Our Responsibilities to Our Customers and Business Partners
Quality of Products and Services
BWXT is committed to providing our customers and business partners with the right products and services, safely, the first time, within budget, with no ethical violations.
In order to meet these goals, it’s important that we identify all requirements before work starts and that we communicate them to all concerned.
As a consequence of our commitment to providing value to our customers in a responsible way, we also hold our external business partners accountable for complying with our high standards of quality.
If at any time you are not sure what the production requirements are, ask your manager or supervisor for clarification before continuing the work.
We Should:
- Understand our customers’ needs and be committed to meeting their requirements.
- Address and report any quality issues and concerns.
- Management is responsible and accountable for showing its commitment to quality and for providing the necessary resources to meet the agreed requirements.
- Line supervisors are responsible and accountable for the work performed by their direct reports and to ensure that quality requirements are made known and followed.
- Always complete reports and documentation fully and honestly, and never falsify or misrepresent test results.
- Never perform tasks for which you are not qualified.
If at any time you are not sure what the production requirements are, ask your manager or supervisor for clarification before continuing the work.
Integrity in Business Relationships
We will only do business with third parties that conduct business ethically and do not subject the Company to criminal or other liability or cause BWXT reputational harm.
All third parties must agree to comply with business practices reflected in our Code and applicable policies. Conducting due diligence minimizes BWXT’s risk by helping to avoid relationships that may implicate BWXT through the misconduct of its business partners. Accordingly, we always conduct due diligence on third parties to ensure that their reputation, background and abilities are appropriate and meet our ethical standards.
- No employees should contractually bind BWXT to another party until such party has been through the appropriate due diligence and approval procedures.
- Do not conduct business with a supplier, business partner or other third party that may subject BWXT to criminal or other liability or cause reputational harm.
- Be cautious of any suspicious activity involving the conduct of the company’s sales representatives or agents.
- Strictly follow BWXT policies and procedures in dealings with third parties.
- If you are a manager, ensure that the BWXT’s standards and expectations are understood and agreed to prior to entering into any contractual relationship.
- Never do anything through another party acting on our behalf that we are not allowed to do ourselves.
- Ensure that any commission or fees paid to a third party are reasonable and consistent with sound ethical principles and applicable laws.
When engaging in procurement activities:
- Create and maintain all records accurately to document the procurement process and to substantiate procurement decisions.
- Use merit alone as the standard for procurement decisions. Be careful to avoid conflicts of interest between the Company and any third parties.
- Do not divulge procurement information to anyone outside the Company or to persons inside the Company who do not have a “need to know.”
- Contact the Chief Compliance Officer if you become aware of any unethical business conduct by a BWXT supplier or provider of services.
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.
Contracting with the Government
We deliver quality products and services to our customers at fair and reasonable
prices, regardless of whether the customer is government or commercial.
However, because the laws and regulations for contracting with government entities differ from those for commercial transactions, we have additional policies to follow when dealing with government customers to ensure that we conform to all legal and regulatory requirements.
The laws, rules and regulations for contracting with government entities are detailed and complex, and violating them may result in criminal penalties as well as Company disciplinary action, including dismissal. Employees who deal with government contracting should familiarize themselves with and comply with the various limits and requirements that are imposed by the applicable government-customer entity, as laws and regulations between various agencies and levels of government differ.
- If you are involved in contracting with government entities, be familiar with and conform to all applicable laws and regulations. Ignorance is no excuse for violating the law.
- Take special care to ensure accuracy in all communications with federal, state and local governments. False, inaccurate or misleading communications are criminal violations of law.
- Unless authorized by the appropriate government official, never accept data from any source if there is reason to believe the data relates to national security, is classified or is sensitive or proprietary.
- If you have any questions concerning government contracting, consult with the Legal department or the Chief Compliance Officer.
Conflicts of Interest and Corporate Opportunities
A conflict of interest occurs when your actions or your private interest interferes in any way – or even appears to interfere – with the interests of the Company. Conflicts of interest expose our personal judgment and that of BWXT to increased scrutiny and criticism and can undermine our credibility and the trust that others place in us.
We have a fundamental obligation to make sound business decisions in the best interests of the Company, independent of our personal interests. We must not take personal advantage of opportunities for BWXT that are discovered as a result of our position with BWXT or use of Company property or information.
In addition, we must not use our position with BWXT or Company property or information for personal gain to compete with BWXT. Conflicts of interest can arise through outside employment interests, financial participation in an outside business, customer and supplier relations, and through excessive or inappropriate gifts and entertainment. Because it is impossible to describe every potential conflict, each of us must exercise sound judgment, seek advice when needed and adhere to the highest standards of ethics and integrity.
If you become aware of an actual, potential or perceived conflict of interest, immediately disclose the situation to your supervisor or the Chief Compliance Officer.
In addition, keep in mind the following:
- Avoid being compromised and avoid even the appearance of conflicts of interest.
- When in doubt, disclose.
- Always make business decisions in the best interest of BWXT.
- Remain aware of how personal activities can lead to potential conflicts, such as accepting gifts or entertainment from a supplier.
- Never use your position at BWXT or company property or information you have gained through your work for personal gain.
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.
Conflicts of Interest - Warning Signs
For practical purposes, the Company cannot and does not distinguish between an actual conflict of interest and the appearance of one. Remember – all employees as well as anyone acting on behalf of the Company must make business decisions based only on the best interest of BWXT.
- Avoid situations where you might be involved in hiring or supervising any close relative.
- Relatives of current employees may be hired only if they will not be working directly for or supervising a relative or will not occupy a position with authority to affect decisions involving any direct benefit to the relative.
- Don’t allow your personal relationships with contractors and suppliers to inappropriately influence business decisions.
- Don’t give or accept gifts or hospitality without prior approval that might place you under an obligation– or might appear to do so.
Gifts and Entertainment
Strong relationships with our business partners are vital to our business, but giving gifts to and receiving them from business partners or customers can potentially affect the independence of our judgment and that of our customers, and may create the appearance of favoritism.
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.
You must avoid even the perception that giving or receiving gifts or entertainment is connected in any way with favorable treatment. Even if there is no intent to gain inappropriate influence or advantage, inappropriate gifts may cause embarrassment to the Company and damage our reputation.
For these reasons, employees must not receive, solicit, offer or give inappropriate gifts or entertainment that may influence, or be perceived to influence, the recipient’s integrity or independence.
Because there are special rules and restrictions regarding U.S. government personnel and non-U.S. government officials, employees must consult with the Chief Compliance Officer, as well as the Legal department, before giving any type of gift or entertainment to a government representative.
We recognize there will be times when a current or potential business associate may extend an invitation to attend a social event or participate in trips in order to further develop your business relationship.
As a general rule, such offers should also meet the following criteria:
- Be in accordance with applicable laws and acceptable good business practices.
- Be modest and infrequent.
- Be acceptable under the policies of the company employing the other party.
- Employees shall not accept gifts (whether in the form of cash, services, or any other nature) from a customer, client, supplier or other business, other than an ordinary social amenity.
If you receive an unsolicited gift of more than nominal value, you should return it with a note explaining the Company policy. If you are in doubt as to whether the gift or entertainment is acceptable, seek guidance and approval from your supervisor or the Chief Compliance Officer.
Some examples of gifts and entertainment that are generally prohibited are:
- Payments of cash or cash equivalent (gift cards)
- Invitations to lavish dinners or other forms of entertainment
- Extravagant forms of hospitality, such as luxury resorts or expensive trips
- Paying travel expenses if the trips have no direct connection to a business purpose
- Gifts or entertainment to spouses or family members without prior approval
- Anything which would, if publicly disclosed, embarrass the Company
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.
Protection of Company Assets
BWXT’s assets – both physical and intellectual – are highly valuable and are intended for use only to advance business purposes and goals. We are personally responsible for safeguarding these assets, the assets of others, and for using all assets and resources appropriately.
All physical property including facilities, computers, other equipment and supplies, must be protected from misuse, damage, theft or other improper handling and only used for its intended purpose. This protection extends to laptops, smart phones, USB/external storage media, digital cameras and other portable devices that offer convenient and easy access to information, whether you take work home or across the globe. We must be vigilant in protecting our Company’s systems and information from potential hackers and other parties who may attempt to access data.
- All employees should protect the Company’s assets and ensure their efficient use for legitimate Company business purposes. BWXT does allow the occasional personal use of the Company’s communication and information systems provided that the use does not represent a conflict of interest, or does not include pornographic, defamatory or other inappropriate material.
- Employees and those who represent BWXT are trusted to behave responsibly and use good judgment to conserve company resources. Managers are responsible for the resources assigned to their departments and are empowered to resolve issues concerning their proper use.
- Be vigilant regarding access to our assets by others.
Access to Company intellectual or physical assets (including offices, plants and equipment) by any third party must be limited to and directly associated with services provided by the third party to the Company.
- Keep devices in your possession at all times and protect your passwords.
- Be sure to back up data.
- Do not download software/apps to company devices unless approved by BWXT’s Information Technology (IT) department.
- Immediately report if a device is lost or stolen to IT so that appropriate steps can be taken and the company’s information assets protected.
- Notify the Legal department of any inventions made during or as a result of employment by the Company.
- Comply with specific restrictions placed on the use and/or transfer of Company assets.
- Avoid the unauthorized receipt of proprietary information from others. Do not disclose to the Company or use for BWXT’s business any confidential information in your possession as a result of prior employment with another company.
Proper Use of Information Systems
Our computers, email, networks and communications systems are Company property and are intended for business purposes only. Occasional, incidental, appropriate personal use of our systems, email and phones are permitted if it does not interfere with the performance of your work.
- Generally, you should not use company equipment in the conduct of an outside business or in support of any religious, political or other outside activity, except for company-requested support of non-profit organizations.
- Sending unsolicited bulk email, chain letters or joke emails from a Company email account is prohibited.
- Downloading or sending sexually inappropriate or pornographic material using a company computer or on Company time is explicitly prohibited.
- The email system should not be used for personal commercial purposes or any illegal purposes, or for the creation or distribution of any disruptive or offensive messages.
- In order to protect the interests of the BWXT network and our fellow employees, we reserve the right to monitor or review all data and information contained on an employee’s Company-issued computer or electronic device, the use of the Internet or the Company’s intranet.
Confidential and Proprietary Information
Disclosure of Company confidential or proprietary information can put the Company at a competitive disadvantage or could hurt or embarrass employees, customers, the Company or ventures in which it participates. This section does not apply to the terms Confidential Restricted Data (CRD) or Confidential National Security Information (CNSI), as applicable sites have their own requirements governing these restrictions. Each confidential reference here applies to Company or personal information only.
Not only must you avoid disclosure, but you must also take all necessary steps to prevent others from illegally obtaining confidential and proprietary information. Confidential and proprietary information includes such things as pricing and financial data, customer names and addresses, trade secrets, patent applications, processes, and formulae, and also non-public information about other companies, including current or potential suppliers, vendors and other third parties.
The protection of the personal information of our co-workers is also vital to our continued success and the maintenance of our reputation. Information such as addresses, home phone numbers, salary or medical information, and performance appraisals are private. We also respect the confidential and proprietary information of third parties, and we do not engage in unethical or illegal means to obtain confidential information or proprietary data belonging to others.
- Know what constitutes proprietary information, especially as it relates to your job responsibilities. All employees are required to sign a Confidentiality Agreement upon joining the Company. Ask questions if you are uncertain about what’s covered.
- Do not post confidential Company information on internet message boards or social networking sites.
- Private information about our co-workers should never be shared with anyone who does not have an appropriate business reason for receiving it.
- Do not disclose to Company personnel or use for the Company’s business any confidential information in your possession as a result of prior employment with another company.
- Avoid the unauthorized receipt of proprietary information from others. Should you receive unauthorized proprietary information, notify the Legal department or the Chief Compliance Officer immediately.
- Never solicit confidential information from a third party.
To help protect our sensitive and confidential information:
- Never send confidential information to unattended fax machines or printers.
- Never discuss confidential information loudly or openly when others might be able to hear.
- Never share BWXT’s proprietary information with customers or suppliers without proper approval.
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
We create documents and records in the normal course of business to assist in our decision-making process and to document our compliance with laws, regulations, and Company policies and procedures. All entries in the Company’s books, records and accounts must be complete, accurate and fairly reflect our business transactions conforming to applicable accounting standards and legal requirements. This pertains to all books, records and information in any medium, including hard copies, electronic records, emails, video, backup tapes and other media. Whatever your part in this process, you are required to be honest and forthcoming – if you believe a transaction or payment cannot be accurately documented without raising legal questions or embarrassing the Company, the transaction should not be completed and you should notify your supervisor.
We must not improperly influence, manipulate or mislead any authorized audit, nor interfere with any auditor engaged to perform an internal independent audit of BWXT books, records, processes or internal controls. Essential information used for reporting, auditing and other critical purposes must be retained in a recoverable format and must be managed securely throughout the information’s life cycle.
No business goal of any kind is ever an excuse for misrepresenting facts or falsifying records. It is never acceptable to create false or misleading records or otherwise conceal the truth from BWXT’s management, auditors or regulators.
- Always classify, store and preserve records so that they are safe and protected.
- Dispose of books and records only in accordance with our policies.
- Don’t create or use hidden cash or bank accounts for any purpose. Except for normal and customary petty cash funds, which are strictly controlled, cash transactions are not allowed.
- If you become aware of litigation, investigations or audits, suspend all record destruction.
- If you change jobs or leave BWXT, be sure to properly transfer custody of all relevant books and records.
- If you approve reports and/or documents created by others, read them carefully and satisfy yourself that they are complete and accurate. Your signature is important – make sure you fully understand the implications before signing a document.
- If you are asked by any outside person, group or agency to provide access to records or documents maintained by the Company, you must first discuss the request with the Legal department or the Chief Compliance Officer.
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
Today, businesses are under intense scrutiny from the press and the public, and there are an unprecedented number of outlets for business information and news. In this environment, it is important that only authorized persons speak on behalf of BWXT. We need a clear consistent voice when providing information to investors, analysts, the media and the general public. Unless you are authorized by the Communications or Investor Relations department, never give the impression that you are speaking on behalf of the Company, either verbally, written or electronically.
Care should be taken when talking with journalists or writing communications that might be published. If you participate in online forums, blogs, newsgroups, chatrooms or bulletin boards, never give the impression that you are speaking on behalf of BWXT and, before you hit the ‘send’ button, think carefully. Never send emails or post confidential information or material that could be perceived as damaging to the Company’s reputation.
For additional guidance, please consult the Company’s policy on Social Media Usage.
- Never respond to media inquiries or initiate contact with the media, unless specifically authorized to do so by the Communications department.
- Be alert to situations in which you may be perceived to be representing or speaking on behalf of the Company.
Presentations and speeches that become public should be reviewed by the BWXT Communications department and your group Legal department, as appropriate.
- In situations where you may be sharing information about our government operations, be sure to obtain the appropriate customer approval and consult with the BWXT Communications department prior to the public release of information. Failure to follow these strict guidelines may damage our contracts.
- Refer all inquiries from the media, financial analysts and investors to BWXT’s Corporate Investor Relations or Communications department. Regulatory or governmental inquiries should be referred to the General Counsel or your respective Group attorney.
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
We encourage employees to participate in the political process, and to support charitable causes, always keeping in mind that your political and charitable activities are a personal matter. BWXT employees who wish to make contributions to political parties, candidates or campaigns for public office or make donations to charities must do so in their own name, on their own behalf, and not as representatives of the Company.
The Company has legally established a BWXT Political Action Committee (PAC). You may wish to contribute to the PAC, but your participation is voluntary. Charitable and other contributions on behalf of BWXT must be approved in advance in accordance with the Contributions and Company Memberships Policy.
- Never put pressure on a colleague to participate in a political cause or to make a charitable contribution. If you experience such pressure, especially from a supervisor, report it.
- Do not solicit contributions or distribute non-work related materials during work hours.
- You must never make a political or charitable contribution with the intent to improperly influence someone.
- All political and charitable contributions made on behalf of the Company must be accurately recorded in the Company’s books and records.
No. Even if your supervisor is not pressuring you, the request is inappropriate and coercive.