“Doing the Right Thing or Nothing Else”
One of Ascentech’s key core values is that of doing things in an ethical manner. We have a zero tolerance policy for unethical behavior that is detrimental to the company, its employees, our partners and/or customers. This section elaborates on the standards expected from individuals or companies acting on behalf of Ascentech:
1. Code of Conduct
All personnel shall conduct themselves at all times in a manner that reflects the corporation’s high integrity and business ethics. The following standards of conduct are expected of Ascentech’s staff and Ascentech’s subcontractor’s personnel who interface with Ascentech’s vendors or suppliers:
- All potential or participating vendors or suppliers shall receive impartial, fair and equitable treatment;
- All contacts with vendors or suppliers shall be in strict conformity with ethical business practices so that the best interest of Ascentech and its customers are considered first in all transactions;
- When it is necessary to meet with vendors or suppliers, Ascentech personnel shall conduct themselves so as to avoid implications of impropriety;
- Ascentech personnel shall maintain a professional, businesslike and cordial relationship with suppliers and vendors;
- All supplier’s or vendor’s data is protected from disclosure to other suppliers and vendors; and
- Non-procurement personnel are not authorized to commit Ascentech to any procurement whatsoever unless allowed by the P-Card policy and authorization.
Ascentech is engaged in government contracts utilizing public funds. Therefore, Ascentech’s procurement actions must be completely impartial and unbiased. The conduct of all Procurement personnel must, at all times, be such that Ascentech will not be accused of exercising favoritism in the placement of its procurements.
- Procurement personnel shall not accept gifts, favors, entertainment, loans or anything of value in excess of $5.00 from a potential or current supplier/vendor because acceptance of such might create the impression of placing them under obligation to the supplier/vendor.
- Promotional materials such as pens, pencils, note pads, and calendars are not considered gifts or gratuities.
- Social activities with or sponsored by vendors or suppliers shall not be attended unless they are public in nature (i.e., open house).
- Employees shall comply with FAR 52.203-7 “Anti-Kickback Act of 1986”. Ascentech prohibits any employee from:
(a) Providing or attempting to provide or offering to provide any kickback;
(b) Soliciting, accepting, or attempting to accept any kickback; or
(c) Including, directly or indirectly, the amount of any kickback in the contract.
Rebates and discounts given to Ascentech are not considered to be kickbacks and are acceptable business practices.
It is Ascentech’s policy to maintain vendor’s’ or supplier’s’ proprietary data in strict confidence. It is the responsibility of the Procurement personnel, to maintain vendor’s’ or supplier’s’ proprietary data and to restrict access to Ascentech personnel on a “need to know” basis.
All vendor’s’ or supplier’s’ data concerning prices, costs, deliveries, discounts, promotions are considered to be proprietary to the vendor or supplier to whom they belong. After award, the price paid to the successful offeror, may be disclosed to the unsuccessful offeror(s) upon request. Any additional data may be considered proprietary provided that the vendor or supplier has labeled the data as such.
Restrictive legends or statements, which may create an additional burden on Ascentech, shall be reviewed with Corporate Contracts Manager to determine if the material should be accepted by Ascentech.
Exceptions to this policy shall be made only with the written consent and authorization of the supplier or vendor.
Any suspected Procurement Integrity Violation shall be reported immediately to Ascentech’s Compliance Officer at 713-219-4205.