Compliance with Laws and Regulations
A: You need to pay attention to both. The laws and regulations that govern your work are more detailed and therefore should be carefully applied on the job. Our Code guides your decision-making in a more generic way, but is no less important. Nothing in our Code violates the law, and vice-versa.
Resources for Questions and Reporting
A: You may call (855) 871-9138, text the BWXT Helpline at (434) 290-4257 or contact the Helpline via the web at www.BWXTHelpline.com. You always have the option to report anonymously, but you should give as many details as possible so that the situation can be investigated. You may also contact the Ethics & Compliance department directly at email@example.com or by phone or email to a member of the Ethics & Compliance team.
A: If you have a concern or see a possible violation, the first place to turn is to your supervisor. If you are uncomfortable reporting your concern to your supervisor, use the above resources or report it using the BWXT Helpline at (855) 871-9138. The Helpline is available 24 hours a day, seven days a week. The call will be answered by a professional third party that we have contracted for this purpose. The interviewer will work with you to document the situation in detail. Your call will not be recorded and you do not have to give your name, although this may make it more difficult to investigate and resolve your concern. The information will then be relayed to our Ethics and Compliance department to look into the situation and investigate your concern.
If you call anonymously, you can call back to the third party using the BWXT Helpline number and a reference number that will be given to you. This will allow you to provide additional information. Confidentiality for those who report concerns will be maintained to the fullest extent possible.
Making the Right Choices
A: If the situation is truly against policy, you have an obligation to report it. Your supervisor may not be as aware of the problem as you think. However, even if he or she is aware, the situation should still be reported and corrected.
Protection from Retaliation
A: The person who retaliated, his or her manager and our company may all be held liable. All employees must understand our company’s non-retaliation policies. If there is a retaliation claim, both the manager and the retaliating employee may be subject to disciplinary measures. If you are aware of possible retaliation, you should call the BWXT Helpline or the Ethics & Compliance department with the information that you know.
A: The Company’s reputation is determined by the actions of individuals like you and your co-workers. Your decisions do make a difference. You should speak to your co-workers if you observe behavior that “pushes the envelope” of right and wrong. But even if you never say a word to them, your good example may cause them to reflect on their actions and behave more ethically in the future.
Respect for Diversity
A: You’re right that everyone is equally responsible for making your workplace a better place. Speak to your Human Resources representative about this situation. Perhaps a training session or facilitated open discussion will help to clear the air. As a manager, you are responsible for paying attention to subtle things that happen in your area that may contribute to a hostile environment.
Fair Employment Practices
A: The best thing for you to do is to be consistent in providing feedback to all members of your team. If the performance criterion is fair and evenly applied, then you will be able to defend your position even if you are accused of discrimination. However, if you refuse to give this employee feedback, you’re actually depriving her of a chance to improve performance. That could be considered harassment.
A: You are correct that sexual harassment violates the law and our policies. Further, no one in our company should be afraid to report misconduct. If you cannot speak with a supervisor, then you should forward a report to Ethics & Compliance, who will take it from there.
Health and Safety
A: It’s understandable that you don’t want to get your coworker in trouble, but his physical tiredness poses a risk not only to himself but to the other workers on his production line. Unfortunately, the right decision isn’t easy in this situation. It’s important for you to tell your supervisor about your concerns. If the supervisor is unable to resolve the situation, submit a report to a Human Resources representative.
Integrity in Business Relationships
A: Any business deal that’s a violation of our Code is unacceptable, no matter how “creative” it is. Companies with whom we do business need to understand our commitment to integrity. The short-term benefits of unethical solutions never outweigh the long-term harm done to BWXT’s reputation.
Conflicts of Interest and Corporate Opportunities
A: Company policy is not intended to disrupt personal friendships. However, it could be a problem if you play a role in selecting your friend’s company as a supplier or if you have to deal with your friend on behalf of our Company. Tell your manager about this friendship, and excuse yourself from participating in decisions or negotiations with your friend and the supplier.
Gifts and Entertainment
A: For the purposes of our Code and policies, the term “gifts and entertainment” has the broadest possible meaning, including gifts and favors of all kinds, trips, services, meals, tickets to events and any other gratuitous item, benefit or thing of value.
A: The answer is maybe. Since the supplier will not be in attendance, it appears there is no business purpose for the event. However, the value of the gift may exceed the limits established by our company policy. Please contact the Ethics & Compliance department for guidance before accepting this gift.
Confidential and Proprietary Information
A: It’s fun to compare notes about new techniques, ideas and solutions with someone who can appreciate innovation, but that doesn’t mean it’s harmless. If your job involves anything that’s considered a trade secret or confidential, then you should not talk to him about it. Even though your friend may be curious and genuinely interested in your job, you have no way of stopping him from innocently discussing it with someone else, who may turn out to be a competitor or the press.
Integrity of Records and Accounting Procedures
A: It’s your responsibility to understand every transaction you enter, since you may need to answer questions about its accuracy. You were correct to ask your supervisor for advice. Even though she approved the transaction, your questions related to the integrity of the transaction should be passed along to a higher level of management, Human Resources or the Ethics & Compliance department.
Communicating with the Public
A: When participating in chat rooms or live industry events, do not represent our Company unless you have previous authorization to do so. Our Company has trained and authorized certain employees to speak on behalf of the Company in public. Although your purpose was noble, speaking in the chat room about Company matters was inappropriate. Do not confirm or deny information or divulge confidential information.
Political and Charitable Contributions
A: No. Even if your supervisor is not pressuring you, the request is inappropriate and coercive.
Fair Business Competition
A: If the individual had access to confidential, proprietary or source selection information in the course of his or her government service, our Company may be perceived as having an unfair competitive advantage in the bidding process. Also, federal rules limit the extent to which former officials can participate in projects they were involved with during their government service.
A: Yes. Your friend obviously had inside information about the upcoming merger. By sharing it, even in veiled terms, he tipped you off to a potentially profitable stock deal. That is inside information.