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POLICIES & GUIDELINES

As a company dedicated to continuous improvement, we are continually updating our Ethics & Business Conduct policies, which supplement our Code of Conduct and outline the responsibilities of the company at all levels to promote quality, safety, and an ethical culture. Copies of our policies are available upon request.

Acuity’s operations and personnel must comply with established international standards of law, respect for human rights, and fundamental freedoms. Our policy is to insist that every employee, operation, and business process be aligned and in compliance with accepted international standards for law, human rights, and ethical value systems.

Anti-corruption laws such as the United States’ Foreign Corrupt Practices Act generally prohibit payment or offers of even small amounts to government officials. Acuity’s policy considers non-compliance with applicable anti-corruption laws to be a breach of our Code of Conduct, resulting in employee discipline—up to, and including, termination.

This policy describes common forms of conflict of interest, providing requirements and guidance for employees (including executive officers and directors), consultants, and subcontractors. This ensures that Acuity’s business transactions are conducted in accordance with the law and that our reputation for honesty and integrity is not compromised.

Acuity is committed to environmental stewardship across all company operations. We conduct our business in a manner that: protects the environment by respecting air, water, and land resources; uses energy and materials efficiently; and supports conservation programs. This policy establishes our environmental principles, including our commitment to the prevention of negative environmental impacts as a consequence of our work performance.

This policy sets forth Acuity’s commitment to maintaining the highest standards of business conduct and procurement integrity by our employees engaged in the procurement process. It provides Acuity personnel with direction and guidance in the conduct of all procurement operations. All suppliers must comply with the Supplier Code of Conduct or its own policies and procedures that comply with federal acquisition regulations.

Before engaging with an entity or providing any hardware, software, or technical data or services, Acuity screens that entity to ensure full compliance with laws and regulations of the countries where we do business. We screen for possible restricted parties, proliferation activities, risk of diversion of unauthorized users or uses, military end users, and activities related to certain foreign boycotts.

This policy prohibits export, re-export (whether consisting of a product, information, or service), or any transaction that is contrary to law, regulation, or Acuity’s policies or procedures governing international transactions. Our Export Control Compliance Officer is responsible for implementation, oversight, and maintenance of this policy to ensure Acuity fully complies with the export laws and regulations in every country where we conduct business.

The purpose of this policy is to outline Acuity’s guiding principles that demonstrate our commitment to organizational excellence and customer service. The focus of this policy is to maintain quality through continuous improvement and risk management, using an integrated management system that provides a framework for measuring and improving performance.

Acuity is committed to delivering high-quality services in a manner that actively manages risk, prevents accidents, and ensures the safety of our employees, contractors, and the public. This policy presents the occupational safety and health tenents that guide our operations, including a recognition that it is better to implement measures to prevent an injury than respond to it.

The Acuity Risk Management Plan identifies areas that may have a negative impact on our overall strategic direction and drives decisions that mitigate these identified risks, detect misconduct, and remove potential barriers to success.

Acuity International is an Equal Employment Opportunity (EEO) employer dedicated to fostering a workplace that values diversity, equity, and inclusion. We embrace the principles of EEO and strive to provide a fair and inclusive environment for all employees, regardless of race, color, religion, sex, sexual orientation, gender identity, national origin, disability, veteran status, or any other characteristic protected by applicable law. Our commitment to EEO extends to all aspects of employment, including recruitment, hiring, training, promotions, and compensation. We believe that a diverse and inclusive workforce not only enhances our organizational culture but also drives innovation and success. Acuity International is dedicated to creating a workplace where every individual feels respected, valued, and has the opportunity to contribute to our collective success.

Acuity International is committed to complying with all laws, regulations, contract terms, and other requirements to respect whistleblower rights and protect its employees from employment discrimination and reprisal, in keeping with United States law, the Federal Acquisition Regulation, and international standards.

Acuity is committed to sustaining a working environment where employees and other individual stakeholders are comfortable raising ethics and compliance questions and concerns internally with management, Human Resources, company counsel, or the Office of Ethics and Business Conduct. Under Acuity’s Code of Conduct and Acuity’s Anti-Retaliation Protections and Reporting Policy (ACU-EC-PO-003), employees are required to report concerns involving an actual or suspected compliance, legal, or ethical infraction related in any way to Acuity’s business operations. Employee reporting allows Acuity to respond to perceived and real concerns and to take appropriate corrective action, including individual disciplinary action and changing practices, policies, and procedures, where appropriate.

Acuity has an employee hotline managed by an independent third-party vendor, permitting toll-free telephone and web-based reporting 24/7 from anywhere in the world. Every communication using the hotline is handled promptly, discreetly, confidentially, and professionally. Acuity’s system allows reporters to remain anonymous, if they choose, and still communicate with investigators on the status of their report or inquiry.

All ethics and compliance reports and inquiries are consistently and promptly handled, processed, and tracked. Acuity’s Chief Compliance Officer is responsible for reviewing and responding to all inquiries and reports with the assistance of other company departments and designated Compliance Officers and professionals. The company takes appropriate corrective action where improper practices are found.

Also under Acuity’s Anti-Retaliation Protections and Reporting Policy, all employees are prohibited from threatening, punishing, or retaliating against anyone who, in good faith, reports a possible compliance issue or against anyone who cooperates in an investigation or engages in other conduct protected by law. Acuity will take appropriate action against any individual determined to be engaging in retaliatory conduct.

Our Office of Ethics & Business Conduct supports our businesses and employees in their efforts to uphold the highest ethical standards. Led by our Chief Compliance Officer, the office provides expert advice, training, and assistance in the areas of:

  • Ethics
  • Privacy
  • Export Controls

We encourage best practices while monitoring legal and regulatory compliance throughout all of Acuity’s business processes, and investigate reports of where we may have fallen short. The office strives to ensure every employee is aware of—and follows — Acuity’s Code of Conduct.