HILL BROTHERS
CONSTRUCTION CO., INC
STATEMENT OF
POLICY
It is Hill Brothers Construction Co., Inc.’s policy to
maintain the highest ethical standards and comply with all applicable laws and
regulations of the United States, federal, state and local where HBCC transacts
business. We believe that
adherence to this policy will ensure our continued success and in order to
maintain our commitment to integrity, we have established this Code of Ethical
Conduct. As an employee, you are expected to read both the Code and the Program
and fully comply with them. Integrity is your personal responsibility. An employee who becomes aware of any unethical or illegal
act of the company or any of its employees must report that violation immediately
to the CEO, Project Manager, or the Corporate Ethics Officer.
- All
employees must comply with this Code of Conduct. Any officer, manager,
supervisor or employee violating this Code is subject to discipline, which
may include discharge.
- Employees
in management positions are personally accountable for their own conduct
and the conduct of those reporting to them. Each manager is expected to
inform those reporting to him or her about the Code of Conduct and make
certain compliance is maintained with this Code.
- All
employees have a duty to report all suspected violations of the Code or
other unethical behavior by anyone, whether it be officer, managers,
supervisors, employees, prime contractors, subcontractors, suppliers,
vendors, customers to the Corporate Ethics Officer.
- No
employee has the authority to direct, participate in, approve, or tolerate
any violation of the Code.
- Any
employee who has questions about this Code should consult with the
Corporate Ethics Officer.
CORPORATE
COMPLIANCE PROGRAM
Equal Employment Opportunity:
This policy extends to all phases of employment, including
hiring, placement, promotion, transfer, compensation, benefits and
training. Hill Brothers
Construction Co., Inc. is committed to maintaining a work environment that is
free of discrimination, harassment, intimidation or coercion related to race,
color, religion, sex, age, national origin, disability. Hill Brothers Construction Co., Inc.
promotes a work environment in which everyone is treated with respect, trust,
honesty, and dignity. (See - Hill
Brothers Construction Co., Inc. - Respectful Workplace Policy)
Physical Violence:
All Hill Brothers Construction Co., Inc.’s employees are
expected to act in a professional manner with business associates, employees,
and the public. At no time would
it be appropriate to threaten or to use physical violence against another
person.
Threats or physical violence with an employee, supplier,
subcontractor or any individual on Hill Brothers Construction Co., Inc. job sites
should be reported immediately to the employee’s supervisor.
Safety and Health:
Hill Brothers Construction Co., Inc. considers employee and
customer’s safety and health as the highest priority. Each employee must be aware of HBCC’s safety program that
incorporates health and safety procedures. Supervisors and employees are responsible for ensuring that
all reasonable safeguards and precautions are taken in the workplace including
strict adherence to Hill Brothers Construction Co., Inc.’s procedures and
guidelines, promoting safe work practices. And no work should be conducted at
any time without the use of personal and appropriate protective safety
equipment.
If any employee has any safety related concerns, he or she
should report these to their immediate supervisor or to Hill Brothers
Construction Co., Inc.’s Safety Compliance Officer, Benton Elliott. Violation of safety rules could result
in employee discipline, including discharge.
Environmental Compliance:
Hill Brothers Construction Co., Inc. is completely committed
to being in full compliance to protecting the environment with all federal,
state and local environmental laws. It is an important part of our obligation to the communities, in which we
work and to our reputation. Hill Brothers Construction Co., Inc. takes
environmental policy violations very seriously. It is essential that HBCC provides each employee a safe and
healthy environment in which to work; each employee involved with regulated air
emissions, water discharges, hazardous materials or other pollutants must
follow safety and health rules as well as environmental procedures.
No one at Hill Brothers Construction Co., Inc. may
participate in concealing an improper discharge, disposal, or storage of
hazardous materials or pollutants.
Hill Brothers Construction Co., Inc. is committed to using
energy and materials in a manner that will not impact the environment. HBCC will also strive to use recycled
materials when possible.
Any person who has reason to believe that there has been
violation or suspected violation of HBCC environmental policy or procedures
(may be reported anonymously without fear of retaliation) to the CEO, the
Corporate Safety Officer or the Corporate Ethics Officer.
Drugs and Alcohol:
Hill Brothers Construction Co., Inc. is firmly committed to
providing its employees with a safe and productive workplace. HBCC expects all employees to report to
work and be able to perform his or her duties safely and productively. Drug and alcohol abuse by employees
will not be tolerated and HBCC will take the appropriate measures to ensure
compliance of the drug and alcohol abuse policy. Any person discovered using
alcohol or drugs in the workplace would be subject to discipline, including
termination. (See - Hill Brothers Construction Co., Inc. Drug and Alcohol
Policy)
Conflicts of Interests:
Employees must avoid situations in which their personal
interests could conflict with or even appear to conflict with the interests of
Hill Brothers Construction Co., Inc. Conflicts of interests occur when an individual’s position or
responsibilities with Hill Brothers Construction Co., Inc. present an
opportunity for personal gain or profit separate from the individual’s earnings
(from Hill Brothers Construction Co., Inc.) are inconsistent with the interests
of the company. A conflict of
interest may occur in different situations, if you think that any situation is
a potential conflict of interest, you should consult with the CEO, or the Corporate
Ethics Officer. The following
lists describe situations that have a great potential for conflicts of
interests.
- Personal
Financial Interests:
Employees should avoid personal
financial interests that might be in conflict with the interests of Hill
Brothers Construction Co., Inc. Such would be: Obtaining financial or beneficial interest from a
supplier, customer or competitor of HBCC.
Such personal financial interests
include those of the employee’s spouse, children, parents, grandparents,
siblings, and all in-laws. If an employee knows that personal financial
interest may be in conflict with Hill Brothers Construction Co., Inc., the
employee must speak with the CEO or the Corporate Ethics Officer to obtain
written approval.
Gifts and Entertainment:
Bribery and Kickbacks
All forms of
bribery and kickbacks are illegal and prohibited by Hill Brothers Construction
Co., Inc. Any employee discovered participating in such activity will be
promptly terminated. Any employee
who knows or reasonably should know about such activity and does not report it
to the CEO or the Corporate Ethics Officer will be disciplined which might
include termination of employment.
Government
Personnel:
Any form of
gifts and entertainment to or from government personnel whether it is Federal,
State or local or individuals acting on behalf of the government are strictly
prohibited. The CEO or the Corporate Ethics Officer may authorize an exception
where a family or personal relationship exists outside the employee’s business
relationship with the government employee.
Non-Government
Personnel:
Accepting
gifts in business areas can be inappropriate, or illegal depending on the
Circumstances. It is extremely important that all
employees be careful when giving or receiving gifts from non-government
personnel.
Accurate Records, Books and
Communications:
All Hill
Brothers Construction Co., Inc. and company employee communication,
correspondence, or records must be accurate, timely and complete. If an
employee discovers that he or she has made an error, the employee must take
steps to correct mistake(s). All
disbursements of funds and all receipts must be promptly recorded. No undisclosed funds may be established
for any purpose. Any employee who
knowingly makes a false or miscommunication or misleading correspondence or
record will be discharged from employment.
Company Resources:
To maintain the protection and
proper use of Hill Brothers Construction Co., Inc. assets, each employee should
ensure that any personal use of the company resources including telephones, fax
machines, copiers and office equipment, whether or not for personal gain, for
any unlawful or improper purpose is strictly prohibited.
Competitors and Antitrust:
Hill Brothers
Construction Co., Inc. is committed to full compliance with the antitrust laws,
which were created to promote free and open competition on a fair and level
business field. It is essential
that every employee be aware of the antitrust laws and that all employees who
are involved in the bidding process participate in Hill Brothers Construction
Co., Inc. Antitrust Program.
The antitrust
laws are very complex and violation of antitrust laws is a felony and could
result in criminal prosecution of the company and the employee with huge fines,
imprisonment and disbarment. Also
collusion among competitors may constitute violations of mail or wire
fraud. Any officer, manager,
supervisor or employee who discovers that a violation of this policy has
occurred must report immediately to the CEO or the Corporate Ethics Officer.
In addition, United States Laws prohibit
competitors from fixing prices (bid-rigging) or inflating prices on federal
contracts. No employee will in any
manner violate these laws or suggest to a competitor that Hill Brothers
Construction Co., Inc. would be involved in such violations.
Hill Brothers
Construction Co., Inc. employees must avoid deceptive behavior through
misrepresentation of facts, manipulation of unfair advantage in the conduct of
business affairs. This applies to
relationships with Hill Brothers Construction Co., Inc.’s subcontractors and
suppliers.
Fraud Policy:
Hill Brothers Construction Co.,
Inc. will not tolerate fraud. Fraud is a deliberate deception of
misrepresentation made for personal gain. Employees should report fraud immediately to the CEO, VP and the
Corporate Ethics Officers. Employees will not be discriminated against for
raising concerns. An investigation and internal audit will immediately be
preformed.
Hill Brothers Construction Co.,
Inc. has established a help line for individuals to report fraud or other
violations. The caller may remain
anonymous and report their suspicion of fraud without fear of retaliation. In
addition a Fraud hotline Poster will be posted on Hill Brothers Construction
Co., Inc.’s website.
Disadvantaged Business Enterprises:
Hill Brothers Construction Co., Inc. is fully committed to
comply with government-sponsored opportunity programs, such as the disadvantage
business enterprise (DBE) program. Hill Brothers Construction Co., Inc. will not discriminate on the basis
of race, color, national origin, sex or disabilities in the hiring of
subcontractors or suppliers. Hill Brothers Construction Co., Inc. will maintain
an environment in which everyone will be treated with respect, trust honesty,
fairness and dignity. In every
government contract Hill Brothers Construction Co., Inc. will make good faith
efforts to ensure that each DBE’s participation in subcontracts is executing
the work and carrying out their responsibilities by managing and supervising
the work.
VIOLATIONS:
Employees should report immediately any violations of this
Code or the Program or any
Violations of
law to the CEO or the Corporate Ethics Officer. Hill Brothers Construction Co., Inc. will encourage
reporting of suspected violation of this Code. Employees reporting real concerns and complaints will not
suffer retaliation as a result of reporting an issue. Any employee involved in a violation of the Code, the
Program or other Hill Brothers Construction Co., Inc.’s policy may be subject
to disciplinary action, up to and including termination that is found unethical
or illegal.
Any report made under this section will be strictly
confidential and under no circumstances will any employee who makes a report be
subjected to any act of retaliation or disciplinary action. Additionally, all employees must fully
cooperate in any investigation of a suspected violation of the Code and fully
cooperate with any request by the Corporate Ethic Officer.
Any employee found to have violated this Code or engaged in
other unlawful or unethical behavior will be disciplined, including demotion or
discharge. Any employee who fails
to report known or suspected violations of the Code or other unlawful or
unethical behavior will be subject to appropriate disciplinary action, which
may result in any of the following consequences:
- Reprimand
- Loss
of compensation
- Reduction
in pay
- Demotion
- Suspension
with or without pay
- Discharge
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