Code of Employee Ethics and Conduct
Just as the company has a responsibility to conduct its business in strict compliance with all applicable laws and regulations, so too it expects its employees to act in accordance with the highest standards of business ethics both on and off company premises, and to avoid any appearance of impropriety. It is crucial that DCG Systems (DCG) employees observe all applicable laws and regulations while conducting business on the company’s behalf.
Ethical Standards
DCG is committed to conducting business in a fair and open manner within the spirit and letter of the law, with the highest regard for customers, the community, and employees. The success of the company depends not only on the knowledge, skills and abilities of employees, but also on sound judgment, self-discipline, common sense, and integrity. As such, all employees are required to maintain and uphold the following common ethical standards:
To pursue company objectives in a manner that does not conflict with the integrity of the company or the public interest;
To be truthful and accurate in all you say and do;
To protect confidential information;
To treat fellow employees with respect and dignity;
To uphold all laws and regulations relating to the business;
To maintain honest and fair relationships with all of the company’s vendors;
To ensure quality and value in the company’s products/services and relationships with customers and vendors.
It is company policy to comply fully with all laws, ordinances, rules, and regulations applicable to the operation of the company's business, and to avoid, in the course of the operation of the company, any situations that may engender any conflict between the personal interests of employees and the business interests of the company.
Conflicts of Interest
The company insists on the undivided loyalty of all employees, including management and nonmanagement staff. Employees must not engage in any conduct that would create an actual or potential conflict of interest or create the appearance of such a conflict. All employees are expected to avoid situations that create an actual or potential conflict in which an employee’s actions or loyalties are divided between company interests and those of another.
Conflicts of interest arise when an employee engages in a personal activity or has a personal interest that depends upon a specific outcome in the business of the company. These personal activities or interests may influence the employee's judgment, causing the employee to make decisions based upon the potential for personal gain, rather than in the best interests of the company.
To prevent possible conflicts of interest, the following behavior is deemed unacceptable and unethical:
Receiving or giving of merchandise, money, services, travel, accommodations, or lavish entertainment that might appear to have been given to influence a business decision. Gifts offered or received at any time that are of more than minimal or token value shall not be accepted and shall be returned to the sender with an appropriate explanatory note or letter.
Maintaining personal, business, or financial relationships with a customer or vendor where the employee has control or influence over the company’s relationship with that customer or vendor. For example, employees should not borrow from or lend personal funds to a customer or vendor of the employee's division.
Using information developed or learned on the job for personal or familial benefit. This includes the use of company databases, financial information, and intellectual property.
Maintaining outside directorship, employment, or political office that might appear to conflict or compete with an employee's responsibilities.
Conducting company business with or using position or authority to influence the company to conduct business with family members.
Sharing confidential or proprietary company related information with business associates or representatives of other companies.
The list above serves only to illustrate sources of possible conflicts of interest and does not constitute a complete list of all the situations that may result in a conflict of interest. Ultimately, it is the responsibility of each employee to avoid any situation that could affect his/her ability to judge situations independently and objectively or even appear to be a conflict of interest. It is important to note that under certain circumstances, conflicts of interest can amount to violations of criminal law. Any doubts should be resolved in a discussion with your manager, an HR representative, or the company’s legal counsel.
Employment of Relatives and Significant Others
To avoid conflicts of interest and promote stability and goodwill in the workplace, we won’t hire or transfer relatives into positions where they supervise or are supervised by another close family member.
We also try to avoid placing them in positions where they work with or have access to sensitive information about family members. The same general considerations apply if two employees marry or become involved in a domestic-partner relationship. If a supervisory, security, morale, safety, or other conflict results from the relationship, we reserve the right to use our discretion in hiring and placing employees in a manner designed to avoid these concerns. One of the employees may be transferred—or if necessary terminated—to resolve the situation.
By relatives we mean spouse, child, parent, same sex partner, brother, sister, grandparent, grandchild, niece, nephew, aunt, uncle, or first cousin or one acquiring such relationship through marriage (such as parents-in-law, brothers- or sisters-in-law, sons- or daughters-in law), or anyone cohabiting with a Company employee.
Confidential Information
DCG employees may learn information about the company that is not known by the general public. This information may include trade secrets, business plans, financial results, marketing and sales plans, or acquisition or disposition of company assets. Regardless of whether this type of information is specifically classified as confidential, it is each employee's responsibility to keep this information in confidence. All items such as manuals, reports, records and statements, other than those made available to the general public, are the property of the company, generally to be kept at the company's place of business, and are to be returned to the company when requested and upon termination.
General Employment Conduct
It is essential that everyone pay close attention to possible violations of the Code of Business Ethics and Conduct, whether these violations occur because of an oversight or intention.
It is the responsibility of all DCG employees to bring questionable situations to the attention of their manager, to an HR representative, or to the company’s legal counsel.
Unlawful Harassment and Discrimination
DCG is committed to creating a respectful, courteous work environment free of discrimination and harassment of any kind. We will not tolerate sexual, racial, or other prohibited harassment by any employee, vendor, customer, or visitor. Not only is it a breach of our policy, it is a violation of state or federal law. In addition to any disciplinary action we may take, up to and including termination, offenders may also be personally liable for any legal and monetary damages. The company will not pay damages assessed personally against an employee.
Harassment refers to behavior that is personally offensive, intimidating, or hostile, impairs morale, and interferes with work performance. We maintain a strict policy prohibiting harassment of all kinds, and we are committed to taking all reasonable steps to prevent such actions.
What is Sexual Harassment?
Under federal law, sexual harassment is any unwanted sexual advance, request for sexual favors, and other conduct of a sexual or gender-based nature when:
Submission to such conduct or communication is either explicitly or implicitly made a term or condition of an individual’s employment;
Submission to or rejection of such conduct or communication by an individual is used as a basis for employment decisions affecting such individual (e.g., transfers, advancement, benefits); and
Such conduct or communication has the purpose or effect of interfering with an individual’s work performance or creates and/or perpetuates an intimidating, hostile, or offensive work environment.
What are Other Kinds of Harassment?
Aside from sexual harassment, we prohibit harassment based on age, race, color, national origin, gender (including pregnancy), religion, physical or mental disability, medical condition, registered domestic partner status, sexual orientation, and any other basis protected by federal, state or local law.
Other Examples of Harassment
Instances of harassment, including sexual harassment, include but are not limited to the following kinds of behavior:
Verbal. Epithets; derogatory comments, slurs, or name-calling; sexually explicit, suggestive, or degrading words to describe an individual, sexually explicit jokes, emails or any other form of written communication, comments, noises, or remarks, racial or ethnic slurs, asking for sexual favors, repeated requests for dates, threats, propositions, unwelcome and unwanted correspondence, phone calls, and gifts, or other unwelcome attention.
Physical. Assault; impeding or blocking movement, any physical interference with normal work or movement when directed at an individual; unwanted and unwarranted physical contact, such as touching, pinching, patting, grabbing, brushing against, or poking another employee’s body.
Visual. Derogatory or offensive posters, cartoons, or drawings; displaying sexual pictures, writings or objects; obscene letters or invitations; staring at or directing attention to an employee’s anatomy; leering; sexually oriented or suggestive gestures.
Sexual. Unwanted sexual advances that make an employment benefit contingent on sexual favors, such as threats of demotion, termination, or other penalty if requested sexual favors are not given; making or threatening reprisals after a negative response to sexual advances.
In addition, we prohibit harassment or discrimination based on creed, nationality, ancestry, familial status, marital status, domestic partnership status, sexual orientation, mental or physical disability, physical appearance, perceived disability, and any other basis determined to be unlawful by federal, state, or local statutes.
These kinds of behavior can occur in one-on-one interactions or in group settings. Sexual harassment can also occur in the context of a relationship that was once consensual but has changed so that the behavior is no longer welcome by one party. It is impossible to define every action or all words that could be interpreted as harassment. The examples listed above are not meant to be a complete list of objectionable behavior.
Additional Information on Harassment
At the federal level, you can contact the Equal Employment Opportunity Commission (EEOC). At the state level, the agency name will vary. For example:
In California, it’s the Department of Fair Employment and Housing (DFEH).
In Massachusetts, it’s the Massachusetts Commission Against Discrimination (MCAD).
In New York, it’s the New York State Division of Human Rights.
In Texas, it’s the Texas Commission on Human Rights.
For more assistance, consult your local telephone directory under State or U.S. Government Offices, or consult directory assistance.
Last Updated: 08/01/2011
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