Ethics Policy

If you have questions or concerns about compliance with the subjects described in this policy, or are unsure about what is the “right thing” to do, we strongly encourage you to first talk with your supervisor, IOLT member or a Human Resource representative.  If you are uncomfortable talking to any of these individuals for any reason, call the Ethics Point Hotline at 1-866-870-0960 to report your concerns.  You may also log on to the following web site: www.ethicspoint.com

Your calls to the toll free hotline or contact through the Internet site are facilitated by a third party, Ethics Point, Inc.  Reporting of ethics violations will be treated as confidential information and can be communicated anonymously.

PCI’s Policy Relating To Ethics 
It is PCI’s policy that its employees will not offer, solicit or accept cash or other payments such as goods-in-kind, rebates or special privileges in return for an advantageous position, the establishment of a beneficial situation or for any other reason.  To offer or effect such payments, whether perceived to be in violation of law or not, will subject the employee to disciplinary action and could result in immediate discharge from PCI.  No payments are to be approved or made with the intention that any part is to be used for any purpose other than that described in the supporting documentation and in accordance with standard procedures.  No commission payments are to be authorized or made in excess of those required in the ordinary course of business.

PCI employees may accept reasonable gifts in such circumstances where gifts are a normal expression of courtesy or convention, and where it is obvious that the gift will not result in an expected reciprocal action, particularly as it relates to PCI business (programmatic matters, etc.).  It is not appropriate to give a gift to or receive a gift from a person within PCI with whom there is a manager/supervisor or subordinate relationship.  (An exception may be made in regard to items having a token value of approximately $25.00 (U.S.) dollars, under special circumstances or convention).  Any offering of a gift with a fair market value of $25.00 (U.S.) or more is to be reported to PCI’s CFO.  The offer of valuable gifts, even if not accepted, is to be reported to the employee’s immediate supervisor, and in turn, the Human Resource department who will advise the CFO.

Reasonable tips of $10.00 or less for actual services rendered to PCI can be given. (This usually relates to travel).  The use of PCI assets for any unlawful or improper activity is prohibited.  No unauthorized, unrecorded or undisclosed asset or procedure is to be established or maintained.  No false or otherwise modified entries are to be made in PCI books or other records for any reason; no employee shall engage in any arrangement that accomplishes the fore-mentioned.

Any employee who has reason to question, or who knows of any unrecorded assets, misconduct or/and prohibited act(s), is obligated to report such to the appropriate Department Head or manager/supervisor, the Controller, CFO or the appropriate Human Resource representative.  If you do not feel comfortable reporting to any of these individuals, please file a report through www.ethicspoint.com

Whistleblower Protection
PCI is committed to lawful and ethical behavior in all of its activities and requires that its directors, management, employees and consultants conduct themselves in a manner that complies with all applicable regulations and laws.  Employees with reasonable cause to believe the organization is in violation of – or in noncompliance with – a state or federal statute, rule, regulation or law; are encouraged to access a contracted, confidential investigative service either by a published 1-800 number or through web access.  PCI has contracted with this service to assist in resolving reported complaints and allegations concerning violations of Code of Ethics, Conflict of Interest, Harassment or suspected illegal activities in the most confidential manner possible. The contact information will be posted internally as well as on our website.  This service is in addition to your rights to contact a state or federal agency, should you so desire.  The contact information for these agencies are posted in the common areas of each of our offices.  Retaliation against any employee who discloses such information and/or refuses to participate in an activity that would result in a violation of state or federal statute, or a violation of or noncompliance with a state or federal rule or regulation, will not be permitted.

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