The foundation of Burtek’s business approach has been to promote a strong sense of integrity in everything that we do. We have an obligation to make certain that integrity prevails in all of our business functions and decisions. 
Integrity at Burtek means that we shall:
- Respect the rights of all employees and contractors to fair treatment and equal opportunity, free of discrimination or harassment of any type.
- Conduct all dealings with our customers and suppliers with integrity and honesty.
- Conduct all of our activities with full compliance of all laws and regulations.
- Maintain the highest level of honesty and ethics in all activities related to Burtek.
- Protect information that belongs to Burtek, our customers, suppliers, and fellow colleagues.
- Not use Burtek’s assets or information for personal gain.
Burtek is commited to ensuring that its reputation continues to remain respected and admired within our industry. Please report any unethical or illegal activity to Burtek’s Compliance Department:
Confidential Hotline: (586) 569-3486
Confidential Email Address: Compliance@BurtekEnterprises.com
Burtek’s Code of Business Conduct & Ethics
Introduction
This Code of Business Conduct & Ethics (“Code”) of Burtek Enterprises Inc (“Burtek”) is an expression of our fundamental values and represents a framework for decision-making. The following Code does not cover every issue that may arise in the course of our business, but it sets to define our ethical principles.
Compliance with Laws, Rules and Regulations
Obeying the law is the foundation on which Burtek’s ethical standards are built. Burtek’s employees and vendors shall respect and obey the laws, rules and regulations of the cities, states and countries in which Burtek operates.
Government Contracting
The rules imposed on businesses that sell to the government are often different from, and more restrictive than, the rules that apply to purely commercial transactions. As a government contractor, Burtek is committed to complying with all of those requirements.
Conflict of Interest
Business decisions must be made in the best interest of our Company, not motivated by personal interest or gain. Therefore, Burtek’s employees and vendors shall avoid any actual or perceived conflict of interest.
A conflict of interest exists whenever an individual uses one’s position to engage in conduct that has the result, actual or potential, of personal and private gain or benefit for others instead of the best interests of Burtek. A conflict situation can arise when someone takes actions or has interests that make it difficult to perform his or her Company work objectively and effectively. Conflicts of interest may also arise when an employee, or a member of his or her family, receives improper personal benefits as a result of his or her position at Burtek. It is a conflict of interest for a Burtek employee to work for a competitor, customer or supplier.
It is difficult to identify exhaustively what constitutes a conflict of interest. For this reason, Burtek employees must avoid any situation in which their independent business judgment might appear to be compromised. Questions about potential conflicts of interest situations and disclosure of these situations as they arise shall be reported to the Compliance Office.
Business with Third Parties
Burtek expects its consultants, agents, resellers, distributors, subcontractors, and other business partners to adhere to lawful and ethical business practices. It is important to Burtek’s reputation that we avoid doing business with companies which violate applicable laws or have reputations which could harm our business. Our policy prohibits engaging agents or other third parties to do indirectly what we as a Company should not do under our own policies outlined in this Code.
Accurate Accounting
Burtek requires honest, accurate and timely recording and reporting of information in order to make responsible business decisions. Under no circumstances should employees or contractors alter any business record or destroy any records except in conformity with our policy on record retention. All of Burtek’s books, records, accounts and financial statements must be maintained in reasonable detail, must appropriately reflect the Company’s transactions, must be promptly disclosed in accordance with any applicable laws or regulations and must conform both to applicable legal requirements and to Burtek’s system of internal controls.
Confidential Information
It is Burtek’s policy that all employees, contractors, and vendors keep confidential all information about Burtek’s operations, products and business activities that have not been made public and that are not common knowledge among competitors, customers, suppliers and others, including other employees, contractors,or vendors who do not have a valid business reason for having the information. Employees, contractors, and vendors shall not disclose to others, or use for themselves or others, any confidential information they have originated or acquired in connection with their relationship with Burtek. It is equally important to protect proprietary or confidential information received from other companies, and to honor all terms of any confidentiality or non-disclosure agreements that may be in effect. It is Burtek’s policy to never accept unsolicited confidential information from a third party regarding another company.
Corporate Opportunities
Employees and contractors of Burtek are prohibited from taking opportunities for themselves that are discovered through the use of corporate property, information or position. No employee or contractor may use corporate property, information, or position for personal gain, and no employee or contractor may compete with Burtek directly or indirectly. Employees and contractors owe a duty to Burtek to advance Burtek’s interests when the opportunity to do so arises.
Fair Dealing
Employees and contractors of Burtek must try to deal fairly and in good faith with Burtek’s customers, suppliers, competitors, stakeholders and employees. No employee or contractor of Burtek shall take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts or any other unfair dealing practices.
Gifts and Entertainment
As a government contractor Burtek must avoid any implication that unfair or preferential treatment will be granted or received by its employees or contractors in their course of dealing on behalf of Burtek. Unless permission is received from the Compliance Office, entertainment and gifts cannot be offered, provided or accepted by any employee or contractor.
Discrimination and Harassment
Burtek prohibits unlawful discrimination or harassment against any of its employees, contractors, customers or suppliers on account of race, color, age, sex, religion or national origin. All persons shall be treated with dignity and respect and they shall not be unreasonably interfered with in the conduct of their duties and responsibilities.
International Business
Burtek is a defense contractor subject to United States export control laws and regulations of the International Traffic in Arms Regulations (ITAR) of the Export Administrative Regulations (EAR). ITAR and EAR compliance is an integral part of manufacturing and exporting defense articles, defense services, and related technical data as defined under the U.S. Munitions List, 22 C.F.R. §121 (“Defense Data”). Any person or entity that is involved with Defense Data or has access to Defense Data is also subject to these laws. Employees of Burtek must take appropriate measures so that they do not violate ITAR and/or EAR by directly or indirectly transferring Defense Data such as classified or unclassified critical technology or items of inherent military value to foreign persons or entities. Therefore, in order to comply with these laws and regulations Burtek employees and contractors must:
- Attend all ITAR training sessions as required;
- Control access to all Defense Data;
- Not disclose or transfer any Defense Data to any third person or entity without express written consent of Burtek;
- Not disclose or transfer any Defense Data to a foreign person or entity whether or not related to or affiliated with Burtek without the express written consent of Burtek and appropriate government authorizations;
- Immediately report any and all known or suspected ITAR/EAR violations to Burtek’s Compliance Office;
- Comply with any and all Technology Control Plans or Technology Transfer Control Plans; and
- Comply with any and all conditions that the U.S. government has placed on any Burtek export license, Manufacturing License Agreement, Technology Assistance Agreement, and/or Distribution Agreement.
In Addition to the above requirements, all employees and contractors that have access to Defense Data must either be a citizen, national or lawful permanent resident of the United States.
These requirements are the minimal requirements that must be met and it is strongly suggested that all Burtek employees and contractors review these laws and regulations in further detail which are available through Burtek’s Compliance Office.
Burtek Enterprises Inc’s Compliance Office
At Burtek, ethics is everyone’s business. Burtek established the Compliance Office to emphasize our commitment to ethical conduct throughout the company. The Compliance Office reports directly to the Board of Directors, and oversees a strong corporate wide effort to promote a positive, ethical work environment for all employees. If employees or contractors are confronted with an ethical question or do not understand the policies set forth in this Code, employees and contractors are strongly urged to discuss this matter with the Compliance Office. The Compliance Office will respect the confidentiality of all discussions and reporting. Employees or contractors who provide information to or assist in any investigation will not be subject to retaliatory action for their cooperation in such matters. Any employee or contractor who believes he or she has been the subject of retaliation should report the matter to the Compliance Office.
Confidential Hotline: (586) 569-3486
Confidential Email Address: Compliance@BurtekEnterprises.com
This Code applies to all employees and contractors of Burtek. Any employee or contractor, who violates these policies or fails to report a known violation of this Code, is subject to disciplinary action, up to and including termination of employment.