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  • Page A

    of Business Ethics and Conduct

    Revised October 2015

    Contractors Code

  • Page 1

    Contractors Code of Business Ethics and Conduct

    Commitment to ProfessionalismWHPacific, Inc. (WHPacific or the Company) is committed to providing quality services to our clients with integrity and professionalism and in compliance with all applicable laws. It is also WHPacifics policy to compete fairly and in accordance with applicable procurement rules.

    This is possible only when all WHPacific employees perform their jobs with the highest standards of ethical conduct and with consideration for the interests of our clients, other employees, subcontractors, suppliers, and the communities affected by our work. The Companys reputation depends upon the actions employees take and the decisions that they make each day. Therefore, WHPacific expects every employee to conduct his or her business affairs in a manner that protects and even strengthens the Companys reputation. To formalize these expectations, WHPacific maintains a business ethics and conduct compliance program for all employees.

    What is the Code?WHPacifics Contractor Code of Business Ethics and Conduct (the Code) explains what is expected of WHPacific employees and provides guidance on how to meet those expectations. More specifically, the Code describes the Companys expectations for appropriate business conduct.

    The Code is a key part of WHPacifics Ethics and Compliance Program (the Program), which ensures that the Codes provisions are communicated effectively to employees and enforced through policies, procedures, and management practices.

    To Whom Does the Code Apply?Our Code is applicable to all employeesexecutives, managers, and individual contributorswithout exception. No provision of the Code maybe waived for or by any manager or executive officer. The Code also applies to employees traveling on behalf of the Company. It may also apply to independent contractors, venders, and subcontractors.

    How is the Code Administered?The most current version of the Code is available on the WHPacific intranet, Compass. New hires receive a copy of the Code within 10 days of their hire date and training on the Code within 60 calendar days of their hire date. Yearly training on the Code is provided to all employees, and on a regular basis, every employee is asked to sign a statement that he or she has received and read the Code and understands it. The Code is reviewed annually by WHPacifics Compliance Officer and modified if necessary.

    At the heart of the code are our values, which are the same values as those of our parent company, NANA Development Corporation.

    WHPacific's Values

    The basic values that guide us are these:

    Honesty and integrity govern our activities. Commitments made will

    be fulfilled. All individuals are treated with dignity

    and respect.

    Our values define how we conduct business and how we measure and evaluate our decisions and actions. WHPacifics strong ethical reputation is a critical asset, and each of us shares a personal responsibility to protect, preserve, and enhance it.

  • Page 2

    WHPacifics Compliance Officer

    WHPacifics Compliance Officer, Juliana Cobb (Julie), is responsible for overseeing WHPacifics Compliance Program. If you have compliance questions, comments, or concerns, you may reach Julie at 907-339-6515 or via email at jcobb@whpacific.com.

    Internal Compliance Reviews and AuditsOn a regular basis, WHPacifics books and records are reviewed by both internal and outside auditors to ensure compliance with Company policies, standards, and procedures. All WHPacific employees are expected to fully cooperate with such audits.

    WHPacifics Internal Controls

    Internal controls are important in preventing and detecting fraud and protecting the Companys resources. They ensure that our financial reporting is accurate and that management has up-to-date information on how well we are achieving operational or strategic goals. Oversight of WHPacifics internal controls is the purview of WHPacifics Finance and Accounting department.

    WHPacifics Role in Ensuring Program SuccessWHPacific works to keep the Compliance Program successful by:

    1. Training

    Providing yearly training on the Code for all employees. Requiring managers and employees with signature authority to complete annual training on laws and regulations

    governing the services WHPacific provides its clients with an emphasis on federal government contracting issues.

    Code of Business Ethics and Conduct Policy Statement

    It is WHPacific, Inc.s policy to:

    Conduct business according to high ethical and legal standards;

    Insist that employees avoid business activities and situations that may createor appear to createan appearance of impropriety;

    Maintain accurate and reliable corporate records in accordance with generally accepted accounting principles and practices and other appropriate internal controls; and

    Engage in business activities in an ethical manner and in accordance with applicable laws and regulations.

    mailto:jcobb%40whpacific.com?subject=Email

  • Page 3

    2. Hiring

    Not knowingly allowing someone who has engaged in unethical conduct to act as a principal for the Company. Principal includes anyone authorized to represent WHPacific before current or potential clientsnot just officers or senior managers.

    Not knowingly hiringwhether as an employee or a contractoranyone who is suspended or debarred by any agency of the federal government, or who otherwise is not eligible to participate in federal programs.

    3. Employee Resources

    Maintaining a secure, confidential resource that all employees can use to report unethical behavior or other employee concerns (see the highlighted area below).

    Investigating possible violations of Company policies, standards, procedures, or the Code.

    Prohibiting any retaliatory action against employees who report violations or suspected violations of Company policies, standards, procedures, or the Code. Employees determined to have engaged in retaliatory behavior will be subject to disciplinary action up to and including termination without notice.

    Providing a safe and healthy work environment for our employees, clients, and visitors, and complying with applicable federal, state, and local health and safety laws and regulations.

    The Employees Role in Ensuring Program Success

    Duty to Report Actual or Suspected Violations

    Regardless of your position with the Company, if you have information about or knowledge of any actual or contemplated conduct or transaction that appears to violate the Companys Code, policies, standards, or procedures, you are required to report the matter promptly to your supervisor or manager, the Human Resources department, any member of WHPacific management (including any member of the senior leadership team), or the Compliance Officer. You can make such reports in person, by telephone, or in writing (including email). Requests for anonymity from reporting employees will be honored to the extent reasonably possible, but anonymity cannot be guaranteed.

    If you want to remain anonymous, you may report the concern using Report It, our anonymous reporting hotline. When using Report It, employees are asked to provide sufficient detailed information so as to enable adequate investigation. Anonymous reporters should also realize that their anonymity makes providing follow-up to them unlikely.

    Employee Support

    WHPacific recognizes that employees must have access to reliable, predictable, and supportive resources that help them comply with the Code. Thats why WHPacific provides:

    An open door policy that gives every employee access to higher levels of management;

    A work environment that expressly prohibits retaliation and retribution, discrimination, and harassment of any kind;

    Mandatory harassment training for every employee; and

    A third-party hotline and web site named Report It, where employees can anonymously communicate concerns to senior management (1-877-778-5463 or www.reportit.net (user name: whpacific; password: welcome).

    To report a concern, issue, or suspected Code or policy violation, you can do any of the following:

    Talk to your supervisor Talk to a member of Human Resources Talk to any WHPacific senior manager Use Report It:

    (1-877-778-5463 or www.reportit.net (user name: whpacific; password: welcome).

    http://www.reportit.nethttp://www.reportit.net

  • Page 4

    Guidelines for Doing BusinessEmployees are expected to exercise good judgment and maintain high ethical standards and personal integrity while conducting business on behalf of the Company, including while they are traveling on Company business.

    Accounting PracticesWHPacifics operations must be accounted for and recorded in accordance with legal requirements and Generally Accepted Accounting Principles (GAAP). The integrity of the Companys accounting is based on the validity, accuracy, and completeness of its systems and records. Every employeeregardless of positionwho is involved in creating, processing, or recording accounting information for WHPacific is responsible for the integrity of that information.

    No false or intentionally misleading entries may be made in the

    Companys systems, records, or related documentation.

    Reporting PracticesIf employees are asked for information during audits (internal and external) or by the Companys accounting team or legal counsel, they must provide complete and accurate information. No one in the Company may conceal information that is necessary for the preparation of accurate books, records, accounts, and financial statements.

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