Conflict of Interest

In-Depth Engineering is committed to upholding the highest standards of ethical business conduct and expects the same of its employees, consultants, contractors, and others. We all have a responsibility to act in the best interests of the corporation at all times.

Personal Conflict of Interest

A personal conflict of interest exists when one has divided loyalties such that one has a direct or indirect personal interest in a transaction or matter such that it might reasonably appear to affect the judgment that one exercises on behalf of the corporation, influence ones actions, or lead one to neglect corporate business interests.

We expect our employees to be free from influences that conflict with the best interests of the corporation or might deprive In-Depth Engineering of their undivided loyalty in business dealings. Even the appearance of a conflict of interest where none actually exists can be damaging and should be avoided. Each employee must act in a fair and impartial manner in all business dealings and must place the interests of the corporation over personal interests in matters that relate to business. Each employee is expected to avoid financial, business, or other transactions that might conflict or appear to conflict with the interests of the corporation. An actual conflict of interest does not need to be present to constitute a violation of the code of ethics; however each employee is expected to avoid activities that create the appearance of a conflict of interest.

Questions about a potential conflict or awareness of an actual or potential conflict should be addressed with the ethics officer. Factors that may be considered in evaluating a potential conflict of interest are, among others:

The following are examples of situations that may, depending on the facts and circumstances, involve conflicts of interests:

Organizational Conflict of Interest

An organizational conflict of interest occurs when that which is good or profitable for In-Depth may not be in the best interest of the government. Because of the diverse nature of corporate activities and relationships, questions regarding organizational conflicts of interest should be referred to the Ethics Office. The following factors may be taken into consideration when evaluating a potential organizational conflict of interest:

In-Depth Engineering corporately and each of us individually must take all necessary measures to avoid, neutralize, or mitigate potential organizational conflicts of interest.

Each employee is encouraged to examine each situation individually and to exercise “common sense, good judgment, and sound discretion” in assessing whether a potential conflict exists. If an organizational conflict of interest may exist, contact the ethics officer right away. The ethics officer will help determine whether we will have to stop working on the matter, or whether another remedy would resolve the conflict.

Corporate Opportunities

No employee may take personal advantage of opportunities presented as a result of their position or through the use of corporate property or information. Even opportunities that are acquired privately may be questionable if they are related to our existing or proposed lines of business. Significant participation in an investment or outside business opportunity that is directly related to our lines of business must be pre-approved. No employee may use their position with us or corporate property or information for improper personal gain, nor can an employee compete with us in any way.

Outside Employment

Each employee of In-Depth Engineering is prohibited from accepting outside employment from competitors, suppliers, and customers as a second source of income. Second jobs create loyalty issues, conflict of interest problems, and/or impair an employee’s ability to execute work functions effectively.

Insider Information and Securities Trading

Employees may learn of information that relates to other companies before the general public has access to the same information. Such information is called insider information and employees are prohibited from buying or selling stock based on insider information until such time that it has been released to the public. Non-public information cannot be used to make securities trades, nor can it be used to tell others to make securities trades for the employee’s benefit. Employees may also not pass insider information to others who have no need to know. To ensure that insider information has gone public you can seek out the information on various social and news networks on the internet, newspapers, and television.