Business Ethics & Compliance

OUR DEDICATION TO ETHICAL STANDARDS, INTEGRITY, AND LAWFUL COMPLIANCE

The cornerstone of our commitment to maintaining the highest standards of ethical conduct and legal compliance in every facet of our operations is demonstrated through our comprehensive policies covering:

• Corruption Prevention
  At Morgan Wendellman, we enforce a strict anti-corruption policy that conforms to both international and domestic regulations, including the U.S. Foreign Corrupt Practices Act and the UK Bribery Act. We ensure all business interactions are conducted ethically and transparently, fostering a culture of integrity.

• Financial Integrity and Security
  We implement comprehensive safeguards to prevent and detect any instances of money laundering or terrorist financing. Our rigorous financial compliance measures include thorough vetting processes and continuous monitoring to uphold the integrity of our financial transactions.

• Fair Competition Practices
  Our commitment to fair competition is unwavering. We adhere to all antitrust and competition laws to ensure our business practices promote healthy competition and innovation, while preventing market manipulation or unethical competitive behavior.

• Safeguarding Data Privacy
  Protecting the confidentiality and integrity of data is paramount in our operations. We comply with leading data protection standards such as the GDPR, ensuring that all personal and corporate information is handled with the utmost care and in compliance with global privacy regulations.

• Ethical Conduct
  Ethical behavior is the bedrock of our corporate culture. We conduct regular training sessions and reinforce ethical standards to ensure that all employees embody our core values of honesty, respect, and fairness in their professional conduct.

• Combating Human Trafficking
  Morgan Wendellman is committed to eradicating human trafficking in all its forms. We adhere strictly to laws that forbid human trafficking and enforce rigorous checks to guarantee transparency and ethical practices throughout our supply chains.

• Government Relations and Compliance
  As a trusted partner to the U.S. federal government, we strictly conform to the Federal Acquisition Regulation (FAR) and other pertinent regulations. We ensure full compliance with all government contracts and engagements, maintaining a standard of excellence and reliability.

• Records and Information Management
  We uphold stringent policies for managing corporate and client information. By maintaining comprehensive systems for records management, we ensure compliance with all regulatory requirements and safeguard the confidentiality and accessibility of information.

• Global Trade Law Adherence
  Our global operations are guided by a thorough understanding of and compliance with international trade laws, including export controls and sanctions. We navigate these complex regulations to ensure that our international business practices are both ethical and legal.

Our Ethics & Compliance Initiatives Share a Common Framework to Support Our Strategic Objectives

Leadership and Culture: Our framework is championed by our Board of Directors and the Chief Ethics & Compliance Officer, supported by leadership at all levels. They set the ethical tone and ensure comprehensive support for our compliance initiatives. At the core, our commitment to honesty and ethical behavior underpins every business interaction, crucial for maintaining trust across all stakeholder groups.

Policies and Procedures: We have established clear, documented standards, including our Code of Business Ethics and Conduct, which guide employee behavior. By integrating advanced tools and technologies into everyday business processes like hiring and procurement, we make compliance a seamless part of our operations, providing everyone with the guidance they need. Our compliance efforts include ongoing monitoring and auditing to check the effectiveness of our programs. This regular scrutiny helps us stay on top of trends and ensures our responses are timely and appropriate, keeping our compliance framework robust and responsive.

Risk Management and Legal Compliance: We regularly conduct risk assessments, working closely with our risk management and business teams. This proactive approach helps us spot new compliance risks and benchmark our practices against industry standards. When risks are identified, we tailor our compliance program to address them effectively, keeping our operations both safe and compliant. Keeping up with legal and regulatory changes is crucial for our operations. We monitor developments and adapt quickly, ensuring that we always meet legal standards and are seen as a dependable partner in the industry.

Workplace Integrity and Resource Management: Our commitment to diversity and human rights fosters an inclusive environment where every team member feels valued, enhancing our business interactions and competitive edge. We manage our resources efficiently, aiming to minimize waste and maximize sustainability. Accountability is key in our culture, promoting transparency and trust across the organization.

Training and Engagement: We actively engage our employees with training programs that are both wide-reaching and specific, using real-world scenarios to ensure relevance. We constantly refine our training based on feedback and best practices, empowering our team to manage and mitigate risks confidently.

All Morgan Wendellman’s employees are expected to uphold the standards set forth in our business code of conduct and ethics, as well as comply with applicable laws and company policies.

At Morgan Wendellman, we believe that making informed and ethical decisions is a collective responsibility. We encourage open communication and transparency to ensure that all employees feel empowered to report concerns or seek guidance when needed.