Introduction to BWXT’s Code of Business Conduct

Our Code of Business Conduct provides the ethical guidelines and expectations for conducting business on behalf of BWXT. It provides a summary of certain key Company policies to assist employees in complying with these guidelines as well as laws applicable to the Company.

In addition to serving as a policy summary, there are several elements of the Code that describe our standard of higher ethical conduct. Supported by our underlying policies and principles, the Code reinforces the Company’s commitment to integrity and sets expectations of behavior for employees on the job.

The Code applies to all directors, officers, and all full-time, part-time, and temporary employees of the Company. As a representative of the Company you must act with honesty and integrity in all matters.

Certain external business partners of BWXT serve as an extension of the Company. We expect our suppliers, vendors, contractors, agents, representatives, consultants and joint venture partners to behave in the ethical manner described in our Code when doing work for the Company. Managers who supervise our external business partners are responsible for ensuring that they understand their compliance obligations. If an external business partner fails to comply with our ethics and compliance policies, it may result in the termination of its contract with BWXT.

While the Code cannot address every issue that we may encounter, it does provide guidance and resources for those times when the right choice may not be clear.

Our Code of Business Conduct provides the ethical guidelines and expectations for conducting business on behalf of BWXT. It provides a summary of certain key Company policies to assist employees in complying with these guidelines as well as laws applicable to the Company.

In addition to serving as a policy summary, there are several elements of the Code that describe our standard of higher ethical conduct. Supported by our underlying policies and principles, the Code reinforces the Company’s commitment to integrity and sets expectations of behavior for employees on the job.

The Code applies to all directors, officers, and all full-time, part-time, and temporary employees of the Company. As a representative of the Company you must act with honesty and integrity in all matters.

Certain external business partners of BWXT serve as an extension of the Company. We expect our suppliers, vendors, contractors, agents, representatives, consultants and joint venture partners to behave in the ethical manner described in our Code when doing work for the Company. Managers who supervise our external business partners are responsible for ensuring that they understand their compliance obligations. If an external business partner fails to comply with our ethics and compliance policies, it may result in the termination of its contract with BWXT.

While the Code cannot address every issue that we may encounter, it does provide guidance and resources for those times when the right choice may not be clear.

Compliance with Laws and Regulations


Our workforce includes citizens of different countries and diverse cultural groups.

We are subject to the laws and regulations of the United States, its states and municipalities, as well as the laws and regulations of other countries where we do business. It is our policy to comply with all laws and applicable regulations everywhere we engage in business.

It is important that each of us is aware of relevant laws and regulations that apply to our work, and that we never intentionally engage in conduct that violates these applicable standards. Not only should we be vigilant in our compliance with all applicable laws and regulations, we should also be alert to changes in the law or new requirements that may affect our business.

View of aircraft carrier.

Taking Action When You Have Questions – Reporting Possible Violations


BWXT has an opportunity to improve every time you ask a question or raise a concern.

When you speak up to clarify a policy or report questionable conduct in the workplace, you are protecting your colleagues, our stakeholders and the Company.

If you believe that someone associated with BWXT (including managers, supervisors, fellow employees, suppliers, vendors, contractors, agents, representatives, consultants and joint venture partners) has violated a provision of our Code or policies, bring the matter to the attention of your supervisor or manager, your Human Resources representative, the Legal department, the Ethics & Compliance team or call the Helpline at (855) 871-9138 or submit a report.

Resources for Questions and Reporting

You have an obligation to speak up and report any unethical business conduct and any violation of the Code or of Company policy.

Remember, an issue cannot be addressed unless it is brought to someone’s attention. You have several options for raising questions and concerns. Most questions or concerns you are likely to face can be resolved by working with your supervisor. Your supervisor is most familiar with you and your job and is in the best position to assist you. You also can ask questions or report illegal or suspect activities by using any
of the following methods:

EMAIL/MAIL

  • By email: ethics@bwxt.com
  • By mail:
    • BWXT Ethics & Compliance
      800 Main Street
      Lynchburg, VA 24504
      (Mark the envelope “confidential”)

TELEPHONE/TEXT

  • By telephone/text: BWXT Helpline:
    • U.S. Direct Access by Phone Call:
      • (855) 871-9138
    • U.S. Direct Access by Text:
      • (434) 290-4257
    • You may call anonymously. If you give your name, your identity and the information you provide will be shared only on a “need to know” basis with those who are involved in addressing your concern.

WEB/OTHER

  • By web submission: www.bwxthelpline.com
  • Compliance website: http://www.bwxtethics.com
  • Other resources:
    • Your local Ethics & Compliance manager or coordinator
    • Any BWXT manager or supervisor
    • A BWXT Human Resources representative
    • The Legal department

Making the Right Choices


Codes and policies offer important guidance for our daily conduct at work, but these alone cannot create a company-wide culture of integrity.

We each help to shape our culture through our personal commitment to meet the highest ethical standards in all we do.

Man wearing hard hat working in factory

Seek guidance if you are still unsure what to do. Don’t hesitate to ask questions and get the advice you need. Keep asking questions until you have the information you need to make the right choice.

If you are faced with a difficult decision, ask yourself the following questions:
  • Is it the right thing to do?
  • Have I considered all the options, and do I have all the facts?
  • Will my actions be consistent with BWXT’s Core Values and the law?
  • Will I be comfortable telling others about my decision?
  • Can I honestly say I would be proud of the choice I made?
  • What is the possible impact of my actions on others?
  • What would I say if someone else made the same choice?
  • How will my decision be viewed in one month, one year, or later?
  • If it became known, might my action result in embarrassment either within or outside the Company?

Protection from Retaliation


Regardless of the type of misconduct reported, or the method of reporting that is chosen, BWXT will not tolerate any retaliation or retribution against anyone who makes a good faith report of an alleged violation of the Code or policies.

Individuals who raise concerns or who help to resolve reported matters are protected against retaliation. However, anyone who uses the ethics and compliance program to spread falsehoods or threaten others, or with the intent to unjustly damage another person’s reputation, will be subject to disciplinary action.

We take claims of retaliation seriously. All such claims will be thoroughly investigated and, if substantiated, retaliators will be disciplined up to and including termination of employment. If you believe you have been retaliated against, call the Ethics & Compliance department.

Submarine.
Two peole wearing hard hats and protective jackets looking at laptop.

Accountability and Discipline


Violating relevant laws, regulations, or this Code, or encouraging others to do so, exposes the Company to liability, puts BWXT’s reputation at risk and may result in disciplinary actions up to and including termination of employment.

If an ethics or compliance problem does arise, your supervisor will coach and counsel you to help develop an effective solution. If you fail to respond to coaching or counseling, or further incidents occur, formal discipline may be necessary.

You should understand that violations of laws or regulations may also result in legal proceedings and penalties including, in some circumstances, criminal prosecution.

BWXT takes a zero-tolerance position on these violations.

Waivers and Exceptions


In rare situations, BWXT may grant exceptions to this Code.

Any exception request must be made and explained in writing to the Ethics & Compliance department.

Approvals of such requests will be made in writing and maintained by the Ethics & Compliance department. Any waiver of the Code for executive officers or directors must be approved by the board of directors or a board committee.

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