Our Responsibilities to One Another
All employees have a responsibility to do their part to promote and maintain the highest ethical standards.
In particular:
- Be familiar with the information contained in this Code and corporate policies, paying close attention to the policies that pertain to your job responsibilities.
- Complete an acknowledgment of the Code, confirming your adherence to the principles set out in this code.
- Promptly report concerns about possible violations of laws, regulations, policies, or this Code to your supervisor, any member of management, our Ethics & Compliance department or call the BWXT Helpline.
- Complete all required compliance training in a timely manner, and keep up-to-date on current standards and expectations.
- Cooperate with investigations, auditing and monitoring procedures, and if required, provide all requested documentation.
- Participate in all business transactions with the highest degree of ethical conduct. BWXT explicitly prohibits the making of false or misleading statements in all business dealings.
No reason, including the desire to meet business or personal goals, is ever an excuse for violating laws, regulations or policies.
Ethical Leadership
Management has the added responsibility for demonstrating, through their actions, the importance of high ethical standards.
Managers should not consider employees’ ethics concerns as threats or challenges to their authority – we want the ethics dialogue to be a natural part of daily work. As a manager or supervisor, you are responsible for the ethical conduct of the employees under your supervision and direction. Failure to exercise this responsibility through training, communication and taking disciplinary action when required may subject you to disciplinary action as well.
- Help create a work environment that recognizes effort, appreciates teamwork and values mutual respect and open communication.
- Never ask an employee to do what you would be prohibited from doing yourself.
- Be a resource for employees. Communicate to employees about how the Code and policies apply to their daily work.
- Serve as a role model for the highest ethical standards, and work to create and sustain a culture that demonstrates care and concern for your colleagues.
- Be proactive. Take reasonable actions to prevent and identify misconduct, and report situations that might impact the ability of employees to act ethically on behalf of the Company.
- Take prompt action to correct business conduct that is inconsistent with the Code or policies.
- Seek assistance from other supervisors whenever you are unsure of the best response to any given situation.
- If you supervise external business partners including suppliers, vendors, contractors, agents, representatives, consultants and joint venture partners, ensure they understand and meet their compliance obligations.
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
The diversity of BWXT employees is a key asset.
We are committed to providing a professional atmosphere for all employees that promotes productivity and encourages creativity and innovation. We will strive to maintain a diverse workforce where employees are hired, retained, compensated and promoted based on their contribution to the Company and their performance. It is important that we work together to be sure that all BWXT employees are treated fairly and with respect, regardless of race, color, religion, national origin, ancestry, disability, sex, age, or other protected characteristics as defined by U.S. federal or local laws.
- Treat all colleagues, business partners, customers and visitors with respect.
- Never distribute or display offensive material.
- If you supervise others, judge them on performance; avoid introducing unrelated considerations into your decisions. Use objective, quantifiable standards.
You’re right, 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
BWXT offers equal employment opportunities to qualified individuals, regardless of race, religion, national origin, age, sex, disability – or any other factor protected by law and/or Company policy.
These policies apply not only to hiring decisions, but to all aspects of employment. Every employment decision you make, from compensation and benefits to transfers and training, must conform to applicable federal, state or local laws and to Company policy.
If you have fair employment practices questions, consult with your local Human Resources representative, the EEO manager, or your local Ethics & Compliance department.
- If you are hiring an employee, choose individuals based only on their qualifications to perform the job.
- Supervisors and managers have a special responsibility to consistently adhere to and apply the Company’s policies regarding equal employment opportunity and must be able to show non-discriminatory reasons for taking personnel actions.
- Review your own decisions to ensure that merit and business considerations drive your actions, rather than subtle bias.
- Discrimination questions or concerns should be addressed when possible with the employee’s supervisor or manager. Additional Company resources available to the employee are: Human Resources representatives, Legal Department, Chief Compliance Officer and the BWXT Helpline.
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.
Harassment
Harassment in the workplace is behavior that is unwelcome and offensive to specific individuals or groups.
We will not tolerate actions, comments, inappropriate physical contact, sexual advances, or any other conduct that is intimidating or otherwise offensive or hostile.
Harassment can take other forms as well. Examples include calling individuals derogatory, crude or insulting names; performing threatening, intimidating, or hostile acts; and placing written or graphic material in the work place that denigrates or shows hostility or aversion toward an individual or group. This includes accessing and disseminating pornographic material via the Company’s information technology systems.
Submission to harassing behavior is unnecessary and never a term or condition of employment for any person at BWXT. If you are offended by an action or remark, speak up and advise the person that you are upset by his or her words or actions. Request that such behavior stop.
- A request for a date, sexual favor or other verbal or physical conduct of a sexual nature that is unwelcome is made as a condition of employment or used as the basis for employment decisions; or
- An intimidating, offensive or hostile work environment is created by unwelcome sexual advances, insulting jokes or other offensive verbal or physical behavior of a sexual nature.
- Maintain a work environment that is free from harassment.
- If possible, speak up and tell a person if you are upset by his or her actions or language, explain why and ask him or her to stop. Make a formal complaint if the matter is serious or a direct approach is not successful.
- Even if you believe your acts or words are innocent, if someone says you are offending them and asks you to stop, do so at once. Be mindful that “harassment is in the eyes of the recipient.”
- Don’t access, distribute or display offensive material. Remember, it is a direct violation of Company policy to access inappropriate (i.e., pornographic) sites on the Internet.
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.
Abuse of Drugs and Alcohol
BWXT is committed to providing a safe and productive work environment. An important part of our effort is to ensure that the workplace is free from the use of illegal drugs, the misuse of legal drugs and the abuse of alcohol.
You are expected to be fit for duty and capable of performing your assigned responsibilities in a safe and productive manner. Employees should report to work in condition to perform their duties, free from the influence of illegal drugs or alcohol.
The use of illegal drugs in the workplace will not be tolerated. Anyone who is under the influence of illegal drugs or alcohol while conducting business for BWXT could create an unsafe work environment and may therefore be subject to discipline. Where permitted by law, to assure compliance, the Company reserves the right to test for the use of alcohol or other controlled substances, and may conduct searches in the workplace if there is reason to suspect violation of policy.
- While at work or on Company business, you should be alert, never impaired, and always ready to carry out your work duties.
- Possession of legally prescribed drugs is not prohibited, but you are responsible to ensure that while in the workplace the use of prescribed drugs will not affect your productivity or the safety of the workplace.
- Follow local laws and customs when they are more restrictive than Company policy.
- Don’t bring alcohol into the workplace by any means or for any purpose not authorized by the Company.
- If you have a problem with substance abuse, seek professional help before it adversely affects you personally or professionally.
Health and Safety
We aim to provide a safe, secure and healthy work environment where zero injuries are the norm.
We can only achieve our goal of a safe, secure and healthy work environment through the active participation and support of everyone. BWXT empowers and expects all employees, contractors, customers and vendors to follow the Company’s EH&S policies and procedures.
We believe that all occupational and environmental incidents can be prevented, and we have an established safety program to help us achieve our environmental, health & safety (EH&S) goals. An integral part of our safety program is our Safety Conscious Work Environment (SCWE), where we encourage an open culture for all personnel to raise issues that are important to them and allow for resolution with commitment, respect and timeliness. Situations that may pose an EH&S hazard must be reported immediately. It is important for each of us to help maintain safe working conditions for ourselves, our co-workers and visitors to our facilities. We must all participate in safety training, follow safety standards and report any safety concerns, accidents, injuries and unsafe conditions. Managers, supervisors, employees, contractors, customers and vendors must work together to develop the proper attitude, practice and promote proper work habits, use good judgment and comply with all applicable EH&S rules and regulations.
It is your responsibility to:
- Always wear required safety equipment.
- Never tamper with safety equipment or systems.
- Create and maintain a work environment that encourages open communication. The more we communicate, the better we can respond to any unsafe or non-compliant situations.
- Make sure you are familiar with the laws, regulations, policies and procedures that apply to your job.
- Notify your supervisor or site safety personnel immediately about any unsafe equipment, or any situation that could pose a threat to health or safety or damage the environment. All personnel have the right and responsibility to stop any work they feel may be unsafe.
- Cooperate in all investigations to determine the cause of incidents.
At BWXT we do not tolerate:
- Threatening remarks
- Causing physical injury to another
- Intentionally damaging someone else’s property, or acting aggressively in a manner that causes someone else to fear injury
- Unauthorized possession of firearms, weapons or explosives on company property or while on duty
- Threatening, intimidating or coercing fellow employees on or off the premises – at any time, for any purpose
If you have any safety concerns, including knowledge of violence or the threat of violence or intimidation, it is your responsibility to report it to your supervisor, an Human Resources representative or the Ethics & Compliance department immediately. For further information, requirements for the creation and maintenance of a safe work environment are detailed in the EH&S procedure manuals developed by each operating group or division.
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 the Human Resources department.