BBNC Code of Ethics Code of Ethics_JooMag | Page 29

ANTI-KICKBACK ACT Business Courtesies to Government Personnel Government personnel are subject to a different standard. Under both federal and state law, government personnel are generally prohibited from accepting entertainment, meals, gifts, gratuities, and other things of value from businesses and persons with whom they do business or over whom they have regulatory authority. Employees of the executive branch are permitted to accept unsolicited business gifts (except cash or investment interests) of up to $20 in market value per occasion (the entire visit). The sum of these gifts cannot exceed $50 from one company per calendar year. Offering or giving gifts in excess of these amounts may be a criminal offense, regardless of intent and regardless of whether paid with BBNC or personal funds. The Anti-Kickback Act prohibits subcontractors and potential subcontractors under government contracts from giving kickbacks to prime contractors or their employees or to higher-tiered subcontractors or their employees. The Act also prohibits the acceptance of such kickbacks. “Kickbacks” can be in the form of money, fees, commissions, credits, gifts, gratuities, or anything of value, which is either directly or indirectly provided in return for obtaining favorable treatment. Favorable treatment does NOT have to be something that you would think of as dishonest, but under different circumstances, might be considered an innocent act. It could include such activities as: Awarding a subcontract or purchase order; Reducing contract requirements; Putting a supplier on the bidder’s list; When the favorable treatment is “bought,” then it becomes unlawful. The Act prohibits any employee from: Providing, attempting to provide, or offering to provide any kickback; Soliciting, accepting, or attempting to accept a kickback; Including, either directly or indirectly, the amount of any kickback in the contract price charged to our customers. Your Responsibilities Immediately report any requests to make, authorize, or agree to any offer or payment which is contrary to this Code. Immediately report any information that makes you suspect that an employee or vendor is engaging in, or has engaged in, conduct prohibited by this Code. Paying an invoice earlier than the company would normally pay it. BBNC Code of Ethics | Ethics Hotline: 1.866.513.7078 | Effective May 17, 2019 | www.bbnc.net 27