The following are our general policies with regards to business conduct and ethics, and apply to all activities involving Enterprise Governance Systems Corporation, including employment, sales of products and services, contracting activities and related business discussions and transactions.
 
Many of these policies are included in our general Terms and Conditions of Sale, Terms of Use, and Electronic Communications Policy, and may also be referred to in documents and/or electronic messages which may incorporate these policies by their reference.
 
ENTERPRISE GOVERNANCE SYSTEMS CORPORATION
IS COMMITTED TO TRANSPARENCY.
Enterprise Governance Systems Corporation expects each of its employees, contractors' employees, agents' employees and contractors and affiliates' employees and contractors to conduct itself with the highest standards of ethics, professional conduct, honesty, transparency and adherence to laws and regulations, including anti-bribery and anti-corruption laws and the Foreign Corrupt Practices Act of 1977, as amended, 15 U.S.C. §§ 78dd-1, et seq., and including Enterprise Governance Systems Corporation internal operational controls and policies.
 
ENTERPRISE GOVERNANCE SYSTEMS CORPORATION
IS AN EQUAL OPPORTUNITY EMPLOYER.
Enterprise Governance Systems Corporation (the "Corporation," "we," "us", "our") is an Equal Opportunity Employer and is committed to providing equal employment, recruitment and advancement opportunities to all individuals, and making employment, recruitment and advancement decisions without regard to an individual's race, color, religion, sex, national origin, age, ancestry, disability, veteran status, gender identity, gender expression, sexual orientation, marital status, parental status, pregnancy, genetic information, ethnic identity, racial identity, community identity or any other characteristic protected by law.
 
ENTERPRISE GOVERNANCE SYSTEMS CORPORATION
IS AN AFFIRMATIVE ACTION EMPLOYER.
Enterprise Governance Systems Corporation and our affiliates expect all business partners, subcontractors, suppliers and vendors to comply with all applicable obligations under Executive Order 11246 (non-segregated facilities), Executive Order 11375 (equal opportunity), Section 503 of the Rehabilitation Act of 1973, the Vietnam Era Veterans' Readjustment Assistance Act of 1974, as amended, 38 U.S.C. 4212, (VEVRAA), and any other law requiring affirmative action or equal opportunity clauses set forth in 41 CFR 60-1.4(a), 41 CFR 60-250.5(a) and 41 CFR 60-741.5(a).
 
ENTERPRISE GOVERNANCE SYSTEMS CORPORATION
EXPECTS COMPLIANCE WITH NON-DISCRIMINATION LAWS.
Enterprise Governance Systems Corporation complies with, and expects all business partners, subcontractors, suppliers and vendors to comply with, all applicable laws regarding non-discrimination in terms and conditions of employment, payment of minimum wage and legally mandated employee benefits and compliance with mandated work hours.
 
ENTERPRISE GOVERNANCE SYSTEMS CORPORATION
EXPECTS COMPLIANCE WITH CHILD LABOR LAWS.
Enterprise Governance Systems Corporation complies with, and expects all business partners, subcontractors, suppliers and vendor to comply with, all applicable laws regarding employment of underage or child labor and shall not employ children under the age of 16.
 
ENTERPRISE GOVERNANCE SYSTEMS CORPORATION
STRIVES FOR TRANSPARENCY IN POTENTIAL CONFLICTS OF INTEREST.
Enterprise Governance Systems Corporation believes that our officers, staff and other members acting on our behalf have the obligation to avoid ethical, legal, financial or other conflicts of interest and to ensure that their activities and interests do not conflict with their obligation to our company or to its welfare. We expect that our officers, staff and other members acting on our behalf will make open, proactive and timely reports of potential appearances of ethical, legal, financial or other conflicts of interest in order to help the Corporation avoid any potential conflict and to help the Corporation make appropriate disclosures or filings regarding the same.
 
ENTERPRISE GOVERNANCE SYSTEMS CORPORATION
REPORTS FRAUD, WASTE, ABUSE AND MISMANAGEMENT.
As a contractor eligible for contracting and subcontracting activities, it is the responsibility of Enterprise Governance Systems Corporation to report and we expect our employees to report criminal activity, fraud, waste, abuse, mismanagement and/or unnecessary government expenditures. In addition to our requirements under United States laws and regulations, Enterprise Governance Systems Corporation has a separate internal policy that prohibits retaliation against employees for reporting what they believe to be potential criminal activity, ethics, fraud, waste, abuse or mismanagement violations.
 
ENTERPRISE GOVERNANCE SYSTEMS CORPORATION
EMPLOYEES MUST REFUSE AND REPORT ILLEGALLY-OBTAINED FUNDS.
No employee of Enterprise Governance Systems Corporation shall disguise or attempt to disguise the sources of funds. No employee shall disguise or attempt to disguise the sources of funds obtained illegally, and any employee who believes that funds may have been obtained illegally must make a report immediately.
 
ENTERPRISE GOVERNANCE SYSTEMS CORPORATION
EMPLOYEES MUST NOT USE PERSONAL FUNDS FOR CORPORATE PURPOSES.
Personal funds should not be used for company matters as a general rule of practice, unless specifically authorized to do so, and in no event shall personal funds be used to circumvent, subvert or otherwise accomplish that which is prohibited by this policy, applicable laws, regulations, or statutes, any contractual agreements binding upon the company, or requirements made upon the company by a duly authorized government agency or department.
 
ENTERPRISE GOVERNANCE SYSTEMS CORPORATION
FINANCIAL TRANSACTIONS ARE SUBJECT TO VERIFICATION.
Employees, contractors, subcontractors and any party to a financial transaction with the Corporation may be subject to additional anti-money laundering (AML), know your customer (KYC) or other compliance mandates or programs to help verify the true identity of parties involved; to help detect and deter fraud, waste and abuse, assess and monitor risk; to comply with requirements set by merchant services, payment processing, financial service and financial institutions providers with whom we contract; and to comply with relevant United States Government regulations to help the Government fight the funding of terrorism and money laundering activities.
 
ENTERPRISE GOVERNANCE SYSTEMS CORPORATION
REVIEWS THE SUITABILITY OF POTENTIAL AND ACTIVE EMPLOYEES.
Enterprise Governance Systems Corporation conducts pre-employment and pre-contracting review and vetting of potential employees, subcontractors and suppliers, in addition to subsequent regular reviews, to ensure compliance with applicable laws, regulations and statutes. These include, where permissible under law, verification of individuals' information provided to us to assess individuals' eligibility to work and individuals' suitability. These may include, where permissible under law, verification of educational credentials, verification of identity, review of financial information, and, in the case of individuals who may require access to export-controlled information, verification of the individual's citizenships or other qualifying data as required by United States law and/or United States Government agencies and departments. Depending on circumstances, we may also require individuals to complete specific background investigations as may be required for particular positions or roles.
 
ENTERPRISE GOVERNANCE SYSTEMS CORPORATION
IS A DRUG FREE WORKPLACE.
Enterprise Governance Systems Corporation is a Drug-Free Workplace. Post-offer applicants and employees are subject to alcohol and drug screening when criteria is met as outlined in our policies.
 
ENTERPRISE GOVERNANCE SYSTEMS CORPORATION
EXPECTS ADHERENCE TO EXPORT COMPLIANCE REGULATIONS.
Enterprise Governance Systems Corporation agrees, and expects all business partners, subcontractors, suppliers and vendors to agree, to not provide foreign nationals (non-US citizens or others as defined by applicable Federal law including 22 CFR § 120.15) as employees or contingent workers for work on any customer site unless that foreign national is covered under a valid US Export License, is not exposed to controlled technology, or does not require a valid US Export License.
 
ENTERPRISE GOVERNANCE SYSTEMS CORPORATION
EXPECTS EMPLOYEES TO ADHERE TO SUPPLIER REGULATIONS.
Enterprise Governance Systems Corporation maintains relationships with multiple suppliers. Many of these suppliers maintain separate and unique codes of business conduct, business ethics, professional conduct and other regulations to which they mandate our adherence and with which they place expectation and trust in the Corporation to maintain compliance. In addition to Corporation-provided policy training, assessment and review, employees will be required to attend training, undergo assessment of understanding, and be reviewed for compliance with the regulations and requirements our suppliers place upon us.
 
ENTERPRISE GOVERNANCE SYSTEMS CORPORATION
SHALL NOT EXPEND FOR OR ON BEHALF OF GOVERNMENT OFFICIALS.
Enterprise Governance Systems Corporation maintains an internal policy that prohibits the expenditure for travel, lodging, gifts, hospitality, or charitable contributions for government officials, including any conference, event and marketing expenditures related thereto. We have a strict prohibition against any incentive or payment, including facilitation payments, that may appear to incentivize a government official to expedite, make, secure or take any government action, including any actions related to acquisition, certification, contracting or procurement, influence any act or decision of such official for the purpose of promoting the business interests of Enterprise Governance Systems Corporation in any respect, to pursue unlawful anti-competitive or anti-trust behavior, or otherwise improperly or unlawfully promote the business interests of Enterprise Governance Systems Corporation in any respect.
For the purposes of this paragraph, a "government official" is defined as any of the following: (i) any employee of a government agency, department, entity or subdivision, including elected officials; (ii) any private person acting on behalf of a government agency, department, entity or subdivision, even if just temporarily or limited in scope or duty; (iii) officers and employees of companies that are owned or controlled by the government or a government agency, department, entity or subdivision; (iv) candidates for political office; (v) political party officials; (vi) other politically-exposed persons and (vii) officers, employees and representatives of public international organizations and public non-governmental organizations, such as the World Bank and United Nations. An entity should be considered as owned or controlled by the government if it is controlled by the government or it performs an activity or function the controlling government treats as its own.
 
ENTERPRISE GOVERNANCE SYSTEMS CORPORATION
PRODUCTS AND SERVICES MAY NOT BE AVAILABLE TO ALL CUSTOMERS.
Due to regulatory restrictions, some of Enterprise Governance Systems Corporation's products and services are not available to all users. Some products and services may vary by industry and jurisdiction and may not be available or suitable for all users.
 
ENTERPRISE GOVERNANCE SYSTEMS CORPORATION
MAINTAINS A ROBUST INFORMATION SECURITY MANAGEMENT PROGRAM.
Enterprise Governance Systems Corporation maintains a robust information security management and export control compliance program that includes management, reporting and registration with applicable United States Government agencies. The details of our export control compliance program are available upon request by duly appointed export compliance representatives of suppliers party to transactions involving the potential exchange of export-controlled articles or data, on an as-needed basis to the extent permitted by applicable law, and Enterprise Governance Systems Corporation may relay any compliance inquiries or questions, as requested or as determined by Enterprise Governance Systems Corporation, to the United States Department of State or United States Department of Commerce, as applicable, for ITAR-related or EAR-related matters respectively.
 
ENTERPRISE GOVERNANCE SYSTEMS CORPORATION
MAINTAINS UP-TO-DATE RECORDS.
Enterprise Governance Systems Corporation maintains an accurate record of information, including payments, financial transactions, contracting activities, compensation and access to data and information in our corporate books, records and accounts, and expects that all employees shall ensure that any payments, financial transactions, contracting activities, compensation and associated access to data and information will be recorded accurately, in an approved format, in a timely manner, and in sufficient detail as required by Corporation policy or applicable laws, regulations and statutes. No undisclosed, unrecorded or obfuscated accounts may be established for any purpose. Some or all of the Corporation's books, records and accounts may be subject to inspection by private sector or public sector third parties, including the auditors of customers, suppliers, or government agencies and departments.