Delivering the highest quality solutions requires abiding by a higher set of standards and regulations. Under our Code of Business Conduct and Ethics (CBCE), we promote a culture of safety, integrity, and accountability in every project, program, and community we serve.

Policy 2.1 Code of Business Conduct and Ethics

General Responsibilities for Anyone Associated with Gray Analytics

Gray Analytics managers, supervisors, employees, agents, consultants, subcontractors, and suppliers are expected to:

• Conduct business in accordance with the highest ethical standards.
• Comply with the letter and spirit of the laws of the U.S. and other jurisdictions in which Gray Analytics does business.
• Use Gray Analytics and customer resources appropriately.
• Never participate in, condone, or ignore illegal or unethical acts; and
• Raise ethical concerns immediately and escalate them as necessary to all appropriate resources within Gray Analytics.

Employee Responsibilities

Employees must be fair, honest, and comply with the law in all business relationships. Employees must:

• Follow the law.
• Follow Gray Analytics Core Values.
• Follow Gray Analytics policies and procedures.
• Use common sense and good judgment.
• Seek guidance when unsure; and
• Speak up when a problem arises.

Manager and Supervisor Responsibilities

Each manager and supervisor must also

• Lead by example.
• Foster an environment that emphasizes and rewards ethical behavior.
• Promote a culture where people are comfortable asking questions and raising concerns; and
• Ensure that colleagues are aware of and comply with this Code and relevant Gray Analytics policies and legal requirements.

Expectations of Employees of Gray Analytics

Gray Analytics employees are each expected to comply with this Code. Any violation of this Code may result in consequences up to and including termination of employment for the responsible party.

Retaliation against anyone who reports what they believe in good faith to be a violation of this Code or any law or regulation applicable to Gray Analytics, who assists in making such a report, or who cooperates with an investigation of any such violation is strictly prohibited and will result in disciplinary action up to and including termination of employment for the responsible party.

Although not every situation contrary to this policy can be listed here, the following situations are prohibited:

• Competing against Gray Analytics.
• Personal conflicts of interest when your own interests, or those of your immediate family, interfere in any way or even appear to interfere with Gray Analytics’ legitimate business interests or your ability to make objective and fair decisions when performing your job.
• Offering or accepting meals, gifts, gratuities, or entertainment that may create or appear to create a conflict between the employee’s personal interests and the interests of Gray Analytics or give the impression of an illegal or unethical transaction with another party; and
• Knowingly making a false claim or statement to the government is a violation of the law and can subject both Gray Analytics and the individual to civil and criminal sanctions including fines, suspension, debarment, and prison sentences.

When presented with a situation that may be unethical, inappropriate, or illegal, ask yourself:

• Does what I am doing comply with Gray Analytics’ guiding principles, Code of Business Conduct and Ethics, and company policies and procedures?
• Have I been asked to misrepresent information or deviate from normal procedure?
• Would I feel comfortable describing my decision at a staff meeting?
• How would it look if this decision made the headlines?
• Am I being loyal to my family, myself, and Gray Analytics?
• What would I tell my child to do in this situation?

Expectations of Agents, Consultants, Subcontractors, and Suppliers of Gray Analytics

Gray Analytics agents, consultants, subcontractors, and suppliers are each expected to comply with this Code. Any violation of this Code may result in consequences up to and including discontinuation of business with the responsible party.

Retaliation against anyone who reports what they believe in good faith to be a violation of this Code or any law or regulation applicable to Gray Analytics, who assists in making such a report, or who cooperates with an investigation of any such violation is strictly prohibited and will result in disciplinary action up to and including discontinuation of business with the responsible party.

Administration and Interpretation

Gray Analytics’ Compliance Officer will administer this Code of Business Conduct and Ethics. All questions relating to this Code and the company’s business practices in general should be directed to the Compliance Officer.

Gray Analytics directors, employees, agents, consultants, subcontractors, and suppliers are each expected to comply with this Code and the company’s other policies and procedures. Anyone with questions about this Code or concerns about compliance have a duty to seek guidance. Questions or concerns should be addressed to his or her immediate supervisor or to the Compliance Officer. Anyone who wishes to seek guidance anonymously should feel free to use the company’s address at [email protected] for reporting violations described in this Code, any law or regulation applicable to the company’s business, or in any other company policy.

Gray Analytics reserves the right to use any lawful method of investigation that it deems necessary to determine whether any person has engaged in conduct that in its view interferes with or adversely affects its business. Every manager, supervisor, employee, agent, consultant, subcontractor, and supplier are expected to cooperate fully with any investigation of any violation of the law, the company’s policies and procedures, or this Code.

COMPLIANCE OFFICER: Jay Town, 256-457-7617, [email protected]

CHAIN of COMMAND: Scott Gray, 256-384-4729, [email protected]

Contacting Gray Analytics’ Ethics Office

For those wishing to raise a concern, to report alleged misconduct or violation of Company policy, government law or regulation, or to seek advice, the Gray Analytics CECO may be reached in the following ways:

Agreement and Responsibility

Employees of Gray Analytics will be issued a copy of this Ethics and Compliance Program and Code of Conduct within the Gray Analytics Policy Book to be signed at hire, annually and at any time the policy is revised. Gray Analytics expects every employee to understand the importance of and embrace this policy.  Failure to comply with all aspects of this policy may result in disciplinary action, up to and including termination. If any portion of this policy is in question, please seek the immediate guidance of management or the Compliance Officer.