Effective Date: January  06, 2023

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Introduction

Carroll International, a veteran-owned small business specializing in SATCOM equipment, cybersecurity solutions, and innovative technologies like the Blue Sky Mast, is committed to conducting business with integrity, transparency, and compliance with all applicable laws and regulations. As a federal contractor, we align our operations with the highest ethical standards to maintain trust with our employees, partners, clients—including the U.S. Department of Veterans Affairs (VA)—and the communities we serve. These Standards of Business Ethics and Conduct (“Standards”) apply to all employees, officers, directors, and representatives of Carroll International.

 

Purpose

The purpose of these Standards is to:

• Promote honest and ethical conduct in all business dealings.

• Ensure compliance with federal laws, regulations, and contractual obligations.

• Deter wrongdoing and foster a culture of accountability.

• Provide guidance for ethical decision-making in support of our mission to deliver innovative solutions.

 

Core Principles

Our Standards are built on the following principles, inspired by federal ethics guidelines and our veteran-owned values:

1. Integrity: We act honestly, fairly, and responsibly in all interactions.

2. Compliance: We adhere to all applicable federal, state, and local laws, including those governing federal contracts.

3. Transparency: We maintain accurate records and disclose information as required by law or contract.

4. Respect: We treat colleagues, clients, and partners with dignity and fairness, free from discrimination or harassment.

5. Public Trust: We prioritize the interests of our clients, especially government entities, above personal gain.

 

Standards of Conduct

1. Compliance with Laws and Regulations

   • Employees must comply with all federal laws, including the False Claims Act, Anti-Kickback Act, and Procurement Integrity Act, as well as regulations like the Federal Acquisition Regulation (FAR).

   • Violations of law or these Standards may result in disciplinary action, up to and including termination, and potential legal consequences.

2. Conflicts of Interest

   • Employees must avoid situations where personal interests conflict with Carroll International’s or our clients’ interests.

   • Disclose any financial interest, outside employment, or relationship that could influence your duties to a supervisor or the Ethics Officer immediately.

   • Example: An employee negotiating a contract must not have a financial stake in the vendor’s company.

3. Gifts, Gratuities, and Bribery

   • Employees may not solicit or accept gifts, entertainment, or favors from individuals or entities seeking business with Carroll International, except as permitted under 5 CFR 2635 Subpart B (e.g., items of nominal value under $20, not cash).

   • Offering or accepting bribes or kickbacks is strictly prohibited and violates federal law (18 U.S.C. § 201).

   • Report any gift offers exceeding nominal value to the Ethics Officer.

4. Confidentiality and Data Protection

   • Protect sensitive information, including client data, proprietary business details, and government-related information, in accordance with federal cybersecurity standards and contract terms.

   • Do not disclose confidential information without authorization.

5. Accurate Records and Reporting

   • Maintain truthful and complete records, including financial reports, contract documentation, and timekeeping, as required by federal standards (e.g., FAR 4.7).

   • Falsification of records is prohibited and may lead to civil or criminal penalties under the False Claims Act.

6. Fair Competition

   • Engage in fair and lawful competition. Do not share pricing or bid information with competitors, in compliance with antitrust laws.

   • Use only lawful means to gather competitive intelligence.

7. Government Contracts

   • Adhere to all terms of federal contracts, including those with the VA and other agencies.

   • Employees involved in government work must complete mandatory ethics training within 30 days of assignment and annually thereafter.

   • Report suspected fraud, waste, or abuse in government contracts to the Ethics Officer or via the anonymous hotline.

8. Workplace Conduct

   • Maintain a workplace free of harassment, discrimination, or retaliation, consistent with Equal Employment Opportunity laws and VA contractor requirements.

   • Use company property and resources only for authorized business purposes.

 

Reporting and Accountability

• Duty to Report: Employees must promptly report violations of these Standards, illegal activities, or unethical behavior to their supervisor, the Ethics Officer, or through our anonymous reporting line: [Insert Phone Number or Email].

• No Retaliation: Carroll International prohibits retaliation against anyone who reports concerns in good faith.

• Investigation: All reports will be investigated promptly and confidentially, with corrective action taken as needed.

 

Training and Compliance

• All employees must complete initial ethics training within 30 days of hire and annual refreshers.

• Supervisors are responsible for ensuring their teams understand and follow these Standards.

 

Contact

For questions or to report concerns, contact:

Byron Carroll
President / Ethics Officer
Carroll International
bcarroll@carrollintl.com
910-377-2441
www.carrollintl.com/ethics