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APARIQ's Code of Business Ethics
Overview
At APARIQ, ethical conduct and legal compliance are the foundation for our
services and solutions. APARIQ’s ability to continue to improve its competitive
position requires that each employee, officer and director exhibit a high level
of personal integrity when interacting with APARIQ customers, business partners,
shareholders, and each other. Directors, officers and employees must allow
honesty, common sense and good judgment to govern their conduct.
As a condition of employment, each officer and employee is expected to comply
with this Code of Business Ethics and will be held accountable if he or she
fails to do so. Any violation of this Code, or any conduct that violates any
law, rule, regulation, or ethical or professional norm, is subject to
disciplinary action, up to and including termination of employment or business
agreements. Directors, officers and employees are also expected to cooperate
fully with any company audits or investigations and to answer all questions
fully and truthfully. It is a violation of company policy to intimidate or
impose any other form of retaliation on any employee who reports any actual or
suspected illegal or unethical conduct (however, an employee who knowingly makes
a false report may be subject to discipline).
This Code provides the standards of conduct that guide all directors,
officers, and employees of APARIQ. All of our directors, officers and employees
must conduct themselves appropriately and seek to avoid even the appearance of
improper behavior.
Our Ethics Statement serves as the benchmark by which each of our daily
business decisions should be measured and lies at the very core of the APARIQ
way of doing business:
"At APARIQ, ethical standards guide our business conduct. We act lawfully and
with integrity in our dealings with our customers, business partners,
shareholders, and with each other."
Compliance with Laws, Rules and Regulations
APARIQ directors, officers and employees are required to comply with all
applicable laws, rules and regulations.
The Recording and Reporting of APARIQ Information
At APARIQ, we are committed to ensuring that all business-related information
is recorded and reported accurately, honestly and in a timely manner. Directors,
officers and employees must ensure that information is reported truthfully and
correctly, and also exercise diligence in ensuring that reported information is
organized in a way that is understandable and does not mislead or misinform
those who receive the information. Our policy relating to accuracy of company
records extends to financial statements, loan documents and servicing records
prepared on behalf of our customers, and to information provided to government
employees or officials.
Nowhere is APARIQ’s commitment to ethical standards more evident than in how
we communicate our solutions to your needs.
Unfair Business Practices
APARIQ’s commitment to high ethical standards in its business practices with
customers, business partners and competitors is reflected in our dedication to
candid and forthright communications about our products and services. Unfair and
deceptive business practices (e.g., the misuse of proprietary information or the
misrepresentation of material facts) are strictly prohibited. APARIQ will engage
in responsible business practices and treat all customers fairly, without regard
to gender, race, color, religion, national origin, ancestry, pregnancy, age,
marital status, sexual orientation, or physical or mental disability.
Antitrust and Anti-Competitive Activities
APARIQ offers its products and services to customers in compliance with
antitrust laws, which prohibit APARIQ from entering into any agreement with its
competitors to restrict the system of free trade by fixing prices, allocating
territories or customers or refusing to provide service to particular customers.
APARIQ’s customers conduct business with the Company on the basis of its
industry reputation. Our customers choose APARIQ as their financial services
provider because of the quality of its services and products.
APARIQ and its directors, officers and employees must, at all times, conduct
business openly and avoid any situation that might even create the appearance
that APARIQ has made any agreement that improperly impacts industry prices or
the competition.
Sensitive and Proprietary Information
Because of the nature of our business, APARIQ possesses sensitive information
about our customers, business partners and the Company itself. All directors,
officers and employees have a duty to protect against the disclosure of such
information unless disclosure is authorized and within the law.
With respect to our customers, who entrust us with sensitive personal and
financial information, APARIQ is committed to safeguarding all such information,
including information gathered through applications and supporting documents,
account information obtained in the course of our ongoing relationships with
customers, and information exchanged through the Company's websites.
Similarly, APARIQ’s directors, officers and employees may be exposed to
proprietary or otherwise sensitive information about a business partner. APARIQ
directors, officers and employees accept responsibility for maintaining the
confidentiality of confidential business partner information, neither using it
for personal gain nor disclosing the information to others without proper
authorization.
Finally, APARIQ directors, officers and employees may be privy to sensitive
information about their fellow employees or APARIQ as a whole. Unauthorized
disclosure of such information is strictly prohibited.
Improper Influence
At APARIQ, all customers and business partners receive the same high level of
assistance and service. APARIQ directors, officers and employees are strictly
prohibited from giving, soliciting or accepting business courtesies or gifts
intended to influence business decisions. All business decisions are to be made
on the basis of the merit of the transaction and in compliance with any legal
and regulatory requirements.
APARIQ also routinely conducts business with a variety of government agencies
such as the U.S. Department of Defense, U.S. AID, the National Institutes of
Health, the U.S. Department of Veterans Affairs, and a host of state regulators,
local and state bond authorities and others. What may be acceptable practice in
the commercial business environment, such as providing nominal gifts and
hospitality, may be inappropriate when managing relationships with government
employees or those who act on the government's behalf. All directors, officers
and employees must adhere to the relevant laws and regulations governing
relationships with government customers, employees, and officials. APARIQ
directors, officers and employees are strictly prohibited from improperly
influencing the decisions of, or obtaining restricted information from,
government employees or contractors by offering or promising to give money,
gifts, loans, rewards, favors or anything else of value. Additionally, APARIQ
exercises proper protocol in bidding on all government contracts, which
prohibits the requesting of information from government officials or agents that
would provide the company with an unfair advantage.
Discrimination in Hiring
APARIQ has a long-standing philosophy and operating policy of seeking
qualified applicants for all positions in compliance with all federal, state and
local laws governing equal employment opportunity. All hiring decisions must be
made without regard to an individual's gender, race, color, religion, national
origin, ancestry, pregnancy, age, marital status, sexual orientation, medical
condition, veteran status, or physical or mental disability. APARIQ strives to
be an employer of choice for a highly diverse, best-in-class workforce.
Harassment
APARIQ is committed to providing a work environment that is free of unlawful
discrimination and harassment. We strive to create a work environment in which
everyone is treated with respect and dignity. It is our philosophy that every
employee has the right to work in an atmosphere that provides equal employment
opportunities and prohibits discriminatory practices and conduct, such as
illegal harassment, including sexual harassment. APARIQ takes illegal harassment
seriously and will endeavor to prevent, investigate and correct harassment in
the workplace or in any setting where company business or a company-sponsored
event is being conducted.
Safety
APARIQ strives to ensure the health and safety of each of its employees,
customers and visitors by maintaining a workplace that is free of unsafe and/or
hazardous conditions. APARIQ has established a Safety Program, which includes
procedures for correcting unsafe conditions and for responding in emergency
situations. As part of our commitment to creating a safe work and operating
environment, drug and alcohol abuse in the workplace is strictly prohibited.
Workplace Violence
APARIQ is committed to providing its employees with a safe and productive
workplace. APARIQ’s policy prohibits any acts or threats of violence by or
against APARIQ’s employees, customers, vendors, or other visitors. APARIQ does
not tolerate actual or threatened workplace violence against co-workers,
customers, vendors, visitors, or any other persons who are either on APARIQ’s
premises or have contact with employees in the course of their duties.
Conflict of Interest and Corporate Opportunities
Just as we are committed to providing our employees with a secure and
supportive work environment, we expect our directors, officers and employees to
act in the best interest of APARIQ and its customers, business partners and
shareholders at all times. Each director, officer and employee has a
responsibility to ensure that his or her personal interests do not conflict with
those of APARIQ. Using APARIQ property or information, competing with APARIQ or
leveraging APARIQ business opportunities to achieve personal gain or to benefit
a person or entity outside of APARIQ, is a direct violation of APARIQ’s conflict
of interest policy. In addition, should a director, officer or employee believe
that a contemplated material transaction or relationship could reasonably be
expected to give rise to a conflict of interest; he or she should notify one of
the persons listed in the "Reporting Unethical or Illegal Conduct/Ethics
Questions" section of this Code.
A director, officer or employee may not represent APARIQ in any transaction
with a person or an entity in which the director, officer or employee or his/her
spouse, children, and other members of the director, officer or employee's
household have a direct or indirect interest, or from which the director,
officer or employee may derive an improper personal benefit. To avoid possible
conflicts of interest, directors, officers and employees may not process or
approve a loan application that was submitted on behalf of their spouse,
relative, personal friend or member of their household. Any such loan
application must be approved by a loan officer or manager who is not supervised
by the director, officer or employee.
Protection and Proper Use of Company Assets
All employees have an obligation to protect APARIQ’s assets (e.g., computer
equipment and software, intellectual property, etc.) and ensure that those
assets are efficiently used. All of APARIQ’s assets must only be used for
legitimate business purposes.
Waivers of Code
Any waiver of this Code for executive officers or directors may be made only
by the Board of Directors and must be promptly disclosed to shareholders.
Reporting Unethical and Illegal Conduct/Ethics Questions
APARIQ employees are required to report illegal or unethical conduct to one
of the following:
(1) To confidentially or anonymously report any ethics concern, including
concerns about questionable accounting or auditing matters, employees should
contact the Ethics, Accounting and Auditing Helpline through one of the
following methods:
# By telephone, at 1-301-417-9559 (staffed 7 days per week, 24 hours per day)
# By U.S. mail, at APARIQ Ethics, Accounting and Auditing Helpline, c/o
President, APARIQ, Inc., 7300 Olive Tree Court, Gaithersburg, MD 20879
(2) To report suspected criminal activity.
(3) To report employment-related concerns (discrimination, harassment,
compensation matters, etc.), employees should contact their Employee Relations
representative by calling the HR Service Center at 1-301-417-9559.
APARIQ will take reasonable steps to maintain the confidentiality of any
employee who makes a non-anonymous report to the Ethics, Accounting and Auditing
Helpline, the Fraud Hotline or Employee Relations.
Similarly, APARIQ will take reasonable steps to maintain the confidentiality
of employees about or against whom such a report has been made, unless or until
it has been determined that an actual violation has occurred.
IT IS A VIOLATION OF COMPANY POLICY TO INTIMIDATE OR IMPOSE ANY OTHER FORM OF
RETALIATION ON AN EMPLOYEE WHO REPORTS ANY ACTUAL OR SUSPECTED ILLEGAL OR
UNETHICAL CONDUCT. HOWEVER, AN EMPLOYEE WHO KNOWINGLY MAKES A FALSE REPORT MAY
BE SUBJECT TO DISCIPLINE.
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