Ethics Program for Vencill Management Consulting

It is the responsibility of each and every Vencill Management Consulting employee to understand and demonstrate integrity in the work that is done every day. How employees work within the ethical framework of various and diverse professional fields is also important. To this end, Vencill Management Consulting has adopted the following professional Code of Conduct and procedures related to interactions with our clients in the non-profit sector. In addition to employees, Vencill Management Consulting’s Code of Conduct extends to its contractors, agents and suppliers. Standards and Procedures

Vencill Management Consulting employees are responsible for the integrity of their own work. Vencill Management Consulting’s policies and procedures provide additional, more specific guidance. Each employee must acknowledge receipt of Vencill Management Consulting’s Code of Conduct and confirm that they will follow the standards. In addition, employees are asked to confirm that they understand and comply with these standards. This measures the implementation of Vencill Management Consulting’s Code and how well the value of integrity is integrated into the culture at Vencill Management Consulting. It ensures that Vencill Management Consulting’s Code of Conduct is being applied uniformly and provides a channel for employees to raise issues.

Since Vencill Management Consulting’s Code of Conduct and the supporting policies and procedures may change from time to time, Vencill Management Consulting employees are responsible for knowing and complying with the current laws, rules, regulations, standards, policies and procedures that govern their work. Vencill Management Consulting’s employees are also individually responsible for reporting wrongdoing. If a law or company policy has been broken, employees are required to report it promptly. If a Vencill Management Consulting employee fails to comply with applicable laws, rules, regulations, standards, policies and procedures, he or she risks being disciplined or terminated. If a Vencill Management Consulting employee breaks the law, they also may be personally liable. Vencill Management Consulting’s management team is responsible for maintaining an ethical climate by: Explaining to their employees why it’s important to comply with the Code of Conduct. Encouraging discussion of the Code and situations.

Responding promptly and properly to concerns raised by employees. Protecting employees against reprisals when they report, in good faith, actions they feel violate the law or these standards. Vencill Management Consulting’s management team is responsible for reviewing and evaluating the company’s policies and practices to ensure that they are consistent with Vencill Management Consulting’s social responsibility to act with integrity to employees, customers and society. As part of that responsibility, the management team oversees Vencill Management Consulting’s Code of Conduct.

Vencill Management Consulting’s management team is responsible for the coordination, oversight and enforcement of Vencill Management Consulting’s compliance programs and activities and helps to promote an organizational culture that encourages compliance with laws and regulations and ethical conduct for all Vencill Management Consulting employees. Also, the the management team is responsible for communicating Vencill Management Consulting’s ethics and compliance standards, providing guidance and training to employees and maintaining multiple channels for employees to report concerns and monitoring compliance. Ethics Training Program

Vencill Management Consulting’s Code of Conduct requires compliance with laws, regulations and internal policies that govern how the company works. All employees must complete the company’s Code of Conduct awareness training. In order to reinforce the company’s standards and help employees understand the policies and regulations, Vencill Management Consulting continues to offer compliance training for employees across a variety of topics. We focus our attention on key risk areas that we are likely to confront in light of our business activities and the markets in which we operate. This allows us to tailor our compliance program to our unique risk profile. Our primary risk areas include: Discrimination Environmental Harassment Medical Political activity/lobbying | Privacy and data protection Services provided to military/government Trade secrets Worker health and safety

With our suppliers, Vencill Management Consulting performs targeted risk assessments. Our evaluations examine their documented labor and ethics practices and programs. Compliance training enables employees to perform with integrity by understanding the legal and regulatory implications of their actions. Vencill Management Consulting provides risk-specific training to appropriate employees, reinforced with guidance from compliance staff and resource guides to ensure compliance. Monitoring and Compliance

Vencill Management Consulting strives to develop a culture that produces conscientious and ethically-minded employees who are committed to integrity, honesty, openness and fairness. If Vencill Management Consulting is to be successful, employees need to allow team members to be able to openly communicate and ask questions regarding Vencill Management Consulting’s Code of Conduct. Vencill Management Consulting encourages employees to seek out management for assistance in handling their inquiry. Vencill Management Consulting employees are encouraged to raise issues and open communications about Vencill Management Consulting’s ethics and compliance issues.

Employees, customers, suppliers and other Vencill Management Consulting constituencies may also seek guidance, discuss concerns or report issues relative to Vencill Management Consulting’s Code of Conduct. Vencill Management Consulting employees will not be punished for asking about possible breaches of law, regulation or company policy. Any allegation of a reprisal will be investigated. Vencill Management Consulting’s company president, as well as the management team enforces this policy. Upon receipt of reasonable indications of suspected noncompliance, the company president along with the management team, as appropriate, will investigate the allegations to determine whether a material violation of the applicable laws, regulations or policies has occurred, and if so, take appropriate steps to correct the problem. Review and Improvement

Vencill Management Consulting’s management team is responsible for reviewing and evaluating the company’s policies and practices to ensure that they are consistent with Vencill Management Consulting’s social responsibility to act with integrity to employees, customers and society. As part of that responsibility, the management team oversees Vencill Management Consulting’s Code of Conduct. Vencill Management Consulting’s management team conducts periodic compliance assessments covering an array of regulatory regimes. The compliance assessment program is risk-based and adapts to the business and competitive landscape. Vencill Management Consulting ‘s compliance program’s responsibilities include planning and executing audits by reviewing and validating business processes and procedures, systems, financial and operational controls and assessing financial reporting, management reporting and business practices. These compliance assessments should be completed annually or as deemed necessary by the company president or by unforeseen company changes and/or situations.

References

Linda Ferrell, O. C. Ferrell, John Fraedrich (2009). Business Ethics Ethical Decision Making and Cases 2009 Update, 7 e. Chapters 5-9. Retrieved December 13, 2012 from http://online.vitalsource.com/#/books/9781285279985/pages/52929019.