COE 2021 FINAL | Page 39

PROHIBITED CONTRACTUAL RELATIONSHIPS
BBNC shall not knowingly engage in any unlicensed transaction or knowingly contract with any individual or entity located in a country subject to U . S . embargo sanctions ( i . e ., the Crimea Region of Ukraine , Cuba , Iran , North Korea , and Syria ), or identified on the Office of Foreign Assets Control ’ s ( OFAC ) “ Specially Designated Nationals and Blocked Persons ” list .
BBNC may not knowingly employ an individual who has been convicted of an offense related to government contracting .
BBNC will immediately sever all business connection with any former employee and / or consultant of BBNC whose conduct violates applicable laws , regulations , or basic tenets of business integrity and honesty . Appropriate notices specifically identifying such individuals will be provided to applicable employees .
CLASSIFIED DATA PRIVACY & SECURITY
Some BBNC employees work on a day-to-day basis with information that has a government security classification . Access to this information is restricted to those employees who have the appropriate security clearance and such information is only shared on a needto-know basis .
Allowing improper access to , or unauthorized disclosure of , classified information , whether intentional or through carelessness , is punishable under federal criminal laws . This can be damaging to the individual employee , to BBNC , and to our nation ’ s security .
Classified information violations should NOT be reported via the Ethics Hotline and Website . If you need to report a concern about a violation of law or of this Code and you feel that reporting such a concern may require disclosure of classified information , report your concern via your established chain of command . If you are uncomfortable doing so , or if after doing so , you still feel that further action is necessary , then you should report to the Ethics Hotline or Website that you have a concern involving classified information .
Do NOT disclose the classified information until a proper review and investigation is conducted .
Your Responsibilities
Never share classified information with anyone ( including a co-worker ) who does not have both the required security clearance and need-to-know status .
After accessing classified information , ensure that such material is locked in an approved storage place . Do NOT take classified documents home .
Report unauthorized release , loss , or destruction of classified material to chain of command .
Government rules and regulations governing the processing , storing and transmission of Controlled Unclassified Information ( CUI ) and Unclassified Controlled Technical Information ( UCTI ) are constantly changing . If you have a question , contact your IT department or the BBNC Compliance Department .
BBNC Code of Ethics | Ethics Hotline : 1.866.513.7078 | May 7 , 2021 | info . bbnc . net 37