W e strongly believe that our blend of lñupiaq and business values uniquely combines to deliver

higher levels of performance and meaning. Our core values are the cornerstones of our success.
• Our lñupiaq Culture – Our culture is who we are and provides us with the guiding principles in our
everyday business practices, guaranteeing continuity of the lñupiaq culture across generations. Our
lñupiaq values include the following:

Aviktuaqatigiigñiq – Sharing
Iøagiigñiq – Family
Iñupiuraallaniq – Knowledge of Language
Aÿuniallaniq – Hunting Traditions
Qiksiksrautiqaåniq Iñuuniaåvigmun – Respect for Nature
Qiñuiññiq – Humility
Nagliktuutiqaåniq – Compassion
Atisiñiaånikun – Resolution of Conflict
Piqpakkutiqaåniq suli qiksiksrautiqaåniq utuqqanaanun allanullu – Love and Respect
for Our Elders and One Another
Paammaaåigñiq – Cooperation
Ukpiqqutiqaåniq – Spirituality
Quvianåuniq – Humor

• Stewardship – We will employ financial discipline when managing our lands and assets to ensure
that increases in business performance and shareholder returns are sustainable.
• Integrity – We will do what we say we will do. We will adhere to high moral principles and
professional standards and operate with transparency and accountability.
• High Performance – We will achieve superior business results and stretch our capabilities to reach
even higher levels.
• Our Relationships – We will develop and maintain relationships that focus on the creation of value
for all participants.
• Respect for Each Other – We will embrace and respect the cultural diversity of our organization
through sharing and team building for continued trust and connection.
• Resolution of Conflict – While respecting our differences, we will deal with the inherent tension in
our decision-making process, strengthening our partnerships. n

From the Arctic Slope Regional Corporation 2007–2012 Strategic Plan

Photo source: asc-anc-file.corp.ad.asrc.com\asrc\External Affairs\Library\Photos

FN-002, Standards of Ethics and Business Conduct Policy

TABLe OF COnTenTs
1.0 Purpose.....................................................................................................................................................................1
2.0 Policy ........................................................................................................................................................................1
Responsibility/Accountability ...............................................................................................................................1
Obligation of Employees to Report Violations of Standards ............................................................................2
Company and Employee Commitments ..............................................................................................................2
False Information and Employment......................................................................................................................3
Drug-Free Workplace Act Compliance.................................................................................................................3
ASRC Federal Workplace Environment ...............................................................................................................4
Employee Dispute Resolution ................................................................................................................................4
Timekeeping Policy..................................................................................................................................................5
Use and Protection of Government Furnished Property ...................................................................................5
Use and Protection of Company Assets ...............................................................................................................6
Use of Software.........................................................................................................................................................6
Use of Computing Resources .................................................................................................................................7
Communications Policy...........................................................................................................................................7
Protection of Intellectual Property, Trade Secrets, Proprietary Information..................................................8
Fiduciary Duty of the Employee............................................................................................................................9
Personal Conflicts of Interest..................................................................................................................................9
Strategic Planning Information ............................................................................................................................10
Regarding Gifts, Gratuities, and Entertainment................................................................................................11
Dealings with Suppliers, Vendors, Business Partners, and Competitors......................................................11
Reporting Material Developments and Complying with Internal Controls.................................................12
Interference with an Audit....................................................................................................................................12
Additional Policies Relating to U.S. Government Contracting.......................................................................12
Reference Documents................................................................................................................................................15
HR Manual Policies................................................................................................................................................15
ASRC Federal Policies and Procedures ..............................................................................................................15
ASRC Federal Forms..............................................................................................................................................16
Other.........................................................................................................................................................................16
Revision History.........................................................................................................................................................17
ASRC Federal Standard of Ethics and Business Conduct Certification Form ..............................................19

i Revised 10/28/10
FN-002, Standards of Ethics and Business Conduct Policy

1.0 PurPOse
This policy defines the standards of ethics and business conduct (the “Standards”) that apply to all officers
and employees of ASRC Federal Holding Company (the “Company”) and all its subsidiaries and business
units worldwide and to all business activities of ASRC Federal. To the extent that any portion of this policy
is inconsistent with any rights or obligations contained in a collective bargaining agreement (“CBA”), the
terms of the CBA shall govern.

2.0 POLICy
n Responsibility/Accountability
The Company’s business depends on its reputation for integrity, trust, and AsrC vALue
confidence. The Company is committed to the highest ethical standards and values
Our Iñupiaq
in the way we conduct business. We are equally committed to complying with all Culture – Our
applicable laws and regulations in each Federal, state, and local jurisdiction in which culture guides us
we operate. in our ethics and
everyday business
It is the personal responsibility of each employee to read, understand and comply
practices and helps
with the Standard, and to diligently comply with this and other ASRC Federal bring our past into
policies and procedures. All employees must promptly direct any questions regarding our future.
specific policies to their immediate manager or higher-level manager. Employees
will be required to certify their understanding of this Standard on an annual basis. The Company will
implement a system that collects these certifications and ensures they are current. Failure to certify
understanding of or failure to comply with this Standard shall be grounds for disciplinary action, up to and
including termination of employment.
• All employees are responsible for upholding their individual reputations and AsrC vALue
that of the Company.
Integrity – We will
• All employees are responsible for ensuring that their own conduct, as well as do what we say we
the conduct of those who report to them, is honest and ethical under all will do. We will
circumstances and fully complies with our policies and these Standards. adhere to high
• All employees are expected to embrace and follow the Standards described in moral principles
and professional
this policy.
standards and
• All employees must take seriously the responsibility to stay knowledgeable operate with
about these Standards and attend training when offered. transparency and
• All employees are expected to be alert to and recognize potential violations of accountability.
these Standards.
• All employees are required to cooperate with investigations of potential non-compliance with these
Standards.

The information contained in this document is Company proprietary and shall not be duplicated, used, or disclosed, in whole or in part, for any purpose other than to provide
internal ASRC Federal and Subsidiary policy guidance.

1 Revised 10/28/10
 FN-002, Standards of Ethics and Business Conduct Policy

Because our reputation for high ethical standards and quality work is so important, violations of the
Standards will be basis for disciplinary or corrective action.

n Obligation of Employees to Report Violations of Standards

All employees are obligated to report internally all suspected violations of these Standards. Every employee
has a duty to report observed, discovered, or suspected non-compliance with applicable rules and regulations
to their management, the Director of Compliance, the Vice President of Human Resources, Corporate
Counsel, or another member of executive management. Such reports will be investigated promptly, with due
respect for the rights and privacy of all who may be involved in such an investigation.
All Employees who in good faith report suspected violations or other wrongdoing will be protected from
retaliation. No employee will be permitted to take any retaliatory action against any other employee who
reports suspected violations or wrongdoing.
The Company also maintains an Ethics Hotline, available at (877) 442-0831, to which employees can report
any suspected violations of the laws, regulations, and compliance requirements embodied in these
Standards. The Ethics Hotline is run by a third-party provider. Employees may call anonymously.
• Subcontractors and Suppliers
Pursuant to the requirements of the Company’s contracts containing FAR clauses 52.203-13, and
52.203-14, the Company’s Procurement Department will ensure that these clauses will be flowed
down to subcontractors and suppliers as required.
• Company Obligation to Report Violations of Standards
Pursuant to the requirements of the Company’s contracts containing FAR clause 52.203-13, the
Company shall timely disclose, in writing, to the Government, whenever the Company has credible
evidence that a principal, employee, agent, or subcontractor has committed—

(A) A violation of Federal criminal law involving fraud, conflict of interest, bribery, or gratuity
violations found in Title 18 of the United States Code; or

(B) A violation of the civil False Claims Act (31 U.S.C. 3729-3733).

n Company and Employee Commitments

The Company-Employee relationship is based in part on each party’s willingness to uphold certain commonly
agreed upon tenets as outlined more fully in the Code of Employer-Employee Relations (HR-104) in the Human
Resources (HR) Manual. While the Company’s commitments are covered briefly within these Standards, the
Company’s expectations for its employees are most fully expressed in the HR Manual, and can be summed up
as follows:
• To deal with customers, suppliers and coworkers in a professional manner;

The information contained in this document is Company proprietary and shall not be duplicated, used, or disclosed, in whole or in part, for any purpose other than to provide
internal ASRC Federal and Subsidiary policy guidance.

Revised 10/28/10 2
FN-002, Standards of Ethics and Business Conduct Policy

• To perform assigned tasks efficiently;

• To be punctual;
• To demonstrate a considerate, positive and constructive attitude toward fellow employees;
• To adhere to the policies adopted by the Company; and
• To protect the interests, reputation, and integrity of the Company and its employees at all times.

n False Information and Employment

If at any time the Company learns that an employee intentionally provided false or misleading information, or
intentionally omitted pertinent information regarding essential background, employment history, credentials
or qualifications for employment, the Company may take appropriate disciplinary or corrective action,
including changing the employee’s status or assignment, reducing the employee’s compensation, or
suspending or terminating the employee.

n Drug-Free Workplace Act Compliance

Our policy has been established to provide the Company’s employees with a safe, healthy and productive
working environment free of the problems associated with the use and abuse of controlled substances or
alcohol. The use of any controlled substances or the abuse of alcohol is inconsistent with the behavior expected
of our employees. Thus the Company has implemented the Anti-Drug and Alcohol Program policy (SF-001A).
This policy, along with all other policies and manuals referenced herein, can be found on the Company portal
using the “Policy and Procedure” (P&P) link. Under this policy, various conduct is permitted while other
types of conduct are prohibited (including but not limited to: the use, distribution, sale or
possession of unlawful drugs or controlled substances or alcohol) and if a violation occurs, an employee will
be terminated or the employment offer will be rescinded and the individual will not be hired. Furthermore,
upon hire, under applicable non-DOT Drug and Alcohol testing policies, any information relating to violations
(past and future) may be shared with any company within the ASRC family. In no event should any employee
be under the influence of alcohol, illegal drugs or controlled substances while on duty at a Company work-
place. For the purpose of these Standards, “Company Working Premises” is defined as: including all property,
facilities, land, buildings, structures, fixtures, (including lockers and other storage areas), automobiles,
trucks and all other vehicles (including vessels), whether owned, leased or used by the Company (or on
behalf it its clients); and includes all other work locations and modes of transportation to and from those
locations with in the course and scope of Company employment.
The Anti-Drug and Alcohol Program policy also references numerous ASRC Corporate and AFHC policies
which the Company follows:
• Non-DOT Substance Abuse and Misuse Prevention Policy (applies to all Employees at AFHC and Subsidiaries);
• DOE Drug and Alcohol Program Policy (addendum to the Non-DOT Policy);

The information contained in this document is Company proprietary and shall not be duplicated, used, or disclosed, in whole or in part, for any purpose other than to provide
internal ASRC Federal and Subsidiary policy guidance.

3 Revised 10/28/10
 FN-002, Standards of Ethics and Business Conduct Policy

• DOT/FMCSA Controlled Substances and Alcohol Use and Testing Policy (Drivers);
• DOT/USCG Chemical (Drug and Alcohol) Testing Program Policy (Coast Guard).
Where a specific subsidiary engages in a government contract requiring additional/different procedures for
testing, the Company’s Human Resources Department will work with the ASRC Drug and Alcohol Manager
to coordinate and implement those requirements.

n ASRC Federal Workplace Environment

ASRC Federal is committed to identifying capable staff to fill our workforce and providing them with the
opportunities to prosper without regard to their race, color, religion, gender, age, national origin, citizenship
status, sexual orientation, physical or mental disability, marital or veteran status, or any other protected status.
Our policy is to provide a work environment free from all forms of discrimination and harassment, including
sexual harassment. Harassment is a form of misconduct that undermines the integrity AsrC vALue
of the employment relationship. No employee should be subjected to unsolicited
respect for each
and unwelcome overtures or conduct, either verbal or physical. Harassment refers
Other – We will
to behavior that a reasonable person would consider unwelcome or personally embrace and
offensive, or behavior that lowers morale and interferes with work effectiveness. respect the cultural
Harassment does not refer to the occasional compliments of a socially acceptable diversity of our
nature. organization
through sharing
It is against ASRC Federal policy for any employee or consultant, male or female, to and team building
sexually harass another employee by (a) making unwelcome sexual advances, for continued trust
requests for sexual favors, or engaging in other verbal or physical conduct of a sexual and connection.
nature, or (b) making submission to or rejection of such conduct the basis for
employment decisions, or (c) creating an intimidating, hostile, or offensive working environment by such
conduct. It is also against ASRC Federal policy to engage in behavior that constitutes harassment of any
kind, whether such activity would be considered to be sexual harassment or otherwise. To access more
information regarding the Company’s Equal Employment Opportunity and Affirmative Action (Policy HR-103),
Sexual Harassment and Other Unlawful Harassment (Policy HR-105) or Workplace Conduct/ Improvement (Policy
HR-706) policies, please review the Human Resources Manual.

n Employee Dispute Resolution

The Company will deal with employees in a fair and consistent manner, ensuring an organizational climate
of integrity and respect. Nevertheless, the Company maintains rights customarily reserved to management,
including but not limited to the rights to: hire, promote, suspend, discipline, transfer or discharge; to relieve
employees from duty because of lack of work, or terminate employees for no reason at any time, with or
without cause or notice in accordance with our at-will policy; to schedule hours or require overtime work
and establish rules pertaining to the operation of the Company. Under normal circumstances, the Company

The information contained in this document is Company proprietary and shall not be duplicated, used, or disclosed, in whole or in part, for any purpose other than to provide
internal ASRC Federal and Subsidiary policy guidance.

Revised 10/28/10 4
FN-002, Standards of Ethics and Business Conduct Policy

endorses a policy of progressive discipline in which it provides employees with notice of deficiencies and an
opportunity to improve. Under such policies, employees will have the right to appeal certain, but not all,
management decisions that may adversely affect their standing within the Company, with some exceptions
as stated in Dispute Resolution (Policy HR-707) within the Human Resources Manual.
Employees are afforded the opportunity to address individual concerns through the AsrC vALue
Company’s dispute resolution program. All Company programs involving dispute
resolution of
resolution and performance improvement are intended to aid employees in improving
Conflict – While
their productivity and value to the Company and at the same time enhance and respecting our
encourage their own personal development and success. Employees who feel they differences, we
have not been treated appropriately in any way, or who feel that they have been the will deal with the
subject of harassment, discrimination or other wrongful behavior, should make a inherent tension in
report of the incident within 5 working days of the event to their manager or anyone our decision-
in their chain of command or the Human Resources Department. Any complaint or making processes,
strengthening our
report received will be investigated as confidentially as possible consistent with the
partnerships.
steps necessary to resolve the matter fairly and appropriately. It is important to
maintain a workplace all employees can be proud of by reporting such incidents. There will be no retaliation
against employees for making such a complaint or report in good faith.

n Timekeeping Policy
Each employee and consultant bears the responsibility to accurately record his or her time on a daily basis,
in accordance with Company timekeeping policy and procedure. The supervisor will review and approve
each employee timesheet at the end of the appropriate timekeeping cycle. Upon being hired, employees are
provided with a link to the Human Resources Manual, available on the portal, which includes the Hours of
Work (Policy HR-801) and Pay Procedures (Policy HR-802) policies. In addition, new employees are provided
with written guidance regarding maintenance of a paper timesheet and the use of the electronic timekeeping
system. Furthermore the Timesheet Completion and Submission procedure (PY-002-02) is found on the
Company’s portal. Each employee and consultant is expected to read, fully understand, and precisely follow
the policies and procedures set forth. If employees have any questions regarding these specific policies, they
should discuss them promptly with their immediate manager or higher-level manager. A knowing failure to
comply with the Company’s Timekeeping Policy will be the basis for disciplinary action up to and including
termination of employment and may be the basis for action by law enforcement authorities.

n Use and Protection of Government Furnished Property

The Company and its employees, consultants and subcontractors shall abide by all regulations applicable to
the possession, use, reporting, and disposition of Government property within its control. Government

The information contained in this document is Company proprietary and shall not be duplicated, used, or disclosed, in whole or in part, for any purpose other than to provide
internal ASRC Federal and Subsidiary policy guidance.

5 Revised 10/28/10
 FN-002, Standards of Ethics and Business Conduct Policy

property shall only be used for those purposes authorized in the contract and will be appropriately tracked,
controlled, reported on and returned, as required. ASRC Federal and its Subsidiaries will ensure that any of
their subcontractors who control Government property shall adequately care for it. More information on the
Company’s policy regarding Government Property Management (CT-004) can be found on the Company’s
portal.

n Use and Protection of Company Assets AsrC vALue

The Company invests substantial sums of money to provide employees with up-to- stewardship –
date technology, equipment and furnishings. These items are intended to facilitate We will employ
the business of the Company with the ultimate goal of increasing value to the share- financial discipline
holders. All employees and consultants are therefore responsible for the when managing
protection and appropriate, efficient use of the Company’s assets, which includes our lands and
assets to ensure
physical assets as well as intellectual property and proprietary information.
that increases in
All assets are to be used for legitimate business purposes only. While some incidental business
personal use is allowed, such use is limited to non-business hours (before or after performance and
work, during lunch or other breaks) and expressly conditioned on compliance with shareholder
returns are
Ethical Business Conduct (Policy HR-705) and Outside Employment (Policy HR-703)
sustainable.
policies located in the Human Resources Manual and the IT Acceptable Use (IT-001B)
and Information Security (IT-002-02A) policies found on the Company’s portal. Any use of Company
property or services which is not solely for the benefit of the Company must be approved beforehand by the
employee’s immediate supervisor.
Theft, or careless, inappropriate or negligent use of the Company’s physical assets, especially when resulting
in loss or diminished value of such assets, as well as unauthorized use, disclosure or transfer of intellectual
property or proprietary information may subject the offending person to disciplinary action up to and including
termination of employment, and may result in possible civil or criminal prosecution under applicable laws.
More detailed statements regarding the use of software, protection of intellectual property, trade secrets and
proprietary information and the electronic communications policy are provided below.

n Use of Software
The Company has established a policy which prohibits the creation or use of unauthorized copies of software,
and no “pirated” software will be installed or used on Company computers. Except for software supplied by a
client or teaming partner pursuant to the terms of a contract, or personally owned software which has been
approved and installed by ASRC Federal’s IT Department, employees shall use only Company licensed software.
Employees shall use all software only in accordance with the terms of the applicable license agreements or
other contracts under which the software is supplied. ASRC Federal or subsidiary licensed software may not
be copied or provided to any third party unless authorized under the license agreement.

The information contained in this document is Company proprietary and shall not be duplicated, used, or disclosed, in whole or in part, for any purpose other than to provide
internal ASRC Federal and Subsidiary policy guidance.

Revised 10/28/10 6
FN-002, Standards of Ethics and Business Conduct Policy

Before taking any action to transfer licensed software, employees should contact the ASRC Federal Help Desk
to determine whether their proposed action is permitted. Please refer to the Human Resources Manual
for information regarding the use of Company licensed software under Communications Systems
(Policy HR-1104), Use of Computers and Software (Policy HR-1105), Ethical Business Conduct (Policy HR-705) and
Outside Employment (Policy HR-703). This subject is further covered within the IT Acceptable Use (IT-001B) and
Information Security (IT-002-02A) policies found on the Company’s portal. Unauthorized use, copying, transfer,
or disclosure of software may subject the offender to disciplinary action and as well as civil and criminal
penalties under copyright laws.

n Use of Computing Resources

Computing resources are provided to users to support their work on behalf of the Company and its clients.
Users are expected to utilize these resources in a professional and appropriate manner, in accordance with
published policy including but not limited to: Communications Systems (Policy HR-1104), Use of Computers and
Software (Policy HR-1105), Ethical Business Conduct (Policy HR-705) and Outside Employment (Policy HR-703).
This subject is further covered within the IT Acceptable Use (IT-001B) and Information Security (IT-002-02A)
policies found on the Company’s portal. The term “Computing Resources” includes any computer, peripheral,
server or network provided or supported by the Company’s Information Technology Department as well as
all communications equipment, systems, and services provided to the employees of ASRC Federal and its
subsidiaries in the course of their employment. This includes, for example, telephone, electronic mail, instant
messaging, voice mail, fax, local and wide area networks, text paging, and internet access. Also covered by
this definition are any data and programs stored on or utilized in connection with such computing resources,
regardless of format or medium of storage. Unauthorized or improper use of the Company’s computing
resources may subject an employee to disciplinary action up to and including termination of employment.

n Communications Policy
It is the policy of the Company to provide or contract for communications services and equipment necessary
to promote the efficient conduct of business. Electronic communications, including electronic mail, voice
mail, electronic commerce, instant messaging and text paging are integral components of our work place.
Each employee must realize, however, that there are risks associated with electronic communications as
more fully described in the Communications Systems Policy (Policy HR-1104), the IT Acceptable Use Policy
(IT-001B) and the Information Security Policy (IT-002-02A). Each employee is expected to read, fully
understand, and comply with these policies, including the rules on content, distribution, receipt and retention
of communications.
The hardware and software on which our company’s communications take place are assets of the Company
provided for business use only. Therefore all Company communications services and equipment, including
the messages transmitted or stored by them, are the sole property of the Company. The Company may
access and monitor employee communications and files as it considers appropriate. Accordingly, ASRC

The information contained in this document is Company proprietary and shall not be duplicated, used, or disclosed, in whole or in part, for any purpose other than to provide
internal ASRC Federal and Subsidiary policy guidance.

7 Revised 10/28/10
 FN-002, Standards of Ethics and Business Conduct Policy

Federal and its subsidiaries reserve the right to review, delete, disclose, or use employee’s electronic
communications for any business purpose. As a result you should not have any expectation of privacy for
the data (including audio and visual files), e-mails, and other material stored in any company telephone or
computer system. This expectation of a lack of privacy extends to any courier or express mail service or
postal service, bulletin boards, on-line services, and facsimiles. Employees should exercise care so that no
personal correspondence appears to be official communication of the Company.
Employees are prohibited from surreptitiously recording or filming any conversation or meeting without the
consent of all parties, even if the recording is legal under state law.
Any question or doubt regarding communications should be discussed with the employee’s immediate
manager.

n Protection of Intellectual Property, Trade Secrets, Proprietary Information

It is essential for all employees and consultants to safeguard the Company’s trade secrets and proprietary
information and to refuse any improper access to trade secrets and proprietary information of any other
company or entity including our competitors. The terms used herein are defined as:
• Proprietary Information: Material and information relating to or associated with a company’s products,
business, or activities including, but not limited to, financial information, data or statements, trade
secrets, product research and development, existing and future product designs and performance
specifications, marketing plans or techniques, schematics, client lists, computer programs, processes,
and know-how that have been clearly identified and properly marked by the company as “Proprietary
Information” or trade secrets.
• Trade Secret: Any formula, pattern, device, or information that is used in a business and which gives a
competitive advantage to others.

All ASRC Federal and Subsidiary employees, and others acting on their behalf in any capacity, are responsible
for the identification, designation, and protection of information in the possession, ownership, or control of the
companies in accordance with the provisions of the Protection of Proprietary Information procedure (SC-002-01).
Upon employment, personnel receive a General Confidentiality and Work Product Agreement form (form
ASRCFH_HR060) which describes in detail the policy and allows for employees to declare work products that
are not controlled or governed by the Company policy. Execution of contract specific non-disclosure agreements
and privacy act statements may also be required for employees.
The originators of proprietary information shall determine the need to protect such information, and then
take the steps necessary to protect that information. If required, originators shall mark or identify the
information as proprietary or trade secret as soon as it is produced in a tangible format, entered into a computer
system, or transmitted to another party either verbally or via electronic means. When it is recognized that

The information contained in this document is Company proprietary and shall not be duplicated, used, or disclosed, in whole or in part, for any purpose other than to provide
internal ASRC Federal and Subsidiary policy guidance.

Revised 10/28/10 8
FN-002, Standards of Ethics and Business Conduct Policy

the sharing of company private or proprietary information is beneficial or necessary to engage a supplier or
prospective supplier, a Non-Disclosure Agreement will be executed prior to the disclosure of the information.
Buyers, Proposal Managers, Marketing Managers and Program Managers should all be sensitive to this
potential situation and proactively advise the Buyer to initiate the agreement. Presentations of Company
information which may be considered proprietary, even in part, should routinely include both a written and
a verbal notification of such protected status to the intended recipients.
More details can be found in the Human Resources Manual under Confidential Company Affairs (Policy
HR-710) and Ethical Business Conduct (Policy HR-705). In addition this subject is further covered within the
Protection of Proprietary Information procedure (SC-002-01) and the Non-Disclosure Agreements procedure
(PR-003-11I) found on the Company’s portal.
Always be alert to avoid inadvertent disclosures which may arise in social conversations or in normal business
relations; and do not receive any such information from other companies or people except pursuant to written
agreement. Employees and consultants on client sites should pay careful attention to the use of government-
owned email systems and accounts. Never send proprietary information or trade secrets across a government
email system, as the information can be requested by competitors and ultimately released by the government
through the Freedom of Information Act (FOIA). Similarly the Company’s property rights in its technology and
products must be protected by use of appropriate agreements whenever such technology and/or products are
used, transferred or disclosed.

n Fiduciary Duty of the Employee

If an employee of the Company has material non-public information relating to the Company he or she cannot
disclose this knowledge to others. All employees should avoid even the appearance of an improper transaction
to preserve the Company’s reputation for adhering to the highest standards of conduct.

n Personal Conflicts of Interest

Conflicts of interest may raise doubts about the quality of the decision and the motive and integrity of the
employee making it. Any situation that appears to cause, or actually causes, an employee to have to make a
choice between loyalty to ASRC Federal and loyalty to oneself, a relative(s), or an outside activity, presents
a conflict of interest (COI).
Conflicts of interest existing at the time of employment, or arising during the time an individual is employed
by ASRC Federal, must be disclosed and resolved in accordance with this Policy, as soon as they arise.
Employees should submit the ASRC Federal Conflict of Interest Disclosure Form (form ASRCFH_HR059,
“Disclosure Form”) to their supervisor. This form is located on the Company portal in the “Forms” area,
under “HR Forms”. In addition, executives, supervisors, and any employee who holds a position that
includes making material (i.e. other than nominal) business decisions on contracts, hiring decisions, procurement
of goods or services, project development or execution, investments, financial or other similar matters, will

The information contained in this document is Company proprietary and shall not be duplicated, used, or disclosed, in whole or in part, for any purpose other than to provide
internal ASRC Federal and Subsidiary policy guidance.

9 Revised 10/28/10
 FN-002, Standards of Ethics and Business Conduct Policy

need to complete a Disclosure Form at least once annually, and as soon as possible after acquiring any interest
which may constitute a conflict of interest under this Policy. Every completed Disclosure Form will be
promptly reviewed by the employee’s immediate supervisor or business unit/department head, and any
conflicts so disclosed will be resolved in accordance with the Conflict of Interest (Policy HR-709) policy found
in the Human Resources Manual.
In order to avoid potential conflicts of interest, employees should avoid any activity outside their Company
work that is reasonably likely to put them in a conflict situation. For example, when a new employee joins
the Company, they execute a Conflicts of Interest form (ASRCFH_HR018) which bars them from entering into
situations that may pose a conflict of interest. Outside employment is not specifically prohibited; however it
may work against the interests of the Company and in those situations would be considered inappropriate.
For more details on scenarios which could be construed as a conflict of interest, please review the Human
Resources Manual under Outside Employment (Policy HR-703). In addition this subject is addressed in the
Avoiding Conflicts of Interest Policy (HR-001F) and the Procurement Ethics Policy (PR-001A) found on the
Company’s portal.

n Strategic Planning Information

All employees must be vigilant in safeguarding most types of non-public Company information from
disclosure both inside and outside the Company unless the person has a need to know the information for
legitimate, Company related reasons. This duty of confidentiality is especially important with respect to any
Company strategic planning activity, including merger, acquisition, divestiture, or reorganization activities.
It is a violation of Federal Securities and Exchange law for anyone with knowledge of such information to
buy, sell or trade in company stock (“insider trading”) or to make an unauthorized disclosure of such
information (known as “tipping”) in connection with such transactions involving companies whose stock is
publicly traded, and whose operations are governed by SEC regulations and requirements. While ASRC is
not a public stock company whose operations are subject to SEC regulations, its strategic activities and
transactions may involve companies which are SEC regulated.
All employees who have access to information not available to the general public concerning the company’s
strategic planning, including, but not limited to, potential acquisitions, divestitures, reorganizations, or
major contract awards, shall neither use such information for personal financial advantage in any way,
including the buying or selling of stock in affected companies, nor disclose such information to an outside
party who may benefit thereby, unless authorized to do so by appropriate levels of management and unless
permitted by law or regulation. Employees involved in such activities will be required to sign specialized
non-disclosure agreements, which will restrict the dissemination of such information to only those designated
individuals who have an actual “need to know.” Always contact Corporate Counsel when in doubt before
making any such disclosure or conducting a personal transaction involving a company affected by ASRC’s
strategic planning.

The information contained in this document is Company proprietary and shall not be duplicated, used, or disclosed, in whole or in part, for any purpose other than to provide
internal ASRC Federal and Subsidiary policy guidance.

Revised 10/28/10 10
FN-002, Standards of Ethics and Business Conduct Policy

n Regarding Gifts, Gratuities, and Entertainment

The Company relies on employees to make sound business judgments based on the corporation’s best interest
and consistent with the ethical standards of ASRC Federal. Offering and accepting business hospitality, gifts,
meals, and/or entertainment as a social amenity is a normal part of doing business in various industries in
which the Company operates. However in certain circumstances, accepting certain gifts and entertainment
from vendors, contractors, competitors, suppliers, or customers with whom the Company has a current or
potential future relationship can adversely affect business judgment and create an appearance of impropriety.
Therefore the Company has adopted guidelines to help employees decide when a hospitality, gift, meal or
entertainment offered may be accepted and when it must be declined. In no event should an employee accept
or give a gift where it would be prohibited by law or is known by the employee to be contrary to law or the
corporate business practices of the company or agency employing the person offering the gift.
In general the Company’s policy on providing business courtesies to commercial or non-governmental clients is
that such offers may be extended provided they are reasonable, not extravagant in value (over $200) or number,
not frequent enough to be considered expected, and not offered in exchange for favorable consideration or
treatment. However, there are significant legal prohibitions associated with providing or receiving gratuities in
the context of international activities or governmental business transactions and relationships. Federal
government employees, as well as those of most state and local governments and many private companies who
do business with government clients, are subject to strict rules regarding the giving and acceptance of gifts.
Respect for these rules is paramount in maintaining a cordial, ethical, and legally compliant business
relationship. In the government environment failure to do so may result in severe legal and financial
consequences for both the Company and the offending employee.
With regard to receipt of similar courtesies, employees may not accept or retain any gift or gratuity with
more than a nominal value (under $25), such as small promotional items (pens, mugs, notepads, candy, etc.).
Guidelines for the polite return of gifts or gratuities, the payment of postage, and the need to document the
return for audit purposes are covered in the Human Resources Manual, under Gifts and Entertainment
(Policy HR-711). Further clarification on this subject can be found in the Gifts, Meals and Entertainment Policy
(CG-005) and the Procurement Ethics Policy (PR-001A) located on the Company’s portal.

n Dealings with Suppliers, Vendors, Business Partners, and

AsrC vALue
Competitors
Our relationships
Integrity and fair dealings are characteristic of ASRC Federal and its subsidiaries. All – We will develop
vendors, suppliers, other business partners, and competitors should be treated fairly and maintain
and uniformly in accordance with the Company’s established purchasing policies relationships that
and procedures such as the Procurement Ethics Policy (PR-001A) located on the focus on the
Company’s portal and the Ethical Business Conduct (Policy HR-705) section within creation of value
the Human Resources Manual. Employees must not engage in any activity prohibited for all participants.

The information contained in this document is Company proprietary and shall not be duplicated, used, or disclosed, in whole or in part, for any purpose other than to provide
internal ASRC Federal and Subsidiary policy guidance.

11 Revised 10/28/10
 FN-002, Standards of Ethics and Business Conduct Policy

under anti-trust or other laws, including reciprocity, kick-backs, boycotting, price-fixing, refusal to deal,
price discrimination, or disparate treatment of suppliers. Paying bribes, accepting kickbacks, and obtaining
and using third party insider information in dealings with suppliers, vendors and business partners are
completely inappropriate and will not be tolerated.
Furthermore the Company will not enter into any subcontract or teaming agreement that unreasonably
restricts sales by the other company directly to the U.S. Government of items made or supplied by the other
company and will not otherwise act to restrict unreasonably the ability of any company to sell directly to the
U.S. Government. Conversely the Company will not enter into agreements where, as a subcontractor or
teaming partner, we are subject to unreasonable restriction to sell our own products and services directly to
the U.S. Government.

n Reporting Material Developments and Complying with Internal Controls

It is the duty of every employee to fully, fairly, accurately, promptly, and comprehensibly report financial
and non-financial developments that could possibly have a material effect on the operations or financial
condition of the Company – through his/her chain of command and to the Company’s Senior Vice President
of Finance and Operations, or Corporate Counsel as soon as it is discovered. The company maintains an
effective system of internal controls. It is every employee’s obligation to understand his or her role in complying
with, and monitoring compliance with, relevant internal control policy and procedures. An employee’s
approval of a timecard, a vendor invoice or an invoice to a client reflects a representation that such information
is accurate to the best of their knowledge. Employees are expected to report any observations of failure to
comply with such controls and procedures to one of the individuals named above.

n Interference with an Audit

The Company’s officers and employees, and persons acting under their supervision, must refrain from
taking any action that misleads, impedes or otherwise disrupts the work of either the company’s internal
Audit Department, its independent outside auditors and most especially, any auditor or investigator from
any Federal agency performing official, authorized duties. This includes taking any action to fraudulently
coerce, manipulate, mislead, or obstruct any auditor in any respect. Any such action taken with respect to
Federal audit or investigative activities is punishable under Federal criminal laws.

n Additional Policies Relating to U.S. Government Contracting

AsrC vALue
As a Government contractor, we have a special obligation to the U.S. Government, High Performance
and to the public at large, to ensure that we administer our contracts and deliver our – We will achieve
products and services in a manner that fully satisfies both our legal obligations and superior business
our own high standards of integrity and quality. results and stretch
our capabilities to
reach even higher
levels.

The information contained in this document is Company proprietary and shall not be duplicated, used, or disclosed, in whole or in part, for any purpose other than to provide
internal ASRC Federal and Subsidiary policy guidance.

Revised 10/28/10 12
FN-002, Standards of Ethics and Business Conduct Policy

We are committed to compliance with the letter and spirit of the laws and regulations governing contracting
with the U.S. Government. These impose requirements not traditionally associated with purely commercial
business transactions, including, but not limited to:
• False Claims/False Statements to the U.S. Government
It is a felony to knowingly make a false claim or false statement to the government, either verbally or
in writing. Violation of these and other statutes can subject us to damaging publicity, expensive and
time-consuming investigations and litigation, reduction of negotiated contract rates, and the revocation
of contracts. Both the Company and the individual employee may also be subject to civil and criminal
sanctions including fines, debarment or suspension, and prison sentences.
False claims and false statements are typically made in any document which carries a certification
referencing 18 U.S.C. 1001, or other cited Federal laws. Typical examples include invoices, proposals,
and representations/certifications made in connection with Federal contracts, or official reports and
responses made under Federal regulation to Federal agencies, such as EEO, Labor or SBA reports. It is
essential that each employee involved in the production of such documents use best efforts to ensure the
accuracy, completeness and currency of the data used therein.
• Lobbying Activities
ASRC Federal and its subsidiaries encourage employees to participate in the political process and
contribute to the communities within which they live and work. The long tradition of active political
involvement by officers and directors of the corporation is also an important aspect of the history of
our company as well as the passage and implementation of the Land Claims Act. Nevertheless it must
be recognized that Federal laws generally prohibit recipients of Federal funds (that is, recipients of
contracts, grants, loans, or cooperative agreements) from the making of campaign contributions to
candidates, political parties, and campaigns; and while Alaska laws permit the making of such
contributions, many states do not. Contributions by the Company, if legally permissible, will only be
made upon approval of the ASRC Federal Board of Directors or senior corporate officials and will be
examined for compliance with all applicable laws and regulations, Federal, state and local. Personal
contributions made by individuals are acceptable provided they are not made on behalf of the
Company. The Company has addressed these special obligations in the Restriction on Lobbying
procedure (PR-003-09B) found on the Company’s portal. This procedure provides guidelines for
complying with the “Byrd Amendment” implemented through FAR Part 52.203-11, Certification and
Disclosure Regarding Payments to Influence Certain Federal Transactions. Prior to the award by ASRC
Federal or its subsidiaries of any subcontract exceeding $100,000 under any Federal contract, ASRC
Federal Procurement personnel shall obtain certifications as required by FAR Part 52.203-11,
Certification and Disclosure Regarding Payments to Influence Certain Federal Transactions. The subject is also
addressed briefly in the Human Resources Manual under Ethical Business Conduct (Policy HR-705).

The information contained in this document is Company proprietary and shall not be duplicated, used, or disclosed, in whole or in part, for any purpose other than to provide
internal ASRC Federal and Subsidiary policy guidance.

13 Revised 10/28/10
 FN-002, Standards of Ethics and Business Conduct Policy

• Prohibited Use of Source Selection Information

All employees are required to safeguard and prohibit use of any proprietary bid or proposal information
and source selection information from unauthorized disclosure in accordance with applicable laws and
the Federal Acquisition Regulations (FAR) Part 3.104. Individuals responsible for preparing material that
may be source selection sensitive information must mark the cover page and each page that contains
source selection information with the legend “Source Selection Information—See FAR 2.101 and 3.104.”
Employees who are unsure if particular information is source selection information should consult with
the Company compliance team or contracts department as necessary.
• Organizational Conflicts of Interest
No contract shall be negotiated or executed if the interests of the particular customer are of such a
nature as to compromise or threaten the company’s ability to maintain unbiased objectivity in serving its
other customers. In instances in which potentially conflicting situations may be created, agreements may be
entered into if the parties involved have full knowledge of the potential conflict and consent to the
arrangements in advance. The contract file should contain appropriate documentation of such arrangements.
• Prohibited Contractual Relationships
The Company shall not knowingly employ an individual nor shall it contract with a company, by any
means, if the individual or company is on the General Services Administration’s (GSA) Consolidated
List of Debarred, Suspended, and Ineligible Contractors, nor shall it knowingly employ an individual
who has been convicted of an offense related to government contracting.
• Hiring of Government and Former Government Employees
Special restrictions apply to hiring or retaining a government employee as an employee or consultant
of the company. In addition, there are special constraints regarding any communication concerning
possible employment during the conduct of any procurement action with which the government
employee may have a connection. The Company will not conduct any discussion regarding or make
any offer or promise of future employment or business opportunity to any procurement official during
the conduct of any procurement with which such official may be connected. Any government employee
seeking a position with the Company or any of its subsidiaries must first obtain the proper ethical/conflict
of interest opinion from government legal counsel, clearing him/her for such a position. Similarly,
ethics/COI clearance must be obtained by any Company employee wishing to offer employment to
current or recently separated government employees. No such offer can be discussed or made before a
government employee has publicly announced that they are leaving government service. In addition,
any plans to employ retired senior military officers or former high ranking civilian government officials
must be approved by the Human Resources organization prior to an offer for employment. n

The information contained in this document is Company proprietary and shall not be duplicated, used, or disclosed, in whole or in part, for any purpose other than to provide
internal ASRC Federal and Subsidiary policy guidance.

Revised 10/28/10 14
FN-002, Standards of Ethics and Business Conduct Policy

reFerenCe DOCumenTs
HR Manual Policies

HR Manual Policy HR-103, Equal Employment Opportunity

HR Manual Policy HR-104, Code of Employer-Employee Relations
HR Manual Policy HR-105, Harassment
HR Manual Policy HR-703, Outside Employment
HR Manual Policy HR-705, Ethical Business Conduct
HR Manual Policy HR-706, Workplace Conduct/Improvement
HR Manual Policy HR-707, Dispute Resolution
HR Manual Policy HR-709, Conflict of Interest
HR Manual Policy HR-710, Confidential Company Affairs
HR Manual Policy HR-711, Gifts and Entertainment
HR Manual Policy HR-801, Hours of Work
HR Manual Policy HR-802, Pay Procedures
HR Manual Policy HR-1104, Communications Systems
HR Manual Policy HR-1105, Use of Computers and Software

ASRC Federal Policies and Procedures

Contracts Process CT-004, Government Property Management
Corporate Governance Policy CG-005, Gifts, Meals, and Entertainment
HR Procedure HR-001F, Avoiding Individual Conflicts of Interest
IT Policy IT-001B, IT Acceptable Use Policy
IT Policy IT-002-02A Information Security Policy
Payroll Procedure PY-002-02, Timesheet Completion and Submission
Procurement Policy PR-001A, Procurement Ethics
Procurement Procedure PR-003-09B, Restriction on Lobbying
Procurement Procedure PR-003-11I, Non-Disclosure Agreement
Safety Policy SF-001A, Anti-Drug and Alcohol Program Policy
Security Procedure SC-002-01, Protection of Proprietary Information

The information contained in this document is Company proprietary and shall not be duplicated, used, or disclosed, in whole or in part, for any purpose other than to provide
internal ASRC Federal and Subsidiary policy guidance.

15 Revised 10/28/10
 FN-002, Standards of Ethics and Business Conduct Policy

ASRC Federal Forms

Conflict of Interest Disclosure Form, ASRCFH_HR059

Employee Non-Compete Agreement, form ASRCFH_HR020
General Confidentiality and Work Product Agreement Form, ASRCFH_HR060
Standards of Business Ethics and Conduct Certification, ASRCFH_ACC015
Conflicts of Interest form, ASRCFH_HR018

Other
FAR Part 52.203-11, Certification and Disclosure Regarding Payments to Influence
Certain Federal Transactions
Federal Acquisition Regulations (FAR) Part 3.104
National Industrial Security Program Operating Manual, NISPOM

The information contained in this document is Company proprietary and shall not be duplicated, used, or disclosed, in whole or in part, for any purpose other than to provide
internal ASRC Federal and Subsidiary policy guidance.

Revised 10/28/10 16