BL Companies | Employee Handbook | 2024
Gifts to BL Companies’ Employees BL Companies’ employees shall not solicit or accept for personal benefit directly or indirectly any gift, loan or any item of substantial monetary value from any person or company that is seeking to conduct or currently conducting business with the Company. Compliance with Government Policies Company employees must comply with all rules established by government officials for procuring products and services as well as the requirements of contracts funded in whole or in part by government funds. This includes, but is not limited to, complying with all requirements of the contracting body, including those related to bid submission, subcontractor requirements and qualifications and payment requisition. This also includes 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. If an employee has any question whether an action or proposed course of conduct in relation to work on contracts involving government funds, the employee should speak to his or her supervisor or the Legal Department. Charitable Contributions BL Employee Owners have always been known as community-minded people who serve as leaders and volunteers for various civic and community service groups. We encourage and support this participation, because our business directly impacts the sustainable growth of the regions where BL Companies has offices. Therefore, we believe that our employees should be involved in making the community a better place to live and work. The Company does not require contributions from its employees for any charity. Contributions to charity or for other similar purposes are considered a personal and individual matter, and such contributions will be on a voluntary basis. The Company does, however, regularly make contributions to a
wide range of charities and public service organizations. Whistleblower Policy A whistleblower as defined by this policy is an employee of BL Companies who reports an activity that he/she considers to be illegal or dishonest to one or more of the parties specified in this policy. The whistleblower is not responsible for investigating the activity or for determining fault or corrective measures; appropriate management officials are charged with these responsibilities. If an employee has knowledge of or a concern of illegal, dishonest or fraudulent activity, the employee is to contact his/ her immediate supervisor, the Human Resources Director or the General Counsel. The employee must exercise sound judgment to avoid baseless allegations. An employee who intentionally files a false report of wrongdoing will be subject to discipline up to and including termination. Whistleblower protections are provided in two important areas -- confidentiality and against retaliation. Insofar as possible, the confidentiality of the whistleblower will be maintained. However, identity may have to be disclosed to conduct a thorough investigation, to comply with the law and to provide accused individuals their legal rights of defense. The Company will not retaliate against a whistleblower. This includes, but is not limited to, protection from retaliation in the form of an adverse employment action such as termination, compensation decreases, or poor work assignments. Please see the paragraphs entitled “Non Harassment Environment” and “Conflict and Resolution Procedures” in the Integrity Section of this Employee Handbook. Any whistleblower who believes he/ she is being retaliated against must contact the Human Resources Director or the General Counsel immediately for review. The right of a whistleblower for protection against
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