The APEX Company has the mission to “Exceed customers’ expectations in providing consulting services of a superior value. ” To be successful in that mission, it is imperative that we are diligent in maintaining a good and solid reputation in every endeavor we undertake. Who we are and how we run our business is guided by our ethics program. The purpose of our ethics program is to identify, prevent and correct ethics issues. Our ethics program consists of our Code of Conduct, compliance auditing, two way communications between management and employees, improvement and re-current training on ethical behavior.
The policy set forth after this overview is expected to be adhered to by all employees from the CEO, down to the janitorial staff. All employees should become familiar with the ethics guidelines that follow this introduction. We are firm believers that the decisions we make today, determine our success for tomorrow. Sincerely, APEX Management B. Standards and Procedures APEX Code of Conduct •APEX management team welcomes concerns from employees and commit to open door policies for those ethical concerns •APEX employees are committed to ethical behavior and shall always act in the best interest of the client.
•APEX employees are committed to providing professional services with integrity. •APEX employees are committed to treating everyone fairly and respectfully. •APEX employees avoid the appearance of unethical or compromising practices. •APEX employees only accept only those assignments for which they have the qualifications, knowledge and skill in which to serve the client. •APEX employees disclose any conflict of interests and avoid conflicts of interest or the appearance of such.
• APEX employees do not accept simultaneous or competing assignments from two or more clients who have potentially conflicting interests without informing all parties in advance and securing all parties’ prior agreement. •APEX employees treat clients’ information as confidential and take all reasonable steps to prevent unauthorized access. •APEX employees do not use company assets or business relationships for personal use or personal gain. •APEX employees promote a trustworthy environment and support positive ethics within the company. C. Ethics Training Program
New Employee Training As part of the onboarding process, all new employees are trained in APEX’s ethics program; this includes an introduction into the corporate values and codes of conduct. Employees are instructed in identifying incidents of ethical behavior and the proper methods of reporting procedures of ethical violations. This is initial training is refreshed in ninety days and then the new hire is in the training cycle with the existing employees. Current Employee Training Existing employees are trained on a continuous basis on the expected ethical behavior of APEX employees.
This initial four hour classroom training is refreshed in quarterly sessions lasting one hour each and the four hour training is repeated annually. All training is conducted by the Ethics Officer D. Compliance Systems Monitor Supervisors are responsible for ensuring the adequate and efficient training for all subordinates. Signatures are obtained on the Verification of Training forms and are to be submitted to Human Resources for retention in the employee’s personnel folder. Employee misconduct will be monitored in by supervisory review of actions taken by employees, by conducting yearly surveys and also by implementing a reporting system.
In our monitoring, we will be reviewing compliance and targeting deviations to our established ethical behavior. When the method of surveys is utilized, they will be nameless and must be completed within the thirty day allotted time. One feature of our reporting system is the establishment of our APEX Ethics Hotline, (800) 555-5555. This line is monitored by the Ethics Office and is open to anyone, the public, employees and customers to anonymously report unethical behavior or to ask ethics questions.
With this system we are able to effectively monitor and evaluate unethical behavior and to take corrective action as required. The Ethics Officer compiles this data monthly and reports to the CEO with the trends and analysis. Audit APEX will conduct yearly audits to our Ethics program. This will determine if we are in compliance with our company’s ethics standards and will utilize the Six-Sigma model as a method of improving upon those standards. This type of model will allow APEX to spotlight areas that are outside of our goals.
Auditing employee misconduct is performed by tracking our hotline calls by the types of incident, number of occurrences, general ethics questions and confirmed noncompliance. The audit are performed by the Ethics Officer on an yearly basis as well as on the spot checks to ensure that all employees are properly orientated in the company’s code of conduct and are familiar with the channels available for reporting violations. Our objective auditing processes will report our compliance and noncompliance with our ethics program and determine whether or not APEX has reached its goals.
All of our internal findings will be verified by an external auditing firm, Wecheckem Auditors, LLC. Wecheckem will generate a report that will be furnished to the Ethics Committee for publishing on the company’s intranet. This third party company will use the results of this report, responses from customers, and the ratings of the surveys to audit the employees of APEX compliance with our Code of Conduct, the company’s officers compliance with our Code of Conduct, and to assess the company an overall score from 1, non-compliant, to 10, excellent, on our ethical program.
Reporting Misconduct It is imperative that employees of APEX feel comfortable with bringing any issues and concerns to management’s attention. Ethical issues occurring with the staff should be communicated immediately. It is important to note APEX has a zero tolerance policy and any infractions of this code of ethics will be met with quick and decisive action. Any employee found to have violated this policy may be subject to disciplinary action, up to and including termination of employment. Often times, a concern may arise or even a simple question concerning ethical conduct.
At those times, there are many different avenues whereby assistance can be sought. Some of those avenues are: •Management team •APEX Ethics Hotline (800) 555-5555 •Human Resources Department • The Ethics Officer: Mr. Idoo Wright Esq. Suite 746 1400 Independence Avenue Corpus Christi, TX 64009 E. Ethics Program Assessment Review The Ethics Officer is responsible forming the Ethics Committee and for the continual review of APEX Company ethics program. The Ethics Officer shall conduct verifications of training records; compile a database of all reports of ethical violations and the resultant investigations and findings of same.
The information gathered is then turned over to an outside firm specializing in Corporate Governance and Ethics for an independent review and assessment. Improvement The Ethics Officer and Ethics Committee shall review all ethical violations and in conjunction with the findings and recommendations of the outside audit firm,Wecheckem, LLC, to produce program improvements utilizing Lean Six Sigma methodologies. Standards and procedures shall be updated whenever there are improvements to the program.