, legal and ethical behavior
and mutual trust. We seek to do business with customers and
suppliers who reflect the diversity of the community in which
we operate. Integrity, ethical behavior and mutual trust are
important in our evaluation and election process. We seek to
do business with parties who have a history of ethical behavior.
365INO
‘IT PROJECT MANAGEMENT CONSULTING’
365INO [A] 7901 4th St. N. | Suite 4540 | St. Petersburg, FL 33702 | [P] 727-819-4456 | [F] 813-475-6665
Page | 7
Fair Dealing
Employees and Executives should deal fairly with our customers,
suppliers, competitors and employees. We will never take
advantage of anyone through manipulation, concealment, abuse
of privileged information or unfair business practices.
Purchasing Practices
All suppliers should be treated in a fair, ethical and impartial
manner. All decisions regarding suppliers and vendors of goods
and services should be made on the basis of factors such as
suitability, quality, price, and delivery. Individuals involved in the
review and selection of potential suppliers, vendors and services
providers must be diligent in avoiding actions that convey or
imply that decisions will be influenced by favors, concessions
or relationships (personal or family).
Government Agencies and Customers
There are special rules, restrictions and procedures for dealing
with government customers (including government-owned
enterprises). Requirements may include enhanced disclosure
requirements in contract negotiations, special billing or shipping
procedures or stringent restrictions on gifts, travel and
entertainment which can be offered to government employees.
All statements and representations to government procurement
officials must be accurate and truthful. 365INO will comply with
all government rules and regulations. In special instances, these
may often supersede our own internal rules and regulations.
Our Responsibility To Fair Competition
Gathering Competitive Information
365INO does not seek to obtain competitive information by
illegal or unethical means, and we do not knowingly use any
information obtained in this manner. If we find ourselves in
possession of information that may have been obtained in an
illegal or unethical manner, such as information provided to us in
breach of a confidentiality agreement, we should immediately
inform the Legal Department and should turn the information
over only to a member of the Legal Department staff, without
showing it to or sharing it with other 365INO employees.
Fair Competition and Anti-Trust
365INO competes aggressively
and fairly! In each market in which
it operates and is dedicated to
compliance with the applicable
antitrust and competition laws in all
its worldwide activities and locations.
Antitrust laws are designed to
prohibit agreements among
companies that would fix prices, divide markets, allocate
customers, limit production or otherwise impede or destroy
market forces. We must strictly comply with the antitrust laws of
all countries, states and localities in which we conduct 365INO
business. In addition, we should generally avoid exchanging or
discussing with any customer information about another
competitors pricing policies, product offerings, marketing
strategies or any other similar competitive information. We
should always consult the Legal Department before we agree to
perform any category management services for a customer that
may expose us to confidential information about competitors’
pricing, product offerings, marketing strategies or any other
similar competitive information. Membership in trade
associations, while helpful to our business, may also
inadvertently create opportunities for discussions that may be
contrary to the antitrust laws. If a prohibited subject comes up
during the course of a trade association, we should leave the
meeting and inform the Legal Department.
Our Responsibility To Communities
Community Service
365INO is committed to improving the communities in which it
operates through Philanthropy programs supported by 365INO
and accomplished by voluntary efforts of 365INO’s employees.
As a company, 365INO works to improve the lives of citizens in
need through a variety of efforts, including corporate financial
and product contributions, organized employee volunteer
activities and through programs administered by 365INO.
Environment and Sustainability
365INO is committed to protecting the health and safety of its
employees and minimizing our environmental impact.
365INO
‘IT PROJECT MANAGEMENT CONSULTING’
365INO [A] 7901 4th St. N. | Suite 4540 | St. Petersburg, FL 33702 | [P] 727-819-4456 | [F] 813-475-6665
Page | 8
Communications To The Media
In order to ensure that the information provided to the public is
accurate and consistent, all communications to the media should
be coordinated with the Executive Team. We should not engage
in conversations with the media without prior authorization from
the Executive Team, and if contacted by a member of the media
should refer inquiries to them.
Our Responsibility To Government and Compliance With Laws
Employees and Executives
Must comply with all applicable laws, rules and regulations
wherever we do business. When we have any questions or
concerns about the legality of an action, we should seek
guidance from the Legal Department. Each of us has a
responsibility to understand the legal and policy
requirements that may apply to our jobs or role.
Which Law Applies?
365INO is a corporation organized in Florida, United States.
The laws of the US frequently extend to the operations of
365INO, as well as to the business activities of 365INO’s
employees wherever we live and work. The Code of Conduct
has been written to promote compliance with the laws and
regulations that govern 365INO’s business. However, if
compliance with the Code of Conduct would bring us into
conflict with applicable laws or regulations in any jurisdiction
where 365INO’s conducts its business, we must obey the laws
and regulations and notify the Legal Department of any such
conflict as soon as possible. If any local business custom or
practice conflicts with the Code of Conduct, we must comply
with the Code of Conduct and notify supervisors of any conflicts.
Political Activity
365INO’s funds and resources, including personnel, facilities and
inventory, should not be used directly or indirectly to make a
political contribution to any elected official, political candidate or
party or for campaigning, fundraising or any other political
activity, without required approval according to 365INO’s policy.
Political activities by corporations, including lobbying, are subject
to detailed restrictions under U.S. law. In order to avoid any
inadvertent violation of the laws which control these activities, all
political and lobbying activities should be discussed and
coordinated in advance with the Executive Team. Voluntary
personal contributions to candidates, parties and civic
organizations are encouraged and are consistent with 365INO’s
commitment to citizenship and community involvement. Our
individual involvement must be totally voluntary and must be on
our own time and at our own expense.
Anti-Corruption Laws
We must follow the laws of the U.S. and other countries on
bribery and improper payments to government officials.
Bribery of or the offer or payment of money to public officials
is absolutely prohibited. We should not offer directly or indirectly
anything of value to government authorities, including political
parties or candidates, to obtain an improper advantage, or to
retain or obtain business. No gifts, contributions, meals or
entertainment are to be offered which might create an
appearance of impropriety. U.S. law also requires accurate books
and recordkeeping so that all payments are properly recorded.
We should also follow the laws of the U.S. and other countries
that prohibit commercial bribery. We should not give to our
business partners any advantage including kickbacks or other
improper payments, gifts or favors as an inducement to do or
forbear from doing something. Because 365INO’s business
partners (vendors, suppliers, licensors, licensees, joint venture
partners, etc.) may also be required to comply with these laws,
we should exercise proper due diligence in selecting our
business partners and should avoid relationships with parties
with a history of corrupt practices. Because of the complexity of
the laws, and the severity of the consequences for violations of
the anti-corruption laws, the Legal Department should be
consulted in advance for advice on dealings with government
officials including any proposed meals, travel or entertainment.
We should immediately report to the Legal Department any
suspected requirement violations.
Money Laundering
Money laundering occurs when individuals or companies try to
conceal illicit funds or make the source of such funds look
legitimate. 365INO does not permit its employees or resources to
be used in money laundering activities. 365INO complies with all
U.S. and international laws against money laundering, which
prohibit the acceptance or processing of proceeds of criminal
activities (e.g., drug trafficking, arms trading, bribery, or fraud).
365INO
‘IT PROJECT MANAGEMENT CONSULTING’
365INO [A] 7901 4th St. N. | Suite 4540 | St. Petersburg, FL 33702 | [P] 727-819-4456 | [F] 813-475-6665
Page | 9
International Trade
The U.S. and other nations strictly
regulate the import and export of
products, materials, services,
information and technology. We
should also comply with the customs
and import laws and regulations in all
countries in which we do business. We
should not transact business directly
or indirectly with countries, persons and entities which have been
identified as prohibited trading parties (ex. sanctioned countries,
businesses in sanctioned countries, terrorists, etc.) We must
comply with all applicable laws, regulations and restrictions on
trade, and we should contact the Legal Department with any
questions. 365INO will not cooperate with any restrictive trade
practices or boycotts prohibited or penalized under U.S. or
applicable local laws, such as boycotts against countries friendly
to the U.S., or blacklisted firms.
HOW TO GET HELP AND RAISE CONCERNS (GENERAL)
When faced with an ethical decision, you should ask yourself this:
1. What is the ethics issue?
2. What is it about the situation makes you feel uncomfortable?
3. Is it a violation of 365INO’s Code of Conduct, Policy or Law?
4. YES, don’t do it! NOT SURE, talk to your supervisor or HR!
5. How will it affect 365INO’s stakeholders?
6. What is the Impact on ‘all’ 365INO stakeholders?
7. How will this affect 365INO’s or my reputation?
8. Are your actions consistent with 365INO’s values?
9. Are you playing fair?
10. Comfortable explaining to your family or the news media?
11. How does your conscience feel?
12. What would a trusted friend advise?
If you have questions about the Code of Conduct, you should
report them. 365INO offers many resources to assist you in
obtaining answers to your questions. The first place to turn is to
your immediate supervisor. Other resources include the HR
Department and/or Legal Department representative.
Taking Action To Correct Problems
Taking action to correct problems is part of the 365INO’s culture.
If you observe conduct that you believe may be unethical, illegal
or in violation of the Code of Conduct or other company policies,
you are encouraged to report your concerns to your supervisor,
the HR or Legal Department. All reported concerns will be
handled promptly, fairly and discreetly. Employees must
cooperate ‘fully’ with any 365INO investigation and must answer
truthfully any questions asked related to the investigation.
Retaliation Is Not Tolerated
Retaliation toward any employee who in good faith reports an
integrity or ethical concern or issue will not be tolerated. Any
employee who believes that he or she is being subjected to
retaliation for reporting an issue in good faith or assisting in
good faith with a 365INO investigation should report the matter
immediately to the HR Department or the Legal Department.
Additional Guidance
Because these guidelines are very general, it is possible that
under unusual circumstances, the Code of Conduct may not
appear to provide complete guidance. You should always seek
the advice and agreement of the Executive Team before taking
any action that would conflict with the Code of Conduct. Any
waiver of any provision of the Code relating to any Executive
Officer must be approved, and will be promptly disclosed.
RAISING CONCERNS OR COMPLAINTS ABOUT ACCOUNTING
Any employee may submit a good
faith concern or complaint regarding
accounting, internal accounting
controls or auditing matters to
365INO, without fear of retaliation
of any kind. These are general
complaint procedures. Actual
complaint procedures may vary.
1. Contact an officer: Employees with complaints regarding
accounting, internal accounting controls or auditing matters
may report them to the Legal Department (Audit, in writing,
by phone, via email or video conferencing tools).
2. Employee complaints: Submitted in writing or by telephone
may be made on a confidential and anonymous basis. Due
to technical constraints, email submissions may not be
made anonymously.
PLEASE CONSIDER US!
Do you know of a business that could use our services? Please consider referring us. We will not abuse your trust or let you down!
Thank you.
BUSINESS HOURS
Monday — Friday (8a - 5p)
Saturday, Sunday (Closed)
CONTACT INFORMATION
365INO, CO.
7901 4th St. N.
Suite 4540
St. Petersburg, FL 33702
[ T ] 727-819-4456
[ F ] 813-475-6665
[ E ] info@365ino.com
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