Ethics & Conduct

Our Code of Ethics & Business Conduct applies to all associates at J. J. Keller & Associates, Inc. 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 associates 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 anonymously or by name, using the link below. All reports will be taken seriously and investigated thoroughly.

To ask a question or report a concern, email ethics@jjkeller.com
  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 the policy of the company 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 in the implementation of 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 every associate is 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 policy applies to harassment whether it occurs on our premises or in some other location where a company activity occurs, such as at a customer’s site or at a company function. It covers all associates of the company, male and female, as well as applicants for employment.

      This policy covers unlawful discriminatory harassment by associates and also non-associates, such as customers or clients, vendors, contractors, temporary workers or visitors who harass associates to the extent that it affects the work environment or interferes with the performance of work.

    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 on our premises, and in all environments where company functions, business travel, and other work-related activities are performed, unless the weapons are properly secured in a vehicle. These prohibited weapons include firearms, weapons accessories and dangerous substances.

    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. Associates must comply with all J. J. Keller safety and security requirements, whether established by management or by federal, state and local laws. Accordingly, associates 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 associates and those who engage, or seek to engage, in business with the company. We also prohibit working on behalf of the company 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 associates are responsible for ensuring that J. J. Keller’s records are properly managed, handled, stored and, where applicable, destroyed in accordance with retention guidelines. Associates are also required to properly maintain these records, to ensure that they are properly filed and labeled, and that access is 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 associates 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 associates 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 associates who submit inappropriate or fraudulent reimbursement requests.

    4. Records Retention & Legal Hold Procedures

      All business records at J. J. Keller, including but not limited to paper, electronically stored information, microfiche, tape, photographs, CD Rom, flash drive, and CAD, should be maintained and destroyed as required by company leadership and the law, and in accordance with any applicable retention schedule.

      From time to time, similar to many companies, J. J. Keller may be involved in a lawsuit. There are circumstances where the normal and routine destruction of records must be suspended, pursuant to federal and state requirements and J. J. Keller’s record retention schedules and policy. Present and future records that are involved in litigation, or reasonably anticipated in foreseeable legal action, must be preserved until the legal hold is released. In the event of threatened or pending litigation or government audit, the applicable department shall receive a "Legal Hold Notice." The department, in conjunction with J. J. Keller Records Management, will determine which records listed in the applicable Records Retention Schedule may be affected by the litigation or audit, in which case the department will suspend any destruction until the audit or litigation is completed.

    5. Associate Records

      J. J. Keller regards personal associate data as confidential and respects the need to protect each associate’s privacy. We also ensure that our practices comply with all applicable federal, state and local laws. Associates who handle associate records as part of their job are to handle, file and distribute this data in a confidential manner. Access to personal information is limited to only those with clear business needs. All associate records are kept secure and confidential at all times.

    6. Accurate Timekeeping & Invoices

      J. J. Keller is committed to accurate timekeeping and invoicing. Associates working on a project must ensure their time records accurately reflect time worked and leave taken and that the time is attributed to the appropriate project. Time should be recorded consistently, regularly and promptly. Associates are obligated to immediately report errors they discover in timekeeping, whether it is their own error or the error of another associate.

  3. Use Of Company Assets For Electronic Communications & The Internet

    1. Limiting Use to Business Purposes

      All communications data and information sent or received using J. J. Keller equipment or assets is the property of J. J. Keller. Accordingly, we reserve the right to monitor all communications, including Internet usage, to ensure assets are used for their intended business purpose and in accordance with applicable laws and J. J. Keller policies.

  4. Conflicts Of Interest

    J. J. Keller promotes objectivity in business decision-making. Our associates 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 a J. J. Keller associate:

    • Accepts gifts or favors from a potential business partner
    • Accepts additional employment by another company
    • Has a financial interest in a business partner or competitor
    • Has a relative who works for a competitor
    • Places business with any firm where the associate or an immediate family member of the associate has a financial interest or is otherwise not impartial
    • Inappropriately communicates with a competitor

    It is each associate’s duty to disclose known or potential conflicts of interest within the company. Additionally, he or she must disclose any known or potential conflicts of interest on the Annual J. J. Keller Code of Ethics and Business Conduct form, which is part of annual training.

  5. Confidentiality Of Corporate Information

    Every associate must protect confidential information and trade secrets in the same manner that other company 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.

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

  6. Integrity In The Marketplace

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

    1. Relationships with Suppliers & Business Partners

      The company’s buying decisions must always be based on competitive price, quality, value and delivery. J. J. Keller wants associates to have friendly relationships with suppliers, consultants and other business partners; at the same time, associates 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 business communication by J. J. Keller will 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 associates 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, associates 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 associates or clients.

      Associates may accept reasonable and nominal entertainment at lunch, dinner, business meetings and social or charitable events with customers/clients and business partners. However, J. J. Keller associates 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
      • Participating in any activity the associate knows or should know will cause the party offering the entertainment to violate any law, rule, regulation or the ethical standards of their own employer
  7. Integrity In Government Relationships

    J. J. Keller conducts business with the federal government, government agencies and state governments in a manner that is fully compliant with all applicable laws and regulations. J. J. Keller associates 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.

    J. J. Keller associates 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, associates 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. Associates also should 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 associates must comply with certain restrictions on communications with their former agencies.

    2. Entertainment or Gifts for Government Officials

      J. J. Keller associates are prohibited from offering gifts, gratuities or non-business-related entertainment for the personal use of associates 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 company-sanctioned gifts of a token nature with the J. J. Keller company logo. These gifts typically include coffee mugs, pens and bags. Modest refreshments offered on an occasional basis, in conjunction with business activities, are acceptable. 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

      Associates 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. Associates 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. It is J. J. Keller’s policy that all subcontractors, vendors and consultants comply with J. J. Keller’s Code of Ethics and Business Conduct in doing business with the company. Associates, likewise, are responsible for assessing the integrity of any subcontractor, vendor, supplier or consultant with which J. J. Keller likely will do business. Once an agreement has been executed, the responsible associate should monitor the conduct of the subcontractor, vendor, supplier or consultant to ensure they are complying with J. J. Keller’s 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, J. J. Keller associates are encouraged to discuss with our Compliance Officer any suspected improper or questionable conduct, including bribery or other fraudulent activity, of any J. J. Keller associate or any J. J. Keller subcontractor, vendor, supplier or consultant working on a government project.

  8. Compliance With Laws

    J. J. Keller is committed to complying with all applicable federal, state and local laws. Some of the laws that are more pertinent to J. J. Keller are discussed below.

    1. Competitive Intelligence

      J. J. Keller requires associates to comply with all applicable laws in acquiring competitive intelligence. Associates must respect the confidentiality of competitors’ information and must not misrepresent who they are or where they work in obtaining such information.

    2. Antitrust

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

  9. Communications With External Entities

    All requests for interviews or comments by national and local media shall be handled by J. J. Keller’s media contacts.