All employees/contractors are expected to observe the highest standards of ethical conduct in dealing with both inside and outside persons in the performance of their jobs.  It goes without saying that no employee/contractor shall do anything illegal in the performance of his/her job, but it is equally important that employees exercise good moral judgment at all times.  Not only should wrongdoing itself be avoided, but also even the appearance of wrongdoing.  In other words, no employee/contractor should put himself/herself in a position where someone could question the propriety of his/her actions from a legal, moral and/or conflict of interest standpoint.

In any situation where an employee has any doubt whatsoever about the propriety of a certain course of action, he/she should simply ask the question, "If all the facts of this situation were revealed publicly, would I or the company be embarrassed or uncomfortable in any way?"

In order to avoid actual or potential conflicts of interest, employees should be aware of the standard of conduct expected in certain situations, as follows:

Financial Disclosure

At the time of employment/contract, each employee/contractor should make full disclosure of all known investments and financial interests in corporations or other business entities which have any actual or potential business relationship with Sine Nomine Associates, Inc., ("SNA" or "the Company"), including any subcontractors or suppliers, or are in competition with the Company.  Similarly, relationships with a consulting firm which renders services to the Company should also be disclosed.  This disclosure should include investments, financial interests, and business relationships maintained by any immediate family member of the employee/contractor.

In general, an employee/contractor should not maintain financial or other business relationships with companies or projects which might pose a conflict of interest for such employee/contractor in the performance of his/her duties.  Employees/contractor should disclose any potential conflicts of interest to the head of Human Resources or the CEO as soon as the employee is aware of the potential conflict.  Determination of the existence of such a conflict of interest will be made by the head of Human Resources or by the CEO.

Outside Employment

For full-time employees, employment at the Company should be considered a full-time job, and the holding of an additional job outside the Company is discouraged.  All employees must disclose any outside employment to the CEO of the Company.  In no case, should any outside work be performed during company hours/hours billed to Company, or with the use of company equipment, materials, vehicles, etc.  In addition, any outside work must not involve any actual or potential conflict of interest with the employee's/contractor’s duties at the Company.

This restriction is not intended to preclude employees from doing part-time work on their own time, nor to prohibit that contractors complete other work for other customer and on other projects on their own time; but it is intended to ensure that the employee's job at the Company has top priority in all respects, and that the employee/contractor refrain from any actions that might cause ethical conflicts.

Use of Company Business Relationships  

It is not permissible for any employee/contractor to take advantage of a business relationship established through the Company to elicit special consideration, extraordinary services, below-market pricing, etc. for a personal activity.  This rule does not preclude arms-length negotiations with an independent intermediary.  In the event an employee/contractor does use subcontractors or suppliers on a direct basis, he/she should make full disclosure to both the Director of Operations and the Chief Executive Officer of the Company.  No employee/contractor should seek discounts or other financial benefits from any person doing business with the Company by reason of such business.

This prohibition should not prevent an employee/contractor from taking advantage of discounts or other market concessions available to persons not affiliated with the Company such as seasonal sale prices, volume discounts, or wholesale prices available to members of a particular trade or profession.  The important point is that an employee/contractor not use his/her Company affiliation to obtain concessions not otherwise available in exchange for any actual or implied commitment from the Company to do business with the concession grantor.

Any employee/contractor having questions with regard to the applicability of these rules to a personal situation should consult the head of Human Resources or the CEO of the company.

Acceptance of Gifts  

Employees/contractors shall not accept referral fees, finder's fees, or any other financial reward from a person doing business with the Company.  However, employees/contractors will be allowed to accept occasional business meals which do not involve any lavish entertainment and do have a legitimate business purpose.  In addition, employees/contractors are permitted to accept small holiday gifts or promotional items from persons with whom the Company has a business relationship, provided that the value of any such item does not exceed $100.  In the event gifts of greater value are received under circumstances where it is not feasible to return the item, it should be turned over to the head of Human Resources or the CEO of the Company for disposition or use as corporate property.

This rule should not preclude an employee/contractor from having a social relationship with a person doing business with the Company, which may include the giving and receiving of items of financial value such as theater or sporting event tickets, provided the relationship is purely social and involves no expressed or implied business commitment.

Employees/contractors in doubt as to their ability to accept certain gifts or favors should consult the head of Human Resources or the CEO of the Company.

Outside Activities  

Employees/contractors are encouraged to participate in civic or trade associations provided such participation does not interfere with the performance of the employee's/contractor’s duties at the Company.  Furthermore, no such activity should pose a conflict of interest with the employee's/contractor’s position at the Company.

Violation of the above standards shall subject an employee/contractor to appropriate disciplinary action which may include termination of employment and/or legal proceedings resulting in fines.

Disclosure Statement 

Employees will be requested to complete a financial and employment Disclosure Statement at the time of hire and thereafter on an annual basis.