ETHICS  POLICY 








Code of Business Conduct and Ethics Policy

In performing their job duties, Brockwell Incorporated employees should always act lawfully, ethically, and in the best interests of Brockwell Incorporated.  This Code of Business Conduct and Ethics (the "Code of Conduct" / "Ethics Policy") sets out basic guiding principles.


I. Compliance with Laws, Rules, and Regulations

Employees must follow applicable laws, rules, and regulations at all times.  Brockwell Incorporated will fervently compete, fairly, for all business opportunities – due to the quality standards of both our products and our services.  Brockwell Incorporated is in compliance with all business laws and is committed to help facilitate fair industry competition.  

Antitrust and Fair Competition Laws:  these laws are certainly elaborate and abundant.  Conclusively, these laws are created to encourage fair competition by compelling each company to operate independently, rather than together/as a team to participate in activities that restrict, monopolize, or hinder trade – such as:  allocating markets and clients, group boycotts, and price fixing.


II. Conflicts of Interest

In performing their job duties, employees are expected to act, at all times and in all ways, in the best interests of Brockwell Incorporated.  A "conflict of interest" exists when an employee's personal interest interferes with the best interests of Brockwell Incorporated.  For example, a conflict of interest may occur when an employee or a family member receives a personal benefit as a result of the employee's position with Brockwell Incorporated.  A conflict of interest may also arise from an employee's business or personal relationship with a customer, supplier, competitor, business partner, or other employee, if that relationship impairs the employee's objective business judgment.

Gift Receipt/Giving:  occasional receipt & giving of modest gifts can be beneficial in maintaining a good rapport in regards to business matters.  Receipt of cash gifts is prohibited.  Asking for gifts is prohibited.

Outside Employment:  it is permissible for Brockwell Incorporated's employees to partake in secondary work, so long as it does not disrupt their ability to perform their duties for Brockwell Incorporated or disrupt the best interest of Brockwell Incorporated.  If you are currently employed with a secondary company, or seeking secondary employment - please notify Benjamin Stone.

Serving on Board of Directors:  before serving on a board with a for-profit company, you must receive permission from Benjamin Stone.  Serving on a board that directly involves a family business for subjective financial organization is allowed.

Employees should avoid conflicts of interest, and employees who believe a conflict of interest may exist should promptly notify their manager or Brockwell Incorporated's CEO, Benjamin Stone.  Brockwell Incorporated's Legal Department will consider the facts and circumstances of the situation to decide whether corrective or mitigating action is appropriate.


III.  Discrimination and Harassment


Brockwell Incorporated provides equal opportunity in ALL aspects of employment and will not tolerate any discrimination or unlawful harassment of any kind.


IV. Competitive Information

Understanding and analyzing competitor information can be a beneficial tool; however, any competitive information must be properly obtained and utilized.  Examples of properly obtaining competitive information consists of:  print ads, journals, advertisements, and other public sources.


V. Health and Safety

Brockwell Incorporated provides a clean, safe and healthy work environment.  Each employee has responsibility for maintaining a safe and healthy workplace by following safety and health rules and practices and reporting accidents, injuries and unsafe conditions, procedures, or behaviors.

Violence and threatening behavior are not permitted.  Weapons are not permitted on Brockwell Incorporated's property or at any function/sponsored event pertaining to Brockwell Incorporated.  Employees must report to work in a condition to perform their duties, free from the influence of illegal drugs or alcohol.


VI. Fraud and False Statements

Brockwell Incorporated is rooted with both honesty and integrity, and we prohibit any employee or entity from engaging in any fraudulent activity towards Brockwell Incorporated, our clients, contractors, government agencies or officials, or any additional third parties.  Examples of prohibited activities include being deceptive by giving false statements, providing false claims of any manner of reimbursement, altering any sort of document with the intent to deceive or manipulate, or concealing facts - which should be mentioned in regards to the specific circumstance.


VII. Trade Secrets and Confidential Information


Every Brockwell Incorporated employee, upon hire, is required to sign a Confidentiality Agreement.  This prohibits all Brockwell Incorporated employees from disclosing any trade secrets of Brockwell Incorporated or any confidential company information to anyone or entity outside of Brockwell Incorporated.  Confidential information consists of:  specific company software use, unpublished financial data, business plans and processes, coding and programming, customer lists and employee lists, or any related sensitive business methods or operations.


VIII. Intellectual Property

Patents, copyrights, trademarks, and other trade secrets are methods to protect the Company's intellectual property under various laws.  Brockwell Incorporated's policy is to abide by these laws.  As an employee of Brockwell Incorporated, anything you create or design during your employment pertaining to Brockwell Incorporated belongs to Brockwell Incorporated.


IX. Price Fixing

Employees may not discuss prices or make any formal or informal agreement with any competitor regarding prices, discounts, business terms, or the market segments and channels in which the Company competes, where the purpose or result of such discussion or agreement would be inconsistent with applicable antitrust laws.  If you have any questions about this section or the applicable antitrust laws, please contact our management office.



X. Bribery; Payments to Government Personnel

Employees may not bribe anyone for any reason, whether in dealings with governments or the private sector.  The U.S. Foreign Corrupt Practices Act, and similar laws in other countries, prohibit offering or giving anything of value, directly or indirectly, to government officials in order to obtain or retain business.  Employees may not make illegal payments to government officials themselves or through a third party.  Employees who are conducting business with the government officials of any country must contact Brockwell Incorporated's Legal Department for guidance on the law governing payments and gifts to governmental officials.



XI. Recordkeeping, Reporting, and Financial Integrity

Brockwell Incorporated's books, records, accounts and financial statements must be maintained in appropriate detail, must properly reflect the Company's transactions and must conform both to applicable law and to the Company's system of internal controls.  Further, Brockwell Incorporated's public financial reports must contain full, fair, accurate, timely and understandable disclosure as required by law.  The Company's financial, accounting and legal groups are responsible for procedures designed to assure proper internal and disclosure controls, and all employees should cooperate with these procedures.



XII. Questions; Reporting Violations

Employees should speak with anyone in their management chain or the Legal Department when they have a question about the application of the Code of Conduct or when in doubt about how to properly act in a particular situation.

Brockwell Incorporated's Legal Department has developed and maintains reporting guidelines for employees who wish to report violations of the Code of Conduct.  These guidelines include information on making reports to the Legal Department and to an independent third party.

Brockwell Incorporated will not allow retaliation against an employee for reporting misconduct by others in good faith.  Employees must cooperate in internal investigations of potential or alleged misconduct.

Employees who violate the Code of Conduct will be subject to disciplinary action up to and including termination.


XIII. Waivers

Waivers of this Code of Conduct may be made only in a manner permitted by law.