AGGRECOST™ Ethics & Anti-Corruption Policies

The AGGRECOST™ Ethics & Anti-Corruption Policy reflects the high standard of business conduct representing what is the hallmark of our organization. Our Ethics Policy helps define our commitment to support a culture of openness, transparency, trust and integrity in all we do.We are committed to conducting all of AGGRECOST™’s affairs and activities with the highest standards of ethical conduct. All of us have an obligation to adhere to this policy and encourage others to do the same.We are passionate about working with all of our customers. We must dedicate ourselves to pursuing our mission with honesty, fairness and respect for the individual, ever mindful that there is no “right way” to do the “wrong thing.”

The Ethics Policy helps clarify our standard of conduct. It makes clear that AGGRECOST™ expects its  employees to understand the ethical considerations associated with their actions. Our Ethics Policy affirms our long standing commitment to not merely obey the law, but also to conduct our business with integrity and without deception.

AGGRECOST™’s reputation for integrity and honesty is more important today than ever before. As we think of “what we do” and “how we do it,” always remember our responsibility to ask ourselves: “Am I doing the ‘right thing’ for the ‘right reason‘?”

Code of Ethics
The summary code of ethics includes the following provisions:
AGGRECOST™ employees must:

• Proactively promote ethical behavior as a responsible partner among peers in the work environment.
• Deal fairly with  Customers, suppliers, competitors, volunteers, and employees.
• Provide constituents with information that is accurate, completely objective, relevant, timely, and understandable.
• Comply with applicable government laws, rules and regulations.
• Maintain the confidentiality of information entrusted to them by our Clients or its Customers except when authorized or otherwise legally obligated to disclose.
• Accept responsibility for preventing, detecting, and reporting all manner of fraud.
• Be honest and ethical in their conduct, including ethical handling of actual or apparent conflicts of interest between personal and professional relationships.
• Protect and ensure the proper use of company assets.

The purpose for this ethics policy is to support a culture of openness, trust, and integrity in all AGGRECOST™ management and business practices.  A well understood ethics policy requires the participation and support of every AGGRECOST™ contractor and employee.

We are committed to the responsible use of AGGRECOST™ assets; to provide accurate, complete and objective information; to respect the confidentiality of financial and other information; to act in good faith and exercise due care in all we do; to comply with all rules and regulations, and to proactively promote ethical behavior.

AGGRECOST™’s Ethics are built on AGGRECOST™’s Guiding Values.  As such, we acknowledge our individual responsibility to ensure our collective success by practicing and promoting the following values which reflect a shared view of how we want to operate and be seen by others.

Our People

AGGRECOST™ is committed to provide a work environment that values diversity among its contractors and employees.  All Human Resource policies and activities are intended to create a respectful workplace where every individual has the opportunity to reach their highest potential.Employees are provided opportunities regardless of race, color, national origin, religion, sex, sexual orientation, marital status, age, veteran status or disability. These policies apply to both applicants and employees in all phases of employment including, recruiting, hiring, placement, training, development, transfer, promotion, demotion, performance reviews, compensation, benefits and separation from employment.We will evaluate how we are living up to our code of ethics by requesting feedback on a regular basis from our employees, volunteers and customers. We will provide all of our stakeholders a mechanism to report unethical conduct. We will begin with employee orientation and regularly communicate all of these expectations to employees and volunteers.

AGGRECOST™ employees, contractors and suppliers are expected to report any practices or actions believed to be inappropriate to their supervisor, or another AGGRECOST™ leader.

Our Customers

We are dedicated to 100% customer satisfaction.   We are devoted to developing “customer enthusiasm” and are passionate about exceeding customer expectations. We dedicate ourselves to anticipating the changing needs of customers and creating timely, innovative and superior programs, products and services.

Fraud

Fraud is defined as any intentional act or omission designed to deceive others, resulting in the victim suffering a loss and/or the perpetrator achieving a gain.  The AGGRECOST™ Senior Management have adopted a “no fraud tolerance” attitude.  In addition to the management and staff at all levels of the company have responsibility for preventing, detecting and reporting fraud.

In addition to the definition of fraud set out above, this policy covers any dishonest or fraudulent act, including but not limited to:

• Misappropriation of funds, securities, supplies or other assets.
• Impropriety in the handling or reporting of money or financial transactions.
• Profiteering as a result of insider knowledge of company plans or activities.
• Disclosing confidential and proprietary information to outside parties.
• Intentional, false representation or concealment of a material fact for the purpose of inducing another to act upon it to procure an advantage, benefit or gain.
• Accepting or seeking anything of material value from contractors, vendors or persons providing services/materials to AGGRECOST™, unless pursuant to the Acceptance of Gifts Policy.
• Destruction, removal, or unauthorized use of records, furniture, fixtures, and equipment.
• Any similar or related irregularity.

Each member of management will be familiar with the types of improprieties that might occur within his or her area of responsibility and be alert for any indication of irregularity.  An employee, volunteer, consultant, vendor, contractor, or outside agency doing business with AGGRECOST™ shall immediately report any irregularity that is detected or suspected, as instructed below under ‘Reporting Ethics Violations.’  Any employee or person who suspects or reports dishonest or fraudulent activity shall not attempt to personally conduct investigations or interviews related to any suspected fraudulent act.  Investigations will be coordinated with the Legal Department and other affected groups, both internal and external.  For additional information regarding fraudulent activities, refer to the AGGRECOST™ Fraud Risk Management Program.

AGGRECOST™’s Property and Information

Employees and volunteers are expected to protect the AGGRECOST™’s property at all times; including cash, equipment, records, employee, and customer information.  This also requires employees and contractors to maintain confidentiality regarding AGGRECOST™ records, and employee and customer information.

Nondiscrimination Policy

It is AGGRECOST™ policy that the contractor and staff structures and all programs and activities of AGGRECOST™, its Affiliates and components shall be designed and conducted without regard to race, religion, national origin, sex, age, disability or other non-merit criteria.

Reporting Violations

If you have questions or concerns about compliance with any of the policies listed above, or are unsure about what is the “right thing” to do, we strongly encourage you to first talk with your supervisor, program leader, another AGGRECOST™ Leader or the Human Resources department. . No director, trustee, officer, employee or AGGRECOST™ who in good faith reports an action or suspected action taken by or within the AGGRECOST™ that is illegal, fraudulent, or in violation of any adopted policy will suffer intimidation, harassment, discrimination or other retaliation. AGGRECOST™ treats complaints about and reports of possible discrimination seriously and investigates them as required by our procedures and any applicable laws.

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