Our Responsibilities as Corporate Citizens
Fair Business Competition
BWXT believes in free and fair trade, and we compete in a legal and ethical manner on the basis of the quality of our services. We are committed to compliance with fair competition and anti-trust laws that apply.
These laws are intended to prohibit practices that restrain trade or unduly limit free and fair competition. Fair competition violations include agreements with customers, suppliers, competitors and others, such as:
- Mutual understandings to control prices
- The boycotting of certain suppliers or customers
- Attempting to affect competition by selling the same product at different prices to different customers
- Making agreements to rig bids or proposals
- The allocation of products, territories
All employees should be aware of our policies in this area, but this is especially important for individuals in marketing, sales, purchasing and related positions, as well as those who are members of trade and professional associations or individuals planning to attend meetings of such groups.
Remember: Fair competition and anti-trust laws are complex and can have an impact on our business in many ways, including with regard to our suppliers and sales. Violation of the rules can have serious consequences for the Company as well as for anyone acting on our behalf.
- Do not enter into agreements with customers, suppliers, competitors or others that are intended to unfairly limit competition.
- Make purchases strictly on the basis of quality, price and service.
- Do not share information with a competitor about our customers, pricing or Company strategies.
- Don’t discuss any aspect of bidding with any of our competitors.
- Never share competitor information with customers or vendors.
- Never discriminate unfairly in terms of price or services between similar customers.
- When you have any doubt about dealings with competitors, suppliers or customers, you must consult with your group Legal department or contact Ethics & Compliance.
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 that they were involved with during their government service.
Insider Trading
State and federal law and Company policy prohibit buying or selling Company securities while in possession of material non-public information.
Material information can include information about mergers/acquisitions, financial results and projections, legal proceedings, contract awards or other business dealings.
Information is considered to be public only when it has been released through appropriate channels, such as broadly disseminated press releases, and enough time has elapsed to permit the investment market to absorb and evaluate the information. Company policy requires that two full trading days must have elapsed after the public release of material information before an individual may resume trading in that company’s stock or securities. Directors and certain other designated persons have additional responsibilities and must obtain approval from BWXT’s General Counsel prior to trading in Company securities.
- Don’t post non-public Company information on Internet message boards or social networking sites.
- Don’t share material non-public information with anyone, including your spouse, family and friends, who doesn’t have a Company business-related need for such information.
- Carefully adhere to the designated trading windows, blackout periods and other requirements of Company policy.
- Don’t engage in “tipping” (i.e., making recommendations or expressing opinions as to purchasing or selling Company securities based on material non-public information).
Yes. Your friend obviously had inside information about the upcoming merger. By sharing it, even in veiled terms, he tipped you off to a profitable stock deal. That is inside information.
Corruption and Anti-Bribery
Bribery and corruption will harm the Company and our reputation in the marketplace and will not be tolerated.
All employees, agents or representatives of BWXT must comply with the Foreign Corrupt Practices Act (FCPA) of the United States and the laws of any other countries which prohibit bribery. Payments of any kind or offers to pay or give anything of value to any foreign public or government official or to representatives of such persons in order to further Company business are not permitted. Similarly, such payments are not to be made through joint ventures or other affiliates doing business abroad.
The FCPA also requires that we maintain a system of internal accounting controls, and that our books and records accurately reflect all transactions. Facilitating payments will not be made by employees of the Company, or by third parties acting on behalf of the Company, its subsidiaries or affiliated companies.
For more information on facilitating payments, consult your group Legal department or the Chief Compliance Officer.
- Never offer or give anything illegal to an agent, representative, intermediary or employee of another company or a public official to influence any action in connection with the recipient’s position or in relation to that company’s affairs or business.
- Never offer or give any improper advantages such as improper commissions, brokerages, kickbacks, rebates or other compensation to an agent, representative, intermediary or employee of another company or a public official.
- Comply with the commercial bribery laws of the countries in which we conduct business or work.
- Provide adequate documentation for all Company payments.
- Obtain written approval of the General Counsel and the Chief Compliance Officer prior to making any facilitating payment.
Trade Restrictions and Export Controls
The Company respects all U.S. and foreign laws pertaining to export controls and trade restrictions, as well as U.S. anti-boycott provisions.
U.S. law requires that specific licenses must be received before the export or re-export of U.S.-origin products, services or technology to specified countries or entities, as well as to, or for, certain end users.
- Dealing with specifically identified boycotted countries or persons or entities acting on their behalf
- Transactions involving narcotics traffickers and terrorists
- Unlicensed exports for end uses related to nuclear explosives, missiles, chemical and biological weapons, and maritime nuclear propulsion. U.S. laws also prohibit anyone acting on behalf of the Company from participating in boycotts not sanctioned by the U.S. government. The Company is also required to promptly report any request to join in, support, or furnish information concerning a non-U.S. boycott. It is imperative that you know who you are dealing with and the ultimate destination and end use of products that we sell.
Environmental Stewardship
One of BWXT’s Core Values is the protection of the natural environment and its use. This translates into the positive health and safety of our employees and the communities in which we operate. We strive to continuously improve our environmental performance through resource conservation and efficient practices.
From our advanced nuclear technologies to handling hazardous waste, BWXT is committed to providing a safe and rewarding environment throughout our operations.
We measure our environmental performance and work to promote environmentally friendly practices that respect our environment and our natural resources.
Each of us must do our part to help meet BWXT’s environmental goals:
- Take responsibility for ensuring that our operations meet applicable government and Company standards.
- Safely handle, transport and arrange for the disposal of raw materials, products and wastes in an environmentally responsible manner.
- Promptly report any breaches of environmental protection laws or BWXT’s policies.
- Participate in all required training to develop and improve your skills and knowledge, and perform your job safely and in an environmentally sound manner.