Simulint Code of Ethics

Note from the Board

At Simulint, our greatest asset is our people and the integrity that defines our corporate ethos. Our commitment to ethical business practices is at the core of our operations, reflected in our principles of “Maintaining a confidential relationship with our clients” and “adhering to high standards of social and business ethics.”

Our clients entrust us with their reputations, a responsibility we take seriously. This trust demands that we consistently act with sound judgment and seek guidance when necessary to make the right decisions.

This Code of Ethics serves as a guide, but the expectations set by our clients and the board are more. We are held to a higher standard—one that calls for us to act conscientiously, with honesty and honor always.

Be well, and we call on you to uphold our values with diligence and pride.

 

– The Simulint Board of Directors

 

 

Introduction

Welcome to Simulint’s Code of Ethics (the “Code”). This Code is designed to support our commitment to integrity and ethical decision-making in all aspects of our business operations. This document provides the framework through which our employees, management, and board members are expected to conduct themselves to ensure the continued success and integrity of our company.

The purpose of this Code is to ensure that all individuals associated with Simulint understand and adhere to the company’s standards of ethical conduct and legal compliance.

This Code applies to all employees, officers, directors, and contractors of Simulint, collectively our Personnel, across all locations and divisions. Effective ethics is a team effort involving all personnel, who must familiarize themselves with the Code that follows this introduction.

We are committed to protecting clients, employees, partners, vendors, and the company from illegal or damaging actions by individuals, either knowingly or unknowingly. When Simulint is required to address issues, we will do so proactively and use our best judgment.

We will not tolerate any wrongdoing or impropriety at any time.  Simulint will take the appropriate measures to act quickly in correcting the issue if this Code is broken.

[“Always do right; this will gratify some and astonish the rest.”]

The Code is a set of rules and guidelines used to demonstrate our responsibility to all related parties and includes the following, based, naturally, on good judgment.

• Compliance with applicable laws, rules, and regulations.
• Avoiding impermissible conflicts of interest.
• Respect for others and their environment.
• Truthful disclosure of the transfer of information as permissible by law, rules, and regulations.
• Social responsibility to the extent reasonable and financially feasible.
• Preservation of natural resources and our environment.
• Preservation of corporate assets and intellectual property.
• Reporting of unethical behavior without consequence.

 

Compliance

At Simulint, we are committed to providing high-quality services and solutions while adhering to the highest ethical standards. To that end, we are all required to review, accept, and adhere to our Code. Exceptions may be granted, or provisions made only where conflicts with local laws exist. In this case, any exception must be jointly approved by executive management and in certain cases, our Board of Directors.

We must all be responsible for our behavior and comply with any laws and regulations that govern our society and company.  Furthermore, we are competent enough to make appropriate decisions, or know when we cannot, and engage other, appropriate parties for assistance when needed.

[When in doubt, ask.]

There are many laws and regulations within only a specific field. As our business spans not only industries but jurisdictions with different legal structures, it remains our responsibility to engage the proper advice to understand what we may or may not do.  When any doubt arises as to whether your actions are legal or ethical, contact your manager or appropriate personnel within the organization.  If your concerns are not addressed, Legal is always available as a last resort if you feel your situation warrants it.

Managers at every level are required to enforce our Code and must lead by example. They must ensure that their staff and colleagues abide by the Code and act when they witness or suspect unethical conduct.

 

Conflicts of Interest

Simulint believes that motivating employees within ethical boundaries with what matters most to them will minimize the temptation to seek personal interests or personally profit from unethical activity.

[If your actions are personally benefitting you, your family members, or other relationships when these actions relate to business conducted by our company, it is likely that a conflict of interest exists.]

We value Simulint assets, time, intellectual property, and other resources, and Personnel are forbidden to engage in business opportunities for personal gain or the gain of others, unless explicitly authorized.

Some circumstances may arise that can be easily identified as a conflict or potential conflict of interest.  Those should naturally be avoided; however, consequential issues typically surface from those situations that tend to be ambiguous.  Other business opportunities, investments, or employment can often lead to conflicts of interest.  Serious thought should be given to any business conducted outside the company, and your manager or appropriate Simulint personnel must be consulted to determine if a conflict of interest may exist or if such activity is condoned by Simulint.

Simulint maintains its own core values, however it will not support any political activity with the use of corporate funds or resources.  Furthermore, you may not take a political position, support a political party, or endorse a politician on behalf of Simulint.

While Simulint does not prohibit other employment, it must not conflict with the interests of Simulint, negatively impact your job performance, or jeopardize Simulint’s reputation.  Should you desire supplemental employment, it is always best to discuss this with Talent Management, Legal, or your manager.

Whether you are a recipient or the donor of a gift, entertainment, or other benefit, your action must be lawful and not impair your judgment in your duties at Simulint.  Furthermore, any of these actions that might be construed as inappropriate by a third party, even when within the law, should be avoided. Bribes, other illegal payments, and extortion are prohibited activities and may not be used to obtain new business, retain existing business, or provide personal gain to an individual.

 

Confidentiality and Data Protection

Confidentiality and data protection are paramount at Simulint, reflecting our commitment to safeguarding sensitive information. All employees are entrusted with the responsibility to maintain the confidentiality of data provided by the company, our clients, and other stakeholders. This includes proprietary information, client data, and any other sensitive material that may come into their possession during their work. Adherence to applicable data protection laws and regulations is mandatory, and any breach of data security must be reported immediately to the appropriate channels. Our privacy policies are designed to ensure compliance with legal requirements and to protect the privacy rights of individuals.

In addition to maintaining confidentiality and adhering to privacy policies, employees are expected to ensure the secure handling of all information, whether in digital or physical form. This includes implementing appropriate security measures such as password protection, encryption, and access controls to prevent unauthorized access or disclosure of sensitive data.

Employees must also exercise caution when sharing information electronically or in print, taking necessary precautions to minimize the risk of data breaches or leaks. By prioritizing the secure handling of information, we mitigate the potential risks associated with data loss or unauthorized access, safeguarding the confidentiality and integrity of our data assets.

 

Professional Conduct

Respect in the workplace is a fundamental principle at Simulint, shaping our culture and interactions among employees. We expect all team members to treat each other with dignity and consideration, fostering a positive and inclusive environment where everyone feels valued and respected.

Simulint agrees with and supports the Universal Declaration of Human Rights put forth by the United Nations.  Additionally, Simulint will provide a safe and comfortable workplace in which all employees must respect the space of others and their personal property. Such respect extends to all other relationships beyond the workplace when representing Simulint.

[We must refrain from interfering with the human rights of others and celebrate our differences.]

You shall not discriminate based on age, race, gender, color, marital status, sexual orientation, religion, nationality, or ethnicity. We must accept the diversity within our company and beyond.  You are encouraged to celebrate this diversity with yo`ur colleagues, become more culturally aware, and expand your knowledge.

Discrimination, harassment, or any form of abuse is unequivocally prohibited within our organization. Such behavior undermines our core values and erodes trust, and as such, will be met with swift disciplinary action. By upholding a culture of mutual respect and intolerance for discrimination or harassment, we cultivate a workplace where every individual can thrive and contribute to our collective success.

 

Social Responsibility

As our Board of Directors mentions in the “Note from the Board,” we hold ourselves to a higher standard, above what is required of us. Our company believes passionately in serving our clients, but also in contributing to our community. We all share the same planet and do not wish harm or misfortune to befall anyone. We help when and where we can, even if our contributions are not recognized. This is perhaps the greatest contribution of all.

[“We are afraid to care too much, for fear that the other person does not care at all.” – Eleanor Roosevelt]

Simulint believes in supporting education and an equal opportunity for all. We contribute to education reform and improvement while remaining politically neutral. We support fights against our common non-discriminatory enemies and rally to promote awareness. We genuinely care, not only about our employees, clients, and partners, but about people.

Our services and solutions should never be provided in a socially or ethically detrimental manner. We should always be conscious of the impact our behavior has on others and our community.

 

Protecting the Environment

We live in an incredibly challenging and interesting time. Global warming, over-population, depletion of natural resources—they all weigh on our minds.  At the same time, we are developing technologies that can aid in solving these same global issues.  At Simulint, we believe that by helping companies operate efficiently, we can conserve our time, our wealth, and our world’s resources.

Not only do we advise our clients on operational efficiency, but we also use underlying intelligent networking solutions that increase security, improve data access, and reduce the need for a centralized workforce. As Simulint continues to innovate, we do so with our natural resources in mind and applaud our employees, partners, and clients who embrace a better future with us.

 

Financial Integrity

At Simulint, we prioritize unwavering financial integrity to uphold trust and transparency in all our dealings. We adhere to stringent guidelines and policies to ensure the integrity of our financial operations.

All financial transactions within our organization must be documented with accuracy and transparency. This includes recording revenues, expenses, assets, liabilities, and equity in accordance with generally accepted accounting principles (GAAP) or other relevant accounting standards. Our robust record-keeping and regular reviews guarantee reliable financial reporting, empowering stakeholders with informed decision-making.

Simulint has zero tolerance for bribery, corruption, or any form of unethical conduct related to financial matters. We prohibit employees from engaging in or condoning any acts of bribery, extortion, kickbacks, or other corrupt practices, whether involving public officials, business partners, or any other parties.

At Simulint, financial integrity is non-negotiable. By upholding transparency and ethical standards, we strengthen our foundation for sustainable growth and unwavering stakeholder confidence.

 

Protecting Corporate Assets

The value of respect that guides us in how we treat others and their property extends to our corporate assets.  Corporate assets generally include but are not limited to physical assets and intellectual property.  Both are critical to Simulint’s business and must be protected.

Physical assets include any item capitalized or expensed through Simulint funding. Any asset, physical or intellectual, which remains in your possession during your tenure with Simulint is your responsibility and should be treated accordingly.  Any intellectual property such as proprietary frameworks, software code, designs, or patentable material must not be disclosed to any external party or beyond acceptable internal boundaries without proper authorization.  You should engage your manager or Legal should you ever have any doubt as to what may or may not be disclosed.

In addition to actively protecting our assets, we must also take care when accessing them.  Passwords, keys, badges, etc. should always be used in ways that will not compromise assets.

Should you sever ties with Simulint, all assets remain the property of Simulint and may not be used for personal or competitive means without the express written consent of Simulint. All Simulint property, digital and physical, must be returned prior to your departure.

The foregoing also applies to our clients, and we must vigorously protect their assets as if they were our own.  You may not disclose any client information to any third party without written authorization from the client or unless mandated by an authorized government agency with jurisdiction.

 

Workplace Safety and Health

Workplace safety and health are paramount priorities at Simulint, reflecting our unwavering commitment to the well-being of our employees. We adhere to stringent safety standards to ensure a safe and healthy work environment for all team members. All Personnel are responsible for actively participating in maintaining these standards and for promptly reporting any hazards or concerns to the appropriate personnel. Through fostering a culture of safety awareness and accountability, we mitigate the risk of workplace accidents and injuries, promoting the physical and mental well-being of our workforce. Our dedication to workplace safety underscores our commitment to providing a conducive and secure environment where employees can thrive and excel in their roles.

 

Communication

Simulint’s communication systems include but are not limited to phones, electronic messaging, social media, web sites, and blogs.  These systems are governed by the Technology Acceptable Use Policy which all Personnel must review and accept in writing.  The same practices should also be extended to any client system.

Appropriate etiquette must be used when communicating with your colleagues and external parties. Any authorized information provided to the public must be true and accurate.  New information must be approved before being released to the public whether provided digitally, through published materials, press releases, conference, or general announcement.  At no time may confidential information be distributed (leaked) to third parties.

Any financial reporting to an authorized agency must be fair, accurate, and delivered professionally.

 

Conflict Resolution

At Simulint, we recognize that conflicts with this Code may arise in the course of our business operations, and it is essential to address them promptly and effectively.

We have established channels for employees to report any conflicts, ethical concerns, or policy violations they encounter. These mechanisms ensure that employees feel empowered to raise issues without fear of retaliation. Whether it is through direct communication with their supervisors, HR, or utilizing our anonymous reporting system, every employee has a voice.

We are dedicated to protecting whistleblowers who come forward in good faith to report misconduct. Our company policy prohibits any form of retaliation against individuals who report violations of our Code. Whistleblowers can rest assured that their identity will be kept confidential, and they will not face adverse consequences for speaking up.

Upon receiving a report of conflict or misconduct, we conduct thorough and impartial investigations to gather all relevant information. Investigations into alleged misconduct will respect the rights of all involved parties and be conducted confidentially to the extent possible.

After completing the investigation, we will take appropriate action to address the conflict or misconduct identified. This may involve corrective measures, disciplinary action, or implementing preventative measures to mitigate similar issues in the future.

Our goal is to foster a workplace environment where conflicts are addressed promptly and constructively, allowing us to focus on our mission and achieve our collective goals.

Violations of these guidelines may result in disciplinary action, up to and including termination of employment. These guidelines will be reviewed annually and updated as necessary to ensure they remain relevant.

All Personnel are required to sign an acknowledgment form confirming they have read, understood, and agree to abide by this Code.