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Ethics & Conduct

Our Code of Ethics & Business Conduct (our “Code”) applies to all J. J. Keller & Associates, Inc. (“J. J. Keller” or “we,” “us” or “our”) employees, officers, temporary employees and volunteers (collectively, our “personnel”). In addition, we seek, with intention, business partners – clients/customers, contractors, vendors and suppliers – who share our commitment to these principles.

Reporting a Concern

We encourage our personnel and others to ask questions about our Code and report concerns they may have about violations or potential violations of the Code. This can be done by emailing All reports will be taken seriously and investigated thoroughly.

  1. Maintaining A Secure Work Environment

    J. J. Keller is committed to providing a healthy, safe and secure work environment.

    1. Equal Employment Opportunity

      It is our policy to provide equal employment opportunity to all individuals regardless of their race, color, religion, sex, sexual orientation, gender identity, national origin, age, disability, veteran status, marital status, military status or any other characteristic protected under state or federal law. We support and cooperate fully to comply with applicable laws and executive orders in all of our employment policies, practices and decisions. J. J. Keller is strongly committed to this policy and believes in the concept and spirit of the law.

    2. Harassment-Free Workplace

      At J. J. Keller, we believe that all personnel are entitled to respect, regardless of race, color, religion, sex, sexual orientation, gender identity, national origin, age, disability, veteran status, marital status, military status or any other characteristic protected under state or federal law. Therefore, we won’t tolerate inappropriate workplace behavior or harassment, including sexual harassment.

      This applies to harassment whether it occurs on our premises or in some other location where a J. J. Keller activity occurs, such as at a customer’s site or at a J. J. Keller function. It covers all personnel, regardless of gender, as well as applicants for employment.

      This also covers unlawful discriminatory harassment by personnel and non-personnel, such as customers or clients, vendors, contractors, temporary workers or visitors who harass our personnel.

    3. Violence-Free Workplace

      J. J. Keller will not tolerate workplace violence in any form, including threatening behaviors, assaults, harassment, intimidation, bullying, taunting, teasing or any other conduct that leads to violence in the workplace. Additionally, subject to applicable laws, we prohibit possession of dangerous weapons in our facilities except certified and authorized security personnel.

    4. Safety, Security & Environmental Stewardship

      J. J. Keller is committed to environmental, health and safety (EHS) excellence. We strive to provide a safe and healthy working environment and to avoid adverse impact and injury to the environment and the communities where we do business. Personnel must comply with all J. J. Keller safety and security requirements, whether established by management or by federal, state and local laws. Accordingly, personnel are expected to conduct themselves in a safe manner, use good judgment and common sense in matters of safety and environmental stewardship, observe all posted safety rules, and follow all Occupational, Safety and Health Administration (OSHA), state and local safety regulations.

    5. Drug- and Alcohol Abuse-Free Workplace & Workforce

      J. J. Keller maintains a drug- and alcohol-free workplace. We prohibit the use, possession, consumption, manufacture, distribution and sale of controlled substances (including look-a-like substances), illegally used drugs and/or alcohol in the workplace by our personnel and those who engage, or seek to engage, in business with J. J. Keller. We also prohibit working on behalf of J. J. Keller while under the influence of these substances in excess of established threshold levels, including during breaks and meal periods.

  2. Maintaining Accurate & Complete Records

    J. J. Keller strives to maintain accurate business records. We’re committed to a system of internal controls that ensures compliance with laws and regulations, and that promotes the full, accurate and timely disclosure of information in J. J. Keller’s reporting to internal management, the Board of Directors, external auditors and external parties including regulatory and governmental authorities.

    1. Company Records

      All J. J. Keller records must be properly managed, handled, stored and, where applicable, destroyed in accordance with retention guidelines. Additionally, all J. J. Keller records must be properly maintained, filed and labeled and access must be limited to those with a business need to access the records.

    2. Financial Reporting

      J. J. Keller maintains accurate financial records of business transactions and ensures proper reporting to auditors of its financial results. To the extent that personnel create, handle or are otherwise involved in handling financial records, they must ensure that the records are accurate, properly maintained and appropriately represented.

    3. Travel & Entertainment Expense Reimbursement

      J. J. Keller reimburses personnel for approved expenses incurred as a direct result of their job responsibilities. Reimbursement requests that are inaccurate, inflated or based on fictitious expenses will be considered fraudulent. J. J. Keller has zero tolerance for personnel who submit inappropriate or fraudulent reimbursement requests.

    4. Records Retention & Legal Hold Procedures

      All J. J. Keller records, regardless of their format (e.g., paper, electronically stored information, microfiche, tape, photographs, CD Rom, flash drive, and CAD), must be maintained and destroyed in accordance with legal requirements and applicable policies.

  3. Conflicts Of Interest

    J. J. Keller promotes objectivity in business decision-making. Our personnel are expected to exercise business judgment independent of external influences such as personal financial interests, personal relationships, external business relationships and outside employment. Avoiding conflicts of interest is critical to maintaining integrity and honesty in the way J. J. Keller conducts business. Potential conflicts of interest can arise when personnel:

    • Accept gifts or favors from a potential business partner
    • Accept additional employment by another company
    • Have a financial interest in a business partner or competitor
    • Have an immediate family member who works for a competitor
    • Place business with any firm where they or an immediate family have a financial interest
    • Inappropriately communicate with a competitor

    All personnel have a duty to disclose known or potential conflicts of interest within J. J. Keller that they are personally aware of.

  4. Confidentiality Of Corporate Information

    Personnel must protect confidential information and trade secrets in the same manner that other J. J. Keller assets are secured. Confidential information must be held in the strictest confidence, and reasonable care should be used in dealing with such information to avoid improper disclosure.

    Personnel are not to disclose confidential information to anyone outside of J. J. Keller, even to members of their own family, unless there is a clear business need for the disclosure. Any inquiries from outside sources that claim a "need to know" should be referred to a member of the J. J. Keller Executive Leadership Team.

  5. Integrity In The Marketplace

    J. J. Keller strives to conduct business with clients and competitors with complete honesty and integrity. Personnel shall not engage in bribery or any other fraudulent activity. J. J. Keller expects all personnel to eagerly serve clients and compete with competitors in a professional and ethical manner.

    1. Relationships with Suppliers & Business Partners

      J. J. Keller’s buying decisions must always be based on competitive price, quality, value and delivery. J. J. Keller wants personnel to have friendly relationships with suppliers, consultants and other business partners; at the same time, personnel must be open, honest, business-like and completely ethical.

      Confidential information, such as bids submitted to J. J. Keller for the purchase of equipment, supplies, and services, must be maintained in strictest confidence in order to avoid giving competitive advantage to any supplier. Disclosure of such information is unethical.

    2. Truth of Statements in Advertising

      All J. J. Keller communications must be factual, in good taste and free from false or exaggerated claims or statements. This includes business correspondence, advertisements and sales promotion materials, newsletters and news releases, social media and any other communication prepared for internal or external use.

    3. Gifts

      It is important that personnel decline gifts that would raise even the slightest doubt of improper influence. A "gift" refers to the transfer of any item of value, including goods and services, without compensation. As a general rule, personnel must not accept gifts of more than $50 in value from customers or suppliers. Frequent gifts from the same party, including those below $50 in value, may also be considered a potential conflict of interest. Under no circumstances should cash or cash equivalents be accepted as a business courtesy or gratuity.

    4. Entertainment

      J. J. Keller prohibits entertainment activities that compromise the business judgment, impartiality or loyalty of personnel or clients.

      Personnel may accept reasonable and nominal entertainment at lunch, dinner, business meetings and social or charitable events with customers/clients and business partners. However, personnel must decline:

      • Entertainment offered as part of an agreement to do, or not do, something in return for the activity
      • Entertainment offered that might compromise J. J. Keller’s reputation or ethical standards
      • To participate in any activity they know, or should know, will cause the party offering the activity to violate any law, rule, regulation or the ethical standards of their own employer
  6. Integrity In Government Relationships

    J. J. Keller conducts business with the federal government, government agencies and state governments in a manner that complies with all applicable laws and regulations. Personnel must be aware of and adhere to the laws and regulations that pertain to doing business with federal and state governments. These laws and regulations generally have three purposes: to obtain the best possible products and services at the best value; to promote full and open competition based on specifications and evaluation criteria that allow interested suppliers to respond appropriately; and to eliminate waste, fraud and abuse.

    Personnel must comply with all rules established by government officials for procuring products and services. This includes, but is not limited to, dealing with government officials in an environment of openness and under circumstances that contradict any perception of concealment, the appearance of impropriety, or any actual or potential conflict of interest. The laws and regulations applicable to government contractors apply both when J. J. Keller is acting as a prime contractor and when J. J. Keller is acting as a subcontractor at any tier. Consultants and subcontractors who are hired by J. J. Keller to perform work related to a government contract or subcontract must also adhere to government contracting rules and regulations.

    1. Contacts with Government Officials

      J. J. Keller strives to develop and maintain good relationships and effective communication with all levels of federal and state governments. Contacts with government officials must never be conducted in a way that would violate applicable laws and regulations or could cast doubt on J. J. Keller’s integrity. For example, personnel are prohibited by federal law from soliciting, obtaining or disclosing contractor bid and proposal or other proprietary or confidential information, such as source selection information, from agency officials during the course of a competition. Personnel should also avoid employment discussions with current or former U.S. government personnel involved in competitions in which J. J. Keller has an interest. Former government employees who are now personnel must comply with certain restrictions on communications with their former agencies.

    2. Entertainment or Gifts for Government Officials

      Personnel are prohibited from offering gifts, gratuities or non-business-related entertainment for the personal use of employees or officials of any government agency to which J. J. Keller is seeking to sell or is selling goods or services. The only exceptions to this rule are:

      • J. J. Keller-sanctioned gifts of a token nature with the J. J. Keller company logo, such as coffee mugs, pens and bags.
      • Modest refreshments offered on an occasional basis, in conjunction with business activities.

      If an associate works with representatives of a federal agency, the associate is responsible for complying with that agency’s standards of conduct.

    3. Associate Political Involvement

      Personnel are encouraged to be involved in the political process as private individuals, and they are free to express their political views and support candidates of their choice. Personnel are prohibited, however, from speaking on political matters on J. J. Keller’s behalf.

    4. Relationships with Subcontractors, Vendors & Suppliers

      Many of the laws and regulations that apply to J. J. Keller as a government contractor or subcontractor on a government project also flow down to J. J. Keller’s subcontractors, vendors, suppliers and consultants working on the same project. All such subcontractors, vendors and consultants must comply with applicable portions of this Code when working on any such project. Personnel, likewise, are responsible for assessing the integrity of any subcontractor, vendor, supplier or consultant with which J. J. Keller likely will do business as a government contractor or subcontractor on a government project. Once an agreement has been executed, the responsible personnel should monitor the conduct of the subcontractor, vendor, supplier or consultant to ensure they are complying with the applicable portions of this Code and any other applicable J. J. Keller standards of integrity and business conduct.

    5. Mandatory Disclosure

      Federal law requires the federal government to suspend or debar a government contractor from contracting with the federal government if the contractor fails to disclose information related to a government contract or subcontract involving fraud, conflict of interest, bribery, overpayment or impermissible gratuities. Accordingly, personnel are encouraged to discuss with our Compliance Officer any suspected improper or questionable conduct, including bribery or other fraudulent activity, of any personnel or any J. J. Keller subcontractor, vendor, supplier or consultant working on a government project.

  7. Antitrust

    J. J. Keller is committed to upholding federal and state antitrust laws, which exist to promote vigorous competition and open markets. Personnel are prohibited from making false statements about competitors or their products or services and from illegally obtaining a competitor’s confidential information. Personnel are forbidden from engaging in coordinated pricing activities with competitors.