ETHICS POLICY

ETHICAL BUSINESS CONDUCT POLICY

This policy applies globally to all SQUAD employees, and members of the board of directors, agents, consultants, contract labor, and others when they are acting for, or on behalf of, SQUAD. Furthermore, we recognize the importance of extending our ethical standards beyond our immediate employees and board members. We expect our suppliers and business partners to align with our values and uphold similar ethical principles. By engaging in due diligence and selecting partners who share our commitment to integrity, we establish a network of trusted relationships that contribute to the overall ethical framework of SQUAD. Regular assessments and monitoring processes are in place to ensure that our partners maintain the same high standards of conduct.

ETHICAL BUSINESS CONDUCT POLICY

SQUAD maintains an ethics and compliance program that communicates its commitment to uncompromising integrity under corporate values and ensures compliance with all applicable laws, rules, and regulations. This program informs employees worldwide of SQUAD policies and management instructions concerning ethical business conduct and helps them to resolve questions and report suspected violations. The reporting process provides a confidential means of communication separate from line management. Retaliation against employees who come forward to raise concerns will not be tolerated. The Squad ethics and compliance program includes an education and awareness program to provide employees with job-specific compliance training and to raise their level of awareness and sensitivity to key issues. SQUAD will publish its Code of Conduct booklet in a variety of languages to enhance accessibility for the national population. All employees are required to participate in ethics awareness workshops annually and to complete compliance training as assigned. This policy, the SQUAD Code of Conduct booklet, and related policies and management instructions constitute SQUAD standards of conduct. Failure to comply with these standards may result in discipline, including termination.

RESPONSIBILITIES: CHIEF ETHICS AND COMPLIANCE OFFICER

  • Manages and maintains the SQUAD ethics and compliance program.
  • Ensures that appropriate policies, management instructions, and procedures are in place to help employees comply with SQUAD’s expectations for ethical business conduct.
  • Ensures the existence of an ethics and compliance education and awareness program in appropriate subject areas to provide employees with job-specific compliance training and raise their level of awareness and sensitivity to key issues.
  • Provides final and dispositive interpretation of SQUAD standards of conduct to resolve employee questions and confidential inquiries.
  • Represents SQUAD’s ethics and compliance program outside the company through outreach to external stakeholders.
  • Delegates to a network of business-based ethics and compliance officers as appropriate.Represents SQUAD’s ethics and compliance program outside the company through outreach to external stakeholders.
  • Collaborates with cross-functional teams and key stakeholders to continuously enhance and update the ethics and compliance program, adapting to emerging industry standards and regulatory requirements.

All SQUAD EMPLOYEES

  • Comply with SQUAD standards of conduct and, in so doing, reject any plan, transaction, or arrangement involving unlawful or unethical conduct or the appearance of impropriety.
  • Participate in ethics awareness workshops annually and complete compliance training as assigned.
  • Raise questions if the employee is concerned that the standards of conduct are not being met.
  • Avoid any arrangement, agreement, investment, employment, relationship, or activity that is or appears to be contrary to the best interests of SQUAD or its clients or might in any way impair the objective performance of duties or the exercise of independent judgment or action concerning SQUAD or its clients’ interests.
  • Seek guidance from the employee’s supervisor or other management, business organization ethics and compliance officer, Human Resources, the Legal Department, or the Ethics HelpLine if the employee has questions or concerns about compliance with the SQUAD standards of conduct.
  • Inform the employee’s supervisor or other management, organization’s ethics and compliance officer, or the Ethics HelpLine if the employee is aware of any incidents or situations concerning potential unethical conduct or conflicts of interest.

SQUAD SUPERVISORSS AND MANAGERS

  • Ensure that employees understand and comply with this policy.
  • Support implementation of the ethics and compliance program and monitor compliance with the company’s standards of conduct.
  • Ensure that employees participate in ethics awareness workshops annually and complete compliance training as assigned.
  • Create an open and honest environment in which employees feel comfortable in bringing issues forward. Advise others within the organization if employees raise standards of conduct concerns to ensure that any ethics and compliance issues and incidents are brought to the attention of responsible management.
  • Regularly assess and evaluate the effectiveness of the ethics and compliance program, implementing improvements as necessary to maintain a robust and proactive approach to ethical business practices.

SQUAD BUSINESS ORGANIZATIONS

  • Ensure that each new employee (excluding field manual employees) acknowledges having read this policy and SQUAD’s Code of Conduct booklet.
  • Notify the appropriate SQUAD counsel and the Chief Ethics and Compliance Officer whenever there is reason to believe this policy may have been violated.
  • Consult the Legal Department whenever there is any question as to the legal implication or consequence of a given course of action.
  • Provide a prompt report whenever SQUAD knows or is informed by a reliable source that a client, supplier, subcontractor, or other participant (including a SQUAD employee) in a SQUAD project is acting illegally or unethically.
  • Implement and reinforce the importance of the ethics and compliance program.
  • Regularly review and update the policies and procedures related to business organizations to ensure alignment with evolving legal and regulatory requirements.

IMPLEMENTATION

If there is uncertainty about these standards or guidelines, or if a situation involves unusual or special circumstances, these matters should be submitted to responsible management within the organization for interpretation in consultation with the Chief Ethics and Compliance Officer.

The Chief Ethics and Compliance Officer is responsible for providing policy guidance and issuing management instructions to assist employees in complying with SQUAD’s expectations for ethical business conduct. Internal Audit, Legal, and other SQUAD offices may also issue Management Instructions necessary to implement this policy. SQUAD offices may, at their discretion, implement this policy further through internal instructions.