Smartronix promotes an organizational culture that encourages ethical conduct and a commitment to compliance with the law through its ongoing business ethics awareness and compliance program. This program includes reasonable steps to periodically communicate our standards and procedures by conducting effective training programs and otherwise disseminating appropriate information regarding employee roles and responsibilities. Our internal control system establishes standards and procedures to facilitate timely discovery of improper conduct in connection with Government contracts, and ensures corrective measures are promptly instituted and carried out. This includes the assignment of responsibility at the senior level to ensure effectiveness of the program and internal control system, the implementation of vetting of new principals, periodic reviews of company business practices, procedures, policies, and internal controls for monitoring and auditing to detect criminal conduct, periodic evaluation of the effectiveness of the program and internal control system, and periodic assessment of the risk of criminal conduct. Smartronix maintains an internal hotline for anonymous reporting that encourages employees to report suspected instances of improper conduct. Or program provides for disciplinary action for improper conduct or for failing to take reasonable steps to prevent or detect improper conduct.

Smartronix shall also ensure the timely written disclosure of any credible evidence that a principal, employee, agent, or subcontractor of the Contractor has committed a violation of Federal criminal law involving fraud, conflict of interest, bribery, or gratuity violations found in Title 18 U.S.C. or a violation of the civil False Claims Act (31 U.S.C. 3729-3733) in connection with the award, performance, or closeout of any Government contract for a period of at least 3 years following final payment on the contract. Such disclosure will be to the agency OIG, and Contracting Officer. If the violation relates to an order against a Government-wide acquisition contract, a multi-agency contract, a multiple-award schedule contract such as the Federal Supply Schedule, or any other procurement instrument intended for use by multiple agencies, Smartronix shall notify the OIG of the ordering agency and the IG of the agency responsible for the basic contract, and the respective agencies’ contracting officers. Smartronix shall always fully cooperate with any Government agencies responsible for audits, investigations, or corrective actions.

Smartronix ensures that all subcontracts that have a value in excess of $5,000,000 and a performance period of more than 120 days include a requirement for the subcontractor to have a Business Ethics and Compliance program.