Code of Conduct

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Welcome to proper conduct

Welcome, welcome, welcome to the Blevins Holdings Code of Conduct. Every successful institution requires more than ambition, talent, and a handsome collection of organizational charts. It requires judgment, accountability, respect, and a shared understanding of how its people are expected to behave. This Code establishes the minimum standards of professional and ethical conduct for individuals working for or representing Blevins Holdings. It is intended to help each of us make sound decisions, protect the interests of the organization and its stakeholders, and maintain a workplace worthy of the confidence placed in us.

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Purpose

The purpose of this Code is to:

• Establish clear standards of ethical and professional conduct.
• Promote integrity, accountability, fairness, and respect.
• Protect employees, contractors, customers, clients, partners, and the public.
• Safeguard company information, assets, systems, and reputation.
• Support compliance with applicable laws, regulations, contracts, and company policies.
• Provide channels for raising questions and reporting suspected misconduct.
• Prohibit retaliation against individuals who raise concerns in good faith.
• Encourage early identification and responsible resolution of problems.

No code can anticipate every situation. When a rule does not provide an obvious answer, personnel are expected to use sound judgment, seek guidance, and choose the course of action most consistent with the principles in this document.

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Scope

Unless otherwise stated, this Code applies to:

• Employees, including full-time, part-time, temporary, and probationary staff.
• Officers, executives, managers, and supervisors.
• Independent contractors, consultants, and contingent workers.
• Interns, fellows, trainees, and volunteers.
• Individuals serving on committees or acting under delegated company authority.
• Representatives, agents, and other individuals acting on behalf of Blevins Holdings.
• Subsidiary personnel when this Code has been adopted or incorporated by the applicable subsidiary.

Vendors, service providers, and business partners may also be required to meet equivalent standards through contracts, supplier requirements, or other applicable policies.

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Our core principles

These principles guide how we work, make decisions, and represent Blevins Holdings.

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The ethical decision test

When the correct course is unclear, pause and ask:

1. Is it lawful?
2. Is it consistent with this Code and other company policies?
3. Do I have the authority to make this decision?
4. Is the information supporting the decision accurate and complete?
5. Am I treating affected people fairly and respectfully?
6. Could personal interests or relationships be influencing me?
7. Would I be comfortable if the decision were reviewed by leadership, auditors, regulators, or the public?
8. Have I documented the decision appropriately?
9. Would asking for guidance prevent unnecessary risk?
10. Is this the right thing to do—not merely the easiest thing to do?

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Professional conduct

Personnel are expected to conduct themselves in a manner that supports trust, safety, cooperation, and effective operations. This includes:

• Communicating honestly and respectfully.
• Performing assigned responsibilities diligently and competently.
• Meeting reasonable deadlines and commitments.
• Attending work and meetings as required.
• Providing accurate information about progress, risks, and results.
• Following lawful instructions and approved procedures.
• Maintaining appropriate professional boundaries.
• Using sound judgment when representing the organization.
• Avoiding conduct that could reasonably damage workplace trust or the reputation of Blevins Holdings.
• Seeking assistance when qualifications, authority, or information are insufficient.

Professionalism does not require unnecessary stiffness or ceremony. It does, however, require reliability, judgment, and the ability to disagree without turning the workplace into a spectacle.

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Respectful workplace

Blevins Holdings is committed to a workplace free from unlawful discrimination, harassment, retaliation, bullying, threats, and violence. Prohibited conduct may include:

• Derogatory or demeaning comments.
• Slurs, insults, or offensive jokes.
• Unwanted sexual attention or conduct.
• Repeated unwelcome comments about a person’s appearance or private life.
• Threats, intimidation, or humiliation.
• Deliberate exclusion used to punish or isolate.
• Sabotaging another person’s work.
• Abusive messages, calls, or online communications.
• Displaying or distributing offensive material.
• Retaliation for reporting a concern or participating in a review.
• Conduct that creates an intimidating, hostile, or offensive work environment.

These expectations apply in:

• Offices and company facilities.
• Remote-work environments.
• Email, messaging, and collaboration platforms.
• Meetings and video conferences.
• Business travel.
• Training sessions.
• Conferences and industry events.
• Company-sponsored gatherings.
• Social events connected to work.
• Interactions with customers, clients, vendors, and members of the public.

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Equal opportunity and nondiscrimination

Employment and business decisions must be based on legitimate qualifications, performance, conduct, operational needs, and other lawful considerations. Discrimination based on a legally protected characteristic is prohibited. This expectation applies to:

• Recruitment and hiring.
• Compensation.
• Assignments and scheduling.
• Training and development.
• Promotion.
• Performance management.
• Discipline.
• Access to opportunities and resources.
• Termination.
• Vendor and contractor treatment.
• Other employment and business decisions.

Requests for workplace accommodations should be directed to Global Human Resources or another designated contact.

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Conflicts of interest

A conflict of interest exists when personal, financial, family, romantic, or outside interests could interfere—or reasonably appear to interfere—with an individual’s duty to act in the best interests of Blevins Holdings. A conflict is not necessarily misconduct. Concealing one, mishandling one, or allowing it to influence a company decision may be. Potential conflicts may include:

• Outside employment, consulting, or business activities.
• Ownership or financial interests in a competitor, vendor, client, or potential transaction partner.
• Supervising or influencing decisions involving a relative, romantic partner, close friend, or household member.
• Participating in vendor selection when a personal relationship exists.
• Directing company opportunities to yourself or an associate.
• Using nonpublic company information for personal gain.
• Accepting benefits that could affect—or appear to affect—business judgment.
• Conducting personal business using company time, systems, information, or property.
• Serving on an outside board or advisory body with competing obligations.
• Borrowing from or lending money to individuals whose business relationship with the company could create improper influence.

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Disclosure requirements

Personnel must disclose potential conflicts promptly and in writing. A disclosure should identify:

• The nature of the relationship or interest.
• The people or organizations involved.
• The decision, transaction, or duty that may be affected.
• Any financial or personal benefit involved.
• The expected duration of the situation.
• Any proposed safeguards or recusal arrangements.

Disclosures should be submitted to the individual’s manager and Global Human Resources, or through another designated conflict-of-interest process.

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Personal and romantic relationships

Personal relationships can create real or perceived favoritism, divided loyalties, confidentiality concerns, or unequal power dynamics. Personnel must disclose a close personal, family, or romantic relationship when one individual:

• Directly or indirectly supervises the other.
• Influences compensation, promotion, discipline, scheduling, assignments, or access to opportunities.
• Reviews or approves the other person’s work.
• Participates in a transaction involving the other person.
• Has access to confidential information affecting the other person.
• Could reasonably be perceived as favoring the other person.

The company may adjust reporting relationships, decision authority, duties, or assignments to manage the conflict.

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Gifts, meals, entertainment, and hospitality

Business courtesies must never be used to obtain improper influence or reward a favorable decision. Personnel must not offer, request, give, or accept:

• Cash or cash equivalents.
• Bribes, kickbacks, or secret commissions.
• Lavish or excessive gifts.
• Personal benefits tied to a pending decision.
• Gifts that violate law, contract, or recipient policy.
• Entertainment that is inappropriate or unrelated to a legitimate business purpose.
• Anything intended to influence a government official improperly.
• Repeated gifts that become significant when considered together.

Reasonable and infrequent meals, modest gifts, or customary business hospitality may be permitted when they:

• Serve a legitimate business purpose.
• Are lawful and consistent with policy.
• Are not requested or solicited.
• Are reasonable in value and frequency.
• Would not create embarrassment if disclosed.
• Do not influence—or appear to influence—a decision.

When uncertain, seek approval before accepting or providing the courtesy.

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Anti-bribery and improper payments

Blevins Holdings prohibits bribery, kickbacks, facilitation payments, secret commissions, and other improper transfers of value. Personnel must not offer, authorize, request, receive, or arrange anything of value for the purpose of:

• Obtaining improper business advantage.
• Influencing an official or commercial decision.
• Avoiding a lawful obligation.
• Securing confidential information improperly.
• Rewarding another party for breaching a duty.
• Directing business through improper influence.

This prohibition applies whether the payment or benefit is made directly or through an agent, consultant, intermediary, vendor, partner, or other third party.

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Fair dealing

Personnel must deal fairly and honestly with colleagues, customers, clients, competitors, vendors, regulators, and business partners. Prohibited conduct includes:

• Falsifying or withholding material information.
• Making promises the company cannot reasonably fulfill.
• Misrepresenting products, services, qualifications, results, or authority.
• Manipulating procurement or competitive processes.
• Misusing confidential information belonging to another party.
• Colluding improperly with competitors.
• Creating false urgency or pressure through deceptive statements.
• Taking unfair advantage of another person’s mistake, vulnerability, or lack of information.

Competition should be vigorous, lawful, and honorable. There is no need to behave badly merely because others have failed to organize themselves.

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Protection of confidential information

Confidential information may include:

• Business plans and strategies.
• Financial information.
• Pricing and forecasts.
• Contracts and negotiations.
• Customer, client, vendor, and partner information.
• Employee and applicant information.
• Legal advice and privileged communications.
• Security configurations and credentials.
• Technical designs, source code, models, and research.
• Trade secrets and intellectual property.
• Investigation and audit information.
• Acquisition, investment, and transaction information.
• Nonpublic subsidiary information.
• Other information classified or treated as restricted.

Personnel must:

• Access information only for legitimate work purposes.
• Share information only with authorized recipients.
• Use approved systems and communication channels.
• Follow applicable classification, retention, and disposal requirements.
• Protect information during travel and remote work.
• Prevent unauthorized viewing, copying, downloading, or forwarding.
• Report suspected loss, disclosure, or misuse promptly.
• Return or destroy information when required.

Confidentiality obligations may continue after employment, engagement, or access ends.

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Data privacy

Personal information must be handled lawfully, fairly, securely, and only for authorized purposes. Personnel must:

• Collect only the information reasonably needed.
• Use personal information only for approved purposes.
• Limit access to authorized individuals.
• Avoid sharing personal information casually or unnecessarily.
• Follow retention and deletion requirements.
• Use approved systems for storage and transmission.
• Report suspected privacy incidents promptly.
• Consult the responsible privacy or legal function before introducing new uses of personal information.

Curiosity, convenience, and technical access do not create legitimate authorization.

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Information security

Every person with access to company systems has a responsibility to protect them. Personnel must:

• Use strong, unique passwords and approved authentication methods.
• Protect multifactor-authentication devices and codes.
• Never share credentials.
• Lock devices when unattended.
• Install only authorized software.
• Use approved storage and collaboration platforms.
• Follow remote-access and device-security requirements.
• Be alert to phishing, impersonation, and social-engineering attempts.
• Report suspicious messages, activity, or system behavior.
• Avoid bypassing security controls.
• Protect physical access badges, keys, and devices.
• Cooperate with authorized security reviews and investigations.

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Use of company assets

Company assets must be used responsibly, efficiently, and for legitimate business purposes. Assets include:

• Funds and financial accounts.
• Devices and equipment.
• Facilities and vehicles.
• Systems, software, and networks.
• Intellectual property.
• Records and information.
• Employee time.
• Corporate cards.
• Business opportunities.
• Company names, logos, and reputation.
• Authority delegated by the organization.

Limited personal use may be permitted when it is reasonable, lawful, infrequent, secure, and does not:

• Interfere with work.
• Create material cost.
• Violate policy.
• Expose the company to risk.
• Support outside commercial activity.
• Involve offensive or unlawful content.
• Suggest company endorsement.
• Reduce the security or availability of company systems.

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Accurate records and truthful communications

Company records must be accurate, complete, timely, and understandable. This applies to:

• Financial records.
• Expense reports.
• Time records.
• Performance records.
• Contracts and approvals.
• Personnel files.
• Safety and incident reports.
• Customer and vendor records.
• Project documentation.
• Compliance certifications.
• Audit and investigation materials.
• System and access records.
• Communications used to support decisions.

Personnel must not:

• Create false or misleading entries.
• Alter records improperly.
• Backdate documents without authorization.
• Omit material information.
• Conceal unauthorized transactions.
• Approve records without adequate review.
• Maintain undisclosed side agreements.
• Destroy or modify records subject to preservation requirements.
• Direct another person to create an inaccurate record.

A tidy document is lovely. An accurate one is mandatory.

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Expenses and financial stewardship

Business expenses must be reasonable, necessary, properly documented, and submitted in accordance with company policy. Personnel must not:

• Submit personal expenses as business expenses.
• Split transactions to avoid approval limits.
• Submit duplicate claims.
• Fabricate or alter receipts.
• Misstate the purpose or participants of an expense.
• Use company funds for unauthorized gifts, donations, or entertainment.
• Approve an expense when a conflict exists.
• Circumvent purchasing or contracting requirements.
• Use corporate cards for prohibited purposes.

Questions about an expense should be resolved before the commitment is made whenever practical.

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Political and civic activity

Blevins Holdings respects lawful personal participation in civic and political activities. Personnel engaging in personal political activity must:

• Act in their personal capacity.
• Avoid using company funds, systems, property, or branding without authorization.
• Avoid implying company endorsement.
• Comply with applicable laws and company policies.
• Ensure the activity does not interfere with work obligations.
• Obtain required approval before communicating on behalf of the company.

Any corporate political contribution, lobbying activity, or government engagement must be authorized through the appropriate process.

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External communications and social media

Only authorized individuals may speak publicly on behalf of Blevins Holdings. Media inquiries, requests for official comment, and sensitive external communications should be referred to the appropriate communications, legal, or executive contact. When using personal social media, personnel must not:

• Disclose confidential information.
• Imply they speak for Blevins Holdings without authorization.
• Use company branding deceptively.
• Harass colleagues, customers, clients, vendors, or partners.
• Publish knowingly false information about company matters.
• Interfere with investigations or legal obligations.
• Violate applicable workplace or information-security policies.

Nothing in this section is intended to restrict lawful protected activity.

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Health, safety, and workplace security

Personnel must support a safe and secure working environment. This includes:

• Following safety procedures.
• Reporting hazards, threats, injuries, and unsafe conditions.
• Using required protective equipment.
• Cooperating with emergency instructions.
• Avoiding violent, threatening, or intimidating conduct.
• Not bringing prohibited weapons or hazardous materials onto company property.
• Reporting concerns involving workplace violence or security promptly.
• Performing work only when fit to do so safely and effectively.

Immediate threats should be reported to emergency services and company security or management as appropriate.

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Substance use and impairment

Personnel must not perform work while impaired in a manner that creates safety, performance, judgment, security, or legal risk. The unlawful manufacture, distribution, sale, possession, or use of controlled substances in the workplace or while conducting company business is prohibited. Lawful medication should be used responsibly. Personnel who believe a medication or condition may affect safe job performance should seek guidance through the appropriate confidential process.

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Cooperation with audits, reviews, and investigations

Personnel must cooperate honestly with authorized:

• Internal investigations.
• Human Resources reviews.
• Compliance reviews.
• Security investigations.
• Financial audits.
• Legal reviews.
• Regulatory examinations.
• Office of Inspector General inquiries.
• Other authorized oversight activities.

Cooperation includes:

• Providing truthful and complete information.
• Preserving relevant records.
• Following confidentiality instructions.
• Making systems, devices, or documents available when lawfully required.
• Refraining from influencing witnesses improperly.
• Avoiding concealment, alteration, or destruction of evidence.

No person may interfere with, obstruct, or retaliate in connection with an authorized review.

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Responsibilities of managers and leaders

Managers and leaders carry additional responsibilities. They must:

• Model the conduct required by this Code.
• Create an environment where employees can raise concerns.
• Respond seriously and promptly to reported issues.
• Escalate matters to the appropriate function.
• Avoid conducting unauthorized investigations.
• Protect confidentiality to the extent reasonably possible.
• Avoid promising outcomes they do not control.
• Apply standards consistently.
• Address retaliation immediately.
• Ensure personnel receive required training.
• Avoid directing employees to violate law, policy, or professional standards.
• Document material decisions and approvals appropriately.

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Raising questions and reporting concerns

Personnel are encouraged to seek guidance before a concern becomes a crisis. Questions or suspected violations may be reported to:

• A direct manager.
• Another manager or department leader.
• Global Human Resources.
• Legal, Risk and Compliance.
• The Office of Inspector General.
• Information Systems and Technology for security incidents.
• Finance for suspected financial misconduct.
• Another designated ethics, compliance, or reporting channel.
• The confidential or anonymous reporting service, when available.

Confidential reporting channel: [Insert channel] Anonymous reporting channel: [Insert channel] Emergency contact: [Insert instructions] Personnel are not required to report a concern to someone they believe is involved in the matter.

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What to include in a report

Provide as much factual information as reasonably available, including:

• What occurred.
• When and where it occurred.
• Who was involved.
• Who may have witnessed it.
• Whether the issue is ongoing.
• Whether anyone may be in immediate danger.
• Relevant messages, documents, records, or system information.
• Steps already taken.
• Any concern about retaliation or evidence being destroyed.

Do not delay a report merely because every detail is not yet known.

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Confidentiality of reports

Reports and investigations will be handled as discreetly as reasonably possible. Information may be shared with individuals who need it to:

• Evaluate the concern.
• Protect affected persons.
• Conduct a fair investigation.
• Obtain legal advice.
• Implement corrective action.
• Meet reporting or regulatory obligations.
• Protect company operations and assets.

Absolute confidentiality cannot always be guaranteed, particularly when facts must be investigated or disclosed by law.

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Good-faith reporting

A good-faith report is one made honestly based on information the person reasonably believes may indicate misconduct, risk, or a policy violation. A report does not need to be proven correct to be made in good faith. Personnel will not be disciplined merely because a good-faith concern is not substantiated. Knowingly false allegations, deliberate fabrication, or malicious misuse of a reporting process may result in corrective or disciplinary action.

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Non-retaliation

Retaliation against an individual who raises a concern in good faith, participates in an investigation, requests guidance, refuses to engage in suspected unlawful conduct, or exercises a protected right is prohibited. Retaliation may include:

• Termination or demotion.
• Reduced hours or undesirable assignments.
• Exclusion from meetings or opportunities.
• Threats or intimidation.
• Harassment or social isolation.
• Unjustified negative evaluations.
• Interference with advancement.
• Unfounded disciplinary action.
• Spreading damaging rumors.
• Pressure to withdraw or alter a report.
• Any other materially adverse treatment connected to protected activity.

Suspected retaliation should be reported immediately.

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Investigation process

The precise process will depend on the nature and seriousness of the concern. An investigation may include: The company may not be able to disclose confidential findings, personnel actions, legal advice, or all details of an outcome.

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Consequences of violations

Violations of this Code may result in action proportionate to the nature, severity, frequency, and impact of the conduct. Possible consequences include:

• Coaching or counseling.
• Additional training.
• Written corrective action.
• Changes in duties or reporting relationships.
• Loss or restriction of system access.
• Repayment or recovery of funds.
• Removal from a project or position of trust.
• Suspension.
• Termination of employment or engagement.
• Termination of a vendor, contractor, or business relationship.
• Referral to licensing bodies, regulators, insurers, law enforcement, or other authorities.
• Civil or legal action.

Relevant considerations may include:

• Intent.
• Harm or potential harm.
• Position and level of responsibility.
• Whether the conduct was repeated.
• Whether the individual self-reported.
• Cooperation with the investigation.
• Efforts to conceal the conduct.
• Retaliation or interference.
• Prior corrective history.
• Applicable legal requirements.

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No informal waivers

No manager, executive, or employee may authorize conduct that violates law or this Code unless a formal exception is legally permissible and approved through the designated process. Past practice, silence, urgency, customer pressure, or verbal approval does not create an exception.

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Training and acknowledgment

Personnel may be required to complete Code of Conduct training and acknowledge that they:

• Received access to the Code.
• Read and understood its requirements.
• Know how to ask questions and report concerns.
• Agree to comply with applicable standards.
• Understand the prohibition against retaliation.
• Have disclosed known conflicts of interest.
• Understand that violations may result in disciplinary action.

Failure to complete an acknowledgment does not excuse compliance.

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Relationship to other policies

This Code establishes broad standards of conduct. More detailed requirements may appear in other company policies, standards, and procedures. Related documents may include:

• Anti-Harassment and Nondiscrimination Policy.
• Conflict of Interest Policy.
• Information Security Policy.
• Acceptable Use Policy.
• Data Privacy Policy.
• Records Management Policy.
• Expense Reimbursement Policy.
• Travel and Entertainment Policy.
• Procurement Policy.
• Remote Work Policy.
• Workplace Safety Policy.
• Investigation and Non-Retaliation Policy.
• Delegation of Authority Policy.
• Social Media and External Communications Policy.

When another policy imposes a stricter requirement, personnel should follow the stricter requirement unless an authorized policy owner provides different written guidance.

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Questions and interpretation

Questions regarding this Code should be directed to:

• Global Human Resources.
• Legal, Risk and Compliance.
• The Office of Inspector General.
• The department responsible for the relevant subject.
• Another authorized ethics or compliance contact.

No one should be criticized for requesting clarification before acting. A preventable mistake is rarely improved by confidence, speed, or excellent formatting.

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Policy administration

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Revision history

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A final word

Integrity is not a performance reserved for moments of observation. It is the quiet discipline of telling the truth, treating people properly, protecting what has been entrusted to us, correcting mistakes, and speaking up when something is wrong. Conduct yourself honorably. Document matters accurately. Ask sensible questions. Escalate concerns through the proper channels. And remember: Professionalism is always appropriate, integrity never goes out of style, and a properly disclosed conflict is infinitely more attractive than a concealed one.