BBNC Code of Ethics Code of Ethics_JooMag | Page 40

HIRING OF GOVERNMENT AND FORMER GOVERNMENT EMPLOYEES Special restrictions apply to hiring or retaining a government or former government employee as an employee or consultant. In addition, various laws create post-employment restrictions that may limit the type of work that the government employee can perform for certain periods of time, particularly for matters that they were personally and substantially involved or that involved agencies where they had held senior positions. publicly announced that they are leaving government service. In addition, any plans to employ retired military officers of general or flag rank, or civilian officials having the rank of Deputy Assistant Secretary or above, must be approved by the BBNC President and CEO or the respective subsidiary company group President and CEO prior to an offer of employment. BBNC will not conduct any discussions regarding potential employment or business opportunities to any procurement official connected to a contract for which a bid has been submitted or contract awarded. In order to be sure that you do not run afoul of restrictions in this area, before discussing potential BBNC employment with any government employee, contact the BBNC Compliance Department. Authorization from the BBNC Compliance Department must be obtained before even mentioning proposed employment to current or recently separated government employees, and only after they have 38 BBNC Code of Ethics | Ethics Hotline: 1.866.513.7078 | Effective May 17, 2019 | www.bbnc.net Operating with Hiring Government Employees Q: I would like to hire a current or former government employee. What precautions should I take before discussing potential employment with a current or former government employee? A: The first step is to contact BBNC Compliance Department to discuss what you can and cannot do depending on the specific facts and circumstances. There are restrictions on even discussing possible employment with certain current government employees. Current and former government employees are also banned from disclosing certain information that they learned during their government employment, and further safeguards/firewalls may need to be put in place so as to avoid BBNC or its subsidiaries from potentially being disqualified from competing for future contracting opportunities. Some government employees have post-employment or revolving door restrictions on the type of work the can do for specified periods of time after leaving the government.