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27 Virtual Code of Conduct
Ethics & Integrity

CODE OF CONDUCT

The 27 Virtual Code of Conduct establishes the fundamental standards of business conduct that all individuals and entities who work or act on behalf of 27 Virtual are expected to meet. Our values and priorities serve to guide the application of our Code to all facets of our business.

Values and Priorities

We advance our values and priorities; these are the driving forces behind all we do at 27 Virtual.

Our Values

Our core values form the most critical foundation for success.

Honor Those We Serve

We do not take lightly the responsibility we have assumed in supporting our customers. We understand that what we do is something bigger than ourselves, and through our services, we contribute to building and maintaining excellence in our field.

Maintain Selflessness for the Team

We give first to the team and expect nothing in return. Team success breeds personal success. We act for the team first, and for individuals, afterwards. Team is essential to mission and company success.

Operate With Integrity and Trust

We demand it in every way from our leaders and our employees. From the quality of our services, to the way in which we make decisions, customers and partners must be able to count on our trust. Trust is the currency of leadership and the pulse of a company.

Treat Others With Respect

We treat each other with courtesy, dignity, and respect. We recognize the value that is generated from different backgrounds and experiences.

Constantly Innovate

We show initiative and creative thinking. We challenge the status quo, embrace change, and solve problems through innovation, agility, and creative thinking. We engage in open debate, explore novel solutions, and continuously seek to better ourselves.

Deliver Excellence in Value and Capability

We work relentlessly to obtain the highest quality results. We strive for excellence through continuous improvement and flawless execution.

Our Priorities

Customer Mission

We exist to solve our customers’ most challenging problems, to deliver innovative solutions, and to secure their success through our expertise and dedication.

Employee Well-Being

We will treat each other with courtesy, dignity, and respect. We engage in open debate, explore novel solutions, and continuously seek to better ourselves.

The Company

We exist as a company to deliver our talent and capabilities. We will always act ethically and responsibly on behalf of the company while we further our customers’ missions and manage our employees who support them.

Our Stakeholders

We accept and embrace our responsibility to maximize value for our stakeholders. We will be strategic in our investments and focused in our deployment of capital to ensure optimal returns.

Responsibilities

We are individually and collectively accountable for embodying ethics and integrity in everything we do. Seek guidance and report concerns—it’s our obligation to our future.

Responsibilities of All 27 Virtual Personnel:

  • Read, understand, and comply with the Code and 27 Virtual policies.
  • Participate in training and educational programs/events, including mandatory annual training.
  • Obtain guidance for resolving a business practice or compliance concern if you are uncertain about how to proceed in a certain situation.
  • Report possible violations of the Code, policies, applicable laws, and regulatory requirements through our established channels.
  • Cooperate fully in any investigation, audit, or other company review.
  • Make a commitment to conduct 27 Virtual business with integrity and in compliance with applicable laws and regulatory requirements.

Additional Responsibilities of Leaders, Managers, and Supervisors:

  • Set the tone by promoting our values and Code, maintaining a professional work environment, taking steps to detect and/or prevent improper conduct, and refraining from retaliatory behavior.
  • Model ethical behavior by demonstrating integrity, treating employees fairly and with no discriminatory or preferential bias, treating others with respect, and ensuring that employees are not pressured to compromise 27 Virtual policies or the law.
  • Foster an open, ethical culture where employees are encouraged and feel comfortable to speak up, ask questions, and report behavior that is inconsistent with our values, Code, and other policies, without fear of retaliation.
  • Ensure employee concerns are addressed in a timely manner and required compliance training is completed when due.

Mission

We exist to solve our customers’ most challenging problems, deliver innovative virtual solutions, and secure their success through our expertise and dedication.

Working With Customers

27 Virtual maintains professional and ethical relationships with all customers. We are vigilant in ensuring we comply with applicable laws, regulations, and contract requirements.

Procurement Integrity

27 Virtual competes fairly and protects the integrity of customer procurement processes. We:

  • Obtain competitive information only through fair and legal methods
  • Do not solicit or knowingly obtain protected source selection information or competitor bid and proposal information
  • Screen current and former customer personnel seeking employment with 27 Virtual, particularly those with involvement in procurement activity

Accurate Reporting and Charging

27 Virtual personnel must report and charge all costs, including their time, in an accurate, complete, and timely manner.

Gifts and Gratuities

27 Virtual permits reasonable business courtesies, provided they comply with company guidelines. All courtesies must be appropriate, lawful, and should not create a conflict of interest.

Conflicts of Interest

27 Virtual requires all personnel to comply with conflict of interest rules that prohibit serving in conflicting roles that may bias our judgment, impair our objectivity, or otherwise create an unfair competitive advantage.

Employee Well-Being

We treat each other with courtesy, dignity, and respect. We engage in open debate, explore novel solutions, and continuously seek to better ourselves.

Human Rights

27 Virtual protects and advances human dignity and human rights. We promote and comply with all human rights laws and standards, and we will not tolerate the practice of trafficking in persons in any form.

Diversity and Inclusion

27 Virtual values different experiences and innovation, which strengthens our company and enhances our competitiveness. We maintain a strong concern for individual dignity and well-being.

Equal Opportunity

27 Virtual is committed to providing a fair, collaborative, and productive working environment for all employees. Employment decisions are based on an individual’s capabilities and qualifications.

Harassment

27 Virtual is committed to providing a professional work environment that is free of harassing, coercive, abusive or disruptive behavior. Harassment based on any protected category will not be tolerated.

Drug-Free Workplace

27 Virtual maintains a drug-free workplace and requires all personnel to comply with our drug and alcohol policies as a condition of employment.

The Company

We exist as a company to deliver our talent and capabilities. We will always act ethically and responsibly on behalf of the company.

Use of Company Resources

27 Virtual’s company property, software, equipment, or other resources may not be used for non-company business. All electronic and telephonic communication systems are the property of 27 Virtual.

Privacy

27 Virtual requires all personnel to comply with all privacy laws and regulations. All personnel must limit collection, use, storage, and access of personal information to the minimum level reasonably necessary.

Security

We are individually and collectively accountable for the protection of our workforce, customers, intellectual property, brand/reputation, and facilities.

Intellectual Property

27 Virtual recognizes that it is both illegal and unethical to engage in practices that intentionally violate the intellectual property rights of others.

Ethics and Business Conduct

At 27 Virtual, we want to uphold the highest standards of integrity, and we want to do more than comply with laws and regulations.

Making the Right Choice

If you are faced with a difficult decision, ask yourself:

  • Is it the right thing to do?
  • Will my actions be consistent with the Code and the law?
  • Am I aware of all the relevant facts, and have I considered all options?
  • Will I feel proud and comfortable telling others about the choice I made?
  • What impact will my action have on my customers, suppliers, and other employees?

Seek Guidance, Raise Concerns

27 Virtual expects personnel to comply with the text and intent of the Code and promptly report any suspected violations through available reporting channels.

Zero Tolerance for Retaliation

Speaking up to report questionable conduct protects the ethical work culture we value. 27 Virtual does not tolerate retaliation against any personnel who speak up honestly and in good faith.

How to Contact the Ethics and Compliance Office

Email: [email protected]

Ethics Helpline: Available 24/7

Anonymous reports may be made through the ethics helpline.

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