Ethics and Compliance

 

Our Code of Ethics and Business Module underpins our pledge to conduct ourselves in an ethical manner. Furthermore, we require all employees to read, understand and retain the Code of Ethics and Business Conduct (in parallel with six-month review course and certification). We empower our employees to speak up if there is a concern and to seek guidance when confronted with a situation that, they believe may violate our Code. To ensure our employees understand their obligations, we require all employees to read and understand our Code.

Sincerus' Code of Ethics and Business Conduct

 

Anti-Corruption / U.S. Foreign Corrupt Practices Act

Sincerus complies with all United States (U.S.) domestic anti-corruption laws that prohibit bribery in the U.S., with the U.S. Foreign Corrupt Practices Act (FCPA). This which prohibits illegal payments outside of the U.S., and with all other applicable laws in every country in which we do business. Any attempts to gain a business advantage through prohibited activities (such as illegal payments, bribes, kickbacks, gifts, or other inducements) are not tolerated.

IAC Policy

 

Combating Human Trafficking

Sincerus is committed to being a responsible international citizen and at all times, to acting consistently with its values throughout its international operations. We support the elimination of human trafficking and modern slavery throughout businesses and supply chains. We are committed to combatting human trafficking and child labor globally. Respect for the human rights of the people we employ, and the people employed by our suppliers is a core value.

CTIPS Policy

 

Compliance with International Trade Rules & Regulations

International Trade Compliance laws and regulations are essential to protect the national security of the U.S. and our foreign partner nations. Working for a U.S. foreign partner or in a foreign locations (OCONUS) subjects us to the controls set up by those governments as well as any applicable international agreements. Amentum's work is subject to multiple laws and regulations related to export controls, economic sanctions, trade embargoes, boycotts, and the importing of goods in the U.S. and abroad. Strict compliance with all applicable international trade controls is a company requirement.

Trade Policy

 

Confidentiality Commitment

We are committed to protecting the identity of all persons who use our secure reporting system. Reports are submitted by Lighthouse Services to the organization's designee and may or may not be investigated at the sole discretion of the organization. We will not disclose your identity without your express permission, although it is possible that your identity may be discovered during an investigation of the matter reported because of information you have provided

Lighthouse Services is an independent provider that assists Sincerus Global Solutions to identify improper activity. Employees who believe they suspect or are aware of a violation of the Code are expected and encouraged to report their concerns using the phone number or website reporting page.

Ethics Hotline: 1-833-222-1739

Lighthouse-Services Anonymous Reporting for Sincerus

 

Anti-Slavery Act

Sincerus Global Solutions acknowledges its responsibilities under the Modern Slavery Act 2015 and is committed to preventing slavery and human trafficking within its own businesses and in its supply chains. The business understands tha tthis requires an ongoing review of both its internal practices in relation to its labour force and its supply chains.

We have a zero-tolerance policy towards modern slavery. We will refrain from entering into business which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.

Anti-Slavery Act

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