The success of our business is dependent on the trust and confidence we earn from our employees, customers, and shareholders. We gain credibility by adhering to our commitments, displaying honesty and integrity, and reaching company goals solely through honorable conduct. It is easy to say what we must do, but the proof is in our actions.
The purpose of this policy is to ensure that all employees are aware of the ethical standards each is expected to maintain when conducting business for our Company.
This policy applies to employees, contractors, consultants, temporaries, and other workers at eBryIT, including all personnel affiliated with third parties.
4.1 Respect for the Individual
4.1.1 We all deserve to work in an environment where we are treated with dignity and respect. eBryIT is committed to creating such an environment because it brings out the full potential in each of us, which, in turn, contributes directly to our business success.
4.1.2 eBryIT is an equal opportunity employer and is committed to providing a workplace that is free of discrimination of all types and from abusive, offensive, or harassing behavior. Any employee who feels harassed, or discriminated against, should report the incident to his/her manager or to Human Resources.
4.2 Promoting Integrity
4.2.1 Commitment. eBryIT’s commitment to integrity begins with complying with laws, rules, and regulations where we do business. Further, each of us must understand the company policies, laws, rules, and regulations that apply to our specific roles. If employees are unsure of whether a contemplated action is permitted by law or eBryIT policy, advice should be sought from the resource expert. We are responsible for preventing violations of law and for speaking up if we see possible violations.
4.2.2 Competition. eBryIT is dedicated to ethical, fair, and vigorous competition. We will sell eBryIT products and services based on their merit, superior quality, functionality, and competitive pricing. We will make independent pricing and marketing decisions and will not improperly cooperate or coordinate our activities with competitors. We will not offer or solicit improper payments or gratuities in connection with the purchase of goods or services for eBryIT for the sales of its products or services, nor will we engage or assist in unlawful boycotts of particular customers.
4.2.3 Proprietary Information. It is important that employees respect the property rights of others. We will not acquire or seek to acquire by improper means of a competitor’s trade secrets or other proprietary or confidential information. We will not engage in unauthorized use, copying, distribution or alteration of software or other intellectual property.
4.2.4 Selective Disclosure. Employees will not selectively disclose (whether in one-on-one or small discussions, meetings, presentations, proposals or otherwise) any material nonpublic information with respect to eBryIT, its business operations, plans, financial condition, results of operations, or any development plan. Employees should be particularly vigilant when making presentations or proposals to customers to ensure that our presentations do not contain material nonpublic information.
4.3 Protection of Confidential Information
4.3.1 The protection of confidential information is vital to the interest and success of eBryIT. Information about our business, employees, clients, suppliers, and vendors is to be kept confidential and released only to individuals within the Company with a need to know and authorization to do so. If in doubt, act prudently and discuss with your supervisor.
4.3.2 All paper and digital records maintained by the Company are considered confidential and are the property of eBryIT. These records are not to be disclosed to any outside party without the express written permission of your immediate supervisor. Confidential information includes but is not limited to:
4.3.3 Except in performing your work, confidential information may not be removed from Company premises without express authorization. Confidential information obtained during or through employment with eBryIT may not be used by any employee for the purpose of furthering current or future outside employment or activities for personal gain or profit.
4.3.4 Upon employment separation, an employee is required to promptly return to his supervisor or Human Resources any and all Company documents containing confidential information.
4.4 Conflicts of Interest
4.4.1 As a Company, we must avoid any relationship or activity that might impair, or appear to impair, our ability to make objective and fair decisions when performing our jobs. At times, we may be faced with situations where the business actions we take on behalf of eBryIT may conflict with our own personal or family interests. We owe a duty to the Company to advance its legitimate interests when the opportunity arises. We must never use eBryIT property or information for personal gain or personally take for ourselves any opportunity that is discovered through our position with eBryIT.
4.4.2 Here are some ways in which conflicts of interest could arise:
4.4.3 It is also best to avoid the appearance of a conflict of interest. If in doubt, be prudent and contact Human Resources.
4.5 Protection of Company Assets
4.5.1 It is the responsibility of all eBryIT employees to protect Company assets including but not limited to the following:
4.5.2 eBryIT retains the exclusive right of ownership of all company assets in any form and designates management representatives as custodians of those assets to ensure information integrity. Use of eBryIT’s assets for other than company-related business is prohibited.
4.6 Accepting Business Courtesies
4.6.1 Consistent with complying with all laws and the principles of honesty and integrity, employees must refrain from activity or having any financial interest that is inconsistent with eBryIT’s best interest, including activities investments, or associations that compete with our Company, interferes with one’s judgment concerning eBryIT’s best interest, or exploits one’s position with our Company for personal gains. Therefore, situations that create, potentially create, or give the appearance of creating a conflict with eBryIT’s mission must be avoided.
4.6.2 It is the personal responsibility of every employee to ensure that acceptance of such token gifts, meals, refreshments, or entertainment is proper and could not reasonably be considered as an attempt to secure favorable treatment. If the gift could be construed as such, the employee must decline and notify their supervisor and Human Resources. If the gift is received and cannot be returned, the gift is to be given to Human Resources or a member of the Executive Team for donation to a charitable organization.
Employees are required to immediately disclose any financial holdings that may create a conflict of interest to their supervisor or Human Resources. Receipt of any gifts or gratuities should also be reported to the employee’s supervisor, Human Resources, or other management personnel.
4.6.4 Generally, employees may not accept compensation, honoraria, or money of any amount from entities with whom eBryIT does or may do business. Tangible gifts (including tickets to a sporting or entertainment event) that have a market value greater than $100 may not be accepted unless written approval is obtained from management. Employees with questions about accepting business courtesies should talk to their managers or Human Resources.
4.6.5 Employees may accept occasional meals, refreshments, entertainment, and similar business courtesies that are shared with the person who has offered to pay for the meal or entertainment, provided that:
4.7 Offering Business Courtesies
4.7.1 Any employee who offers a business courtesy must assure that it cannot reasonably be interpreted as an attempt to gain an unfair business advantage or otherwise reflect negatively upon eBryIT. An employee may never use personal funds or resources to do something that cannot be done with eBryIT resources. Accounting for business courtesies must be done in accordance with approved Company procedures.
4.7.2 Employees may provide non-monetary gifts (i.e., company logo apparel or similar promotional items) to our customers. Further, management may approve other courtesies, including meals, refreshments, or entertainment of reasonable value, provided that:
4.8 Accurately Report Results
4.8.1 We will make certain that all disclosures made in financial reports and public documents are full, fair, accurate, timely, and understandable. This obligation applies to all employees, including all financial executives, with any responsibility for the preparation for such reports, including drafting, reviewing, and signing / certifying the information. No business goal of any kind is ever an excuse for misrepresenting facts or falsifying records.
4.8.2 We create, retain, and dispose of our company records as part of our normal course of business in compliance with all eBryIT policies and guidelines, as well as all regulatory and legal requirements. All corporate records must be true, accurate and complete, and company data must be promptly and accurately entered in our books in accordance with eBryIT’s and other applicable accounting principles. We must not improperly influence, manipulate, or mislead any unauthorized audit, nor interfere with any auditor engaged to perform an internal independent audit of eBryIT books, records, processes, or internal controls.
4.8.3 Employees should inform Executive Management and Human Resources if they learn that information in any filing or public communication was untrue or misleading at the time it was made or if subsequent information would affect a similar future filing or public communication.
4.8.4 Violation of any of the eBryIT Code of Business Ethics policies can result in disciplinary action up to and including termination of employment.
4.9 Reporting
4.9.1 It is eBryIT’s top priority and every employee’s obligation to uphold the policies in this Code of Business Ethics. If you have any questions regarding the policies contained in this Code, contact Human Resources at 678-385-0400, option 3.
4.9.2 eBryIT’s employees must report any incidents of unlawful or unethical conduct, conflicts of interest, unsafe conditions, lack of proper security for information or property, or other conduct inconsistent with eBryIT policy. Reporting suspected violations of the eBryIT Code of Business Ethics will not adversely affect employment at the Company (i.e. employees will not be demoted, transferred, suspended, or terminated for reporting a violation). To foster a comfortable reporting environment, employees may report any violation or suspected violation directly in person, or anonymously using any of the following:
4.9.3 Employees are not required to confront the person/persons who have given you reason to report a conflict of interest. However, if a conflict of interest contrary to this policy is discovered, employees must make a reasonable effort to make known as soon as it is discovered. Discussing or reporting a potential conflict of interest to any person not listed above does not constitute a report.
5. Compliance
5.1 Compliance Measurement. The eBryIT team will verify compliance to this policy through various methods, including but not limited to, business tool reports, internal and external audits, and feedback to the policy owner.
5.2 Exceptions. Any exception to the policy must be approved by the eBryIT team in advance.
5.3 Non-Compliance. Anyone who violates the Company's rules for this policy may be subject to disciplinary action, up to and including termination of employment. The Company reserves the right to advise appropriate legal officials of any illegal violations.
