EXHIBIT 14.1
Code of Ethics
Message from the Chairman
Dear Colleague:
The latest version of ManTech's Standards of Ethics and Business Conduct is
attached for your review. This booklet contains important information on the
standards of ethics and business conduct that are expected from all employees
of ManTech International and its subsidiaries (collectively "ManTech").
The events of recent months emphasize the importance of ethics and integrity
in business. The cost of failing to maintain the highest standards can be
devastating to a business, its investors and employees. The greatest testimony
to ManTech's employees is our ability to achieve our goals and objectives in a
business environment that requires ethical business conduct that is consistent
with the highest standards of integrity. ManTech's Standards of Ethics and
Business Conduct provides direction on how ManTech employees should manage
ManTech's business activities to maintain these standards.
Our reputation is our greatest asset. Our employees should be rightfully
proud of our organization and the work we perform. I know that it takes a great
deal of effort to provide our customers with the service they deserve and an
even greater effort to maintain our corporate reputation. This is why as
Chairman, CEO and President of ManTech International Corporation, I hereby
pledge my commitment to follow and support ManTech's Standards of Ethics and
Business Conduct. As evidenced by their signatures, the senior members of
ManTech's operating subsidiaries have joined me in pledging their full
commitment and support for these Standards. We expect a similar commitment from
you and every other employee of ManTech.
Please read the attached booklet on ManTech's Standards of Ethics and
Business Conduct carefully. ManTech is counting on your compliance with the
letter and spirit of these standards as well as your assistance with
identifying and correcting any problems that may arise in the areas of business
ethics and conduct.
I recommend that you keep this booklet in a convenient place and refer to it
whenever a question arises in your mind. In the event that further
clarification is required, please contact your supervisor, your human resource
representative or the designated Corporate Ethics Program representative listed
on the last page of this booklet.
I recommend that you keep this booklet in a convenient place and refer to it
whenever a question arises in your mind propriety of a course of action. In the
event that further clarification is required, please contact your supervisor,
your human resources representative, or the designated Corporate Ethics Program
Representative listed in the last page of this booklet.
ManTech International Corporation
/s/ George J. Pedersen
Chairman of the Board CEO and President
INTRODUCTION
It is the policy of ManTech to conduct its business in accordance with the
applicable laws and ethical standards of the jurisdictions in which ManTech
operates. Each employee is required to read, understand and follow the
Standards set forth in this booklet. Moreover, ManTech will treat each employee
as having actual notice of the Standards discussed this booklet and ManTech's
requirement that they be followed. The Standards should not be considered
all-inclusive and all employees are hereby advised to refrain from engaging in
any conduct that could discredit their professional reputation or that of
ManTech. Such inappropriate acts may result in adverse employment action.
Additional guidance regarding these Standards may be obtained from your
immediate supervisor, your local Human Resources Representative, or the
Corporate Compliance Department.
COMMITMENTS
ManTech's reputation is its most valuable asset. The caliber of the
employees, the quality of the services they provide and the manner in which
they perform these services all impact ManTech's reputation. In order to
maintain and further enhance this reputation, we must fulfill commitments to
our customers, our teammates, our suppliers, our communities and each other.
ManTech's values, which form the basis of ManTech's commitment to maintaining a
high standard for business ethics, are summarized below:
. To our customers, we are committed to providing quality products and
services that meet or exceed contractual requirements and to meeting
required schedules and budgets within the parameters of applicable law
and regulation. We are also committed to the protection and handling of
classified information in accordance with established rules and
regulations.
. To our teammates and suppliers, we will practice fair competition,
seeking long-lasting business relationships and a sense of responsibility
that will enable us to be a valued customer. We will not discriminate
against potential teammates or suppliers based on race, religion, color,
national origin, age, sex, handicap or other factors not related to
ManTech's business interest. We will endeavor to protect all proprietary
information belonging to any organization that has entrusted it to us.
. To the many communities in which we reside and to society as a whole, we
are committed to responsible corporate citizenship. We will conduct
ourselves in an ethical manner in all aspects of our business. We are
committed to complying with federal, state, and local laws and
regulations.
. To our shareholders, we are committed to pursuing our growth and earnings
objectives while abiding by our ethical standards. We will exercise
prudence in the use of ManTech's corporate assets and resources.
. To our employees, we are committed to treating one another fairly and
implementing employment practices and programs related to compensation,
training, and health on the basis of equal opportunity for all employees.
We will provide safe and healthy working conditions and maintain programs
intended to prevent work-related injuries and accidents. We will conduct
ourselves professionally and treat each other with the dignity and
respect due all human beings.
STANDARDS
A. Conflicts of Interest
A conflict of interest arises in any situation that can result in a problem
between the private interests of a ManTech employee and that person's official
responsibilities on behalf of ManTech.
1. General Principle on Conflicts of Interest.
We must avoid situations, both on and off the job, where a conflict of
interest or the perception of such a conflict could result. Employees should
avoid any outside financial interest that might influence their decisions or
actions as employees of ManTech. Employees should also avoid any outside
employment or activities that could have a negative impact on the performance
of their job, that could conflict with their obligations to ManTech, or that
could affect ManTech's reputation in the community in a negative manner.
2. Use of Inside Information for Financial Gain.
ManTech employees must never use or disclose to others, inside information
(that which is not available to the general public) for any kind of personal
gain, such as through trading in shares of stock. Examples of inside
information include ManTech's pricing for services or products, burden rates,
business strategies, acquisition candidates and banking relations. Non-public
information shall not be used by any ManTech employee for private gain or
disclosed to persons other than ManTech employees or others who have a
legitimate business need for the information.
The trading of securities of publicly-traded companies while in possession of
material, nonpublic information relating to those companies must be avoided.
Liability could also extend to an employee who "tips" another person about such
information where that person, in turn, conducts securities transactions.
Tipping is a serious breach of corporate confidentiality as well as being
considered a form of insider trading. For this reason, every employee must
avoid discussing sensitive information in any place (for instance, at lunch, on
public transportation, in elevators) where such information may be heard by
others. Each of these prohibitions applies equally to family members and others
living in the same household as an employee. Employees are expected to be
responsible for the compliance with this policy by members of their immediate
family and personal household.
Information should be considered material if it would be considered important
by investors making decisions on whether to purchase, sell or hold the
securities of the company in question. Stated another way, information should
be considered "material" if it would alter the total mix of information
available to the public (for example, knowledge of merger and acquisition
discussions).
Information should be treated as being nonpublic unless a reasonable period of
time has passed since it has been distributed by means likely to result in a
general public awareness of the information. Such awareness would result, for
example, by publication of the information in a daily newspaper. As a general
rule, information may be considered to be public two business days after it has
been broadly distributed to the general public.
3. Outside Financial Interests.
A conflict of interest or the appearance of a conflict can arise when an
employee or an employee's family member holds an investment interest in or is
an employee, official or director of another enterprise, particularly if that
enterprise is a supplier of
products or services to ManTech or is a competitor of ManTech. While such
circumstances are not automatically prohibited, they are not desirable. With
the exception of relatively small holdings of stock in a publicly traded
company that does business with ManTech, such activities require prior
disclosure to and written approval of the Senior Vice President of Corporate
Compliance.
B. Dealings with Customers, Suppliers, Subcontractors, Agents, and Consultants
It is ManTech's policy to compete for business solely on the merits of its
products and services. ManTech will conduct business with its teammates and
suppliers in an ethical and honest fashion. It is a violation of these
Standards for any ManTech employee to seek a competitive advantage through the
use of gifts, gratuities, entertainment or other favors.
1. General Principle regarding Gifts and Gratuities
Under no circumstances may we offer or give gifts of money or other
gratuities to a customer or a customer's representative in an effort to
influence a contract award or other favorable customer action. Further, the
acceptance of a gift of money from a supplier, vendor, subcontractor or
consultant is also prohibited.
Employees may accept unsolicited, non-monetary gifts from a firm or
individual doing, or seeking to do, business with ManTech only if the gift is
of nominal value or is of an advertising/promotional nature. For purposes of
this paragraph, "nominal value" shall mean an amount not greater than Fifty
Dollars ($50).
2. Gifts in Foreign Countries or to Foreign Nationals.
Customary business practice in some foreign countries may call for the
exchange of gifts. In cases where it is necessary to meet such a requirement,
only ManTech may provide the gift and any gifts received will become ManTech
property. Such gifts may only be made after consultation with the Corporate
Compliance Department.
3. Kickbacks.
Employees (or their families) may not personally receive kickbacks, rebates,
or anything else of value in exchange for the purchase or sale of goods or
services to ManTech. Kickbacks or "rebates" can take many forms and are not
limited to direct cash payments or credits. In general, if you or your family
are in a position to gain personally through a purchase or sales transaction
with ManTech, that transaction is prohibited. Such practices are unethical and
may be against the law.
4. ManTech's Purchasing Policies
Whenever possible, materials, supplies, equipment, and other services
purchased by ManTech should be procured from qualified suppliers at the lowest
reasonable cost, keeping in mind the requirements for quality, performance and
the vendor's ability to meet delivery schedules. Whenever feasible, we will
encourage, establish and maintain competition among potential suppliers
qualified for the award of contracts. We will comply with applicable Government
regulations and contractual requirements governing ManTech's purchasing power,
including those pertaining to small, minority-owned, or
women/disadvantaged-owned businesses.
5. Other Improper Payments
Any payment which is improper when made by an employee is also improper if
made by an agent, consultant, or other third party on behalf of ManTech. In
addition, paying a third party for any purpose other than disclosed on the
supporting documentation is strictly forbidden.
C. Antitrust or Anticompetitive Behavior
A wide range of transactions or practices is prohibited under the antitrust
laws of the United States. No agreement or understanding may be made with
competitors to fix or control prices; to allocate products, customers, markets,
or territories; to boycott certain customers or suppliers; to exchange
information with our competitors about prices; or to refrain from or limit the
manufacture, sale or production of any product.
Antitrust laws sometimes restrict the use of joint ventures to produce or
market a product or service. Teaming agreements, which are frequently used to
bid for work under government contracts, may also be governed by the antitrust
laws. In general, joint ventures and teaming agreements are not prohibited
where cooperation between companies is necessary to provide the products or
services under the contract, which the companies are not able to provide on
their own. If ManTech is
considering forming a joint venture or participating in a teaming agreement
with another company to bid on a government contract, that fact may have to be
disclosed to the Government in advance.
D. Quality/Testing
It is our responsibility to ensure that our products and their components
are designed and manufactured to meet the appropriate inspection criteria of
our customers, to perform the testing necessary to demonstrate that these
criteria have been met, and to provide the necessary documentation. The
inspection and testing documentation must be complete, accurate and truthful.
If a contract requires that goods from a particular source be used, this
obligation must be fulfilled. If specified products are not available, ManTech
will not accept any substitute materials, even if they might be equivalent in
form, without informing the appropriate customer.
If a product or design required by a customer is judged to be unsafe to the
users of the product, the customer should be formally advised of this condition
as soon as it is known.
E. ManTech, Customer and Other Third Party Resources
ManTech, customer and other third party resources include labor, technology,
buildings, land, equipment, confidential information, trade secrets, literary
works, intellectual property such as patents and copyrights, and cash.
1. Use of ManTech, Customer and Other Third Party Resources.
No employee may make improper use of ManTech, customer or third party
resources or permit others to do so. Examples of improper use of resources
include: unauthorized use of language of another author and the representation
of that language as one's own, unauthorized appropriation or use of ManTech,
customer or other third party assets such as telephones, supplies and
materials; technology and patents; software; computer and copying equipment;
and alteration, destruction or disclosure of data. If assets that are no longer
needed by ManTech are sold to employees, all such sales must be supported by
proper documentation and approved by an authority other than the employee.
2. Confidential Information, Technology, and Trade Secrets
One of ManTech's strengths is our ability to develop and use technological
products and services in our day-to-day operations. We are therefore all
responsible for safe-guarding ManTech's confidential information, technology,
and trade secrets against unauthorized disclosure. This responsibility also
includes protection of proprietary data developed or purchased by us or
entrusted to us by customers, teammates, prime-contractors, sub-contractors,
joint-venture partners or suppliers. These restrictions apply whether the
information is in written or electronic form or is simply known by us.
. Employees may not disclose or use ManTech or customer proprietary
information except as required by the normal business activity of ManTech
in meeting its contractual obligations to customers. All such disclosures
shall be made pursuant to relevant disclosure obligations.
. Employees may not take, disclose, or use ManTech or customer proprietary
information upon terminating employment with ManTech unless authorized in
writing to do so by a Vice President or President of the relevant ManTech
subsidiary.
. Employees must disclose in writing to ManTech any inventions and
copyrights arising out of his or her employment by ManTech. All
inventions and copyrights discovered, conceived or implemented either
alone or jointly with others, during ManTech work hours or with ManTech
resources are deemed assigned to ManTech as such rights arise.
These obligations are thoroughly discussed in the Confidentiality, Inventions
and Non-Solicitation Agreement that you already signed with ManTech.
3. Cash and Bank Accounts
All cash and bank account transactions must be handled carefully so as to
avoid any question or appearance of bribery, kickbacks, other illegal or
improper payment, or any suspicion of impropriety whatsoever. All cash
transactions must be recorded in ManTech's books of account.
All accounts shall be established and maintained in the name of ManTech,
with the exception of petty cash accounts. All transactions and accounts
involving ManTech funds shall be clearly and accurately identified in ManTech's
books and records. All cash received shall be promptly recorded on its books
and deposited in a ManTech bank account. No funds shall be maintained in the
form of cash, except as required for normal business operations.
F. Political Contributions
1. Federal Elections.
Federal law prohibits corporations from making contributions or expenditures
in federal elections. It is imperative that no ManTech funds or assets are
contributed or loaned, directly or indirectly, to any political party, campaign
or candidate, or expended to support opposition to a federal party, campaign or
candidate.
While ManTech's corporate money may not be used in federal elections,
ManTech has established a separate fund, called a political action committee
("PAC"), to raise voluntary contributions from employees for use in federal
elections. Contributions to ManTech's PAC are voluntary and employees who do
not contribute will not be subject to job discrimination or threats of reprisal.
2. State and Local Elections.
ManTech's ability to make political contributions in state and local
elections depends upon the laws of the state and/or locality of the election.
Accordingly, no ManTech employee may commit ManTech funds or resources in any
way in a state or local election without the prior review and approval of the
Senior Vice President of Corporate Compliance.
3. Political Activity.
ManTech encourages all employees to participate on an individual basis in
political activities that interest them, on their own time and in their own way.
G. International Business
1. General Principles.
ManTech has global business operations and special care must be taken by
employees to identify and accommodate the various customs and expectations that
exist in the international markets. Laws vary widely from country to country,
and may conflict with one another. Our policy is to comply with all laws that
apply in the countries where we do business to the maximum extent permissible
by United States law.
2. Export Restrictions.
Export of ManTech's products or services and disclosure of the technology
involved in such products or services are subject to several laws and
regulations. It is essential that ManTech comply with all export control and
licensing requirements by obtaining proper permits and approvals from relevant
government agencies. Because of the complexity of the laws in this area,
employees having questions about the appropriate practice in a particular
situation should seek guidance from the Legal Department through their
supervisor.
3. Payments to Foreign Officials.
Employees should be particularly mindful of the prohibitions of the Foreign
Corrupt Practices Act. This act prohibits payments or gifts to any foreign
official, political party, party official, member of a ruling family, or any
other person acting on behalf of a foreign nation in order to obtain or retain
business, or to direct business to ManTech or to some other person or entity.
All such payments are prohibited by the Foreign Corrupt Practices Act, whether
made directly or indirectly through a third party. Prior to taking such action,
each proposal to make payments or gifts to foreign persons or entities should
be reviewed by the Corporate Compliance Department in coordination with the
Legal Department.
H. Doing Business With the U.S. Government
Much of ManTech's business involves a close working relationship with
branches of the U.S. government. Therefore, ManTech employees working on
projects for which the ultimate customer is the U.S. government must be aware
of and comply with the laws, rules, and regulations that govern the acquisition
of goods and services by the U.S. government. ManTech also requires its
business partners, suppliers, and consultants to be aware of and comply with
these legal requirements.
1. Security
ManTech has a special obligation to comply with those Government regulations
and laws that protect our nation's security and safeguard our nation's defense
secrets, including classified information. As employees, security is an
integral part of our jobs, whether or not we work directly with classified
information. Any employee who observes or gains knowledge of a potential
violation of the security regulations and/or laws relating to classified or
government information must immediately report it to the respective ManTech
Facility Security Officer or the Corporate Compliance Department.
Employees possessing a valid security clearance and requiring access to
specific classified information will ensure that such information, in whatever
form it exists, is handled in strict compliance with the procedures set forth
by the Department of Defense for safeguarding classified information.
ManTech employees should not seek access to, accept or retain any classified
information for which they have no need or to which they are not entitled. The
unauthorized possession or disclosure of classified information in any form, or
failure to properly safeguard such information, can endanger the security of
this country and is punishable under the Espionage Laws and other Federal
Criminal Statutes.
2. Procurement Integrity - Procurement Sensitive Information
ManTech competes fairly and ethically for all of its business opportunities.
Therefore ManTech will not conduct business with any business partner, dealer,
agent, or consultant involved in the unauthorized disclosure or use of
procurement-sensitive or classified information about a procurement. This
prohibition includes disclosing information about competitors' bids or
proposals, or obtaining such information through improper or illegal means.
Persons with access to proprietary or source selection information may disclose
such information only to a person specifically authorized to receive it.
3. Procurement Integrity - Dealings with Government Procurement Officials.
The procurement integrity laws impose certain restrictions on the activities
of government procurement officials and their contractor counterparts when they
are engaged personally and substantially in a government procurement. In
general, prohibited activities include: (1) offering, discussing, or accepting
post government employment or business opportunities, (2) offering or accepting
any money, gratuity, or other thing of value, or (3) soliciting, obtaining, or
disclosing any bid or proposal information, proprietary or source selection
information. Because of the complexity of the laws and the significant
penalties that can be imposed for violations of these laws, only ManTech's
Senior Management and Human Resources Officials are authorized to conduct
employment discussions with any U.S. federal agency employees or former
employees. Employees should refer questions covering the laws, requirements or
possible violations of the law to their supervisor and, if deemed necessary,
the Corporate Compliance Department. Proper advice should be obtained in
advance of any action that could be perceived as a possible violation of the
law.
4. Procurement Integrity - Truth in Negotiations.
Under the Truth in Negotiations Act, employees involved in the negotiation
of contracts or other business transactions related to U.S. government
procurement must ensure that all cost and pricing data is provided, to the
extent required, to the U.S. government and that it is current, accurate, and
complete; and that any other statements, communication, certificates, and
representations to customers' representatives are accurate and truthful. In
addition, any employee signing any certification or representation on behalf of
ManTech should ensure it is accurate and truthful before signing.
5. Lobbying - Use of appropriated funds.
U.S. government appropriated funds (funds derived from federal contracts)
may not be used to pay anyone to influence, or attempt to influence, anyone
employed by the Executive or Legislative Branches, including members of
Congress and their staffs, in connection with the award of U.S. government
contracts or contract modifications.
6. Time Sheet Reporting
Timely and accurate completion of time sheets by all employees is essential.
Employees must ensure that costs are recorded to the proper direct (contract)
or indirect activity in accordance with contract terms or regulation. A summary
of time keeping procedures are enumerated below. Please refer to the Corporate
Policy manual for complete context of the Timekeeping Policy.
a. Employees should personally record their time on their time sheets.
Execution and submission of a time sheet creates a certification as to the
accuracy of the time sheet whether by electronic or manual means.
b. Time sheets should be filled out daily. Paper time sheets must be
completed in ink.
c. Employees should record time actually worked in accordance with Policy
310.0/310.100 and Policy 234.0/234.100.
d. Corrections to submitted time sheet should be done in accordance with
policy. No erasures or white out allowed.
e. Corrections/adjustments to submitted time sheets should be submitted
on the ManTech Labor Adjustment form as soon as such corrections/adjustments
become known.
f. Supervisors should provide each employee with a "Work Authorization
Form" identifying account codes and descriptions for any activity on which
the employee will perform tasking.
g. Supervisors should review the time sheets and labor adjustment forms
for accuracy and completeness. They should certify as to the accuracy by
approving the timesheet with their signature (electronically or manually).
7. Restrictions on Former Government Employees
There are specific rules and regulations that place certain limits on the
duties that former U.S. Government employees (military or civilian) may perform
as employees of ManTech. As a general guide, no former Government employees
should represent ManTech in dealings with the Government on (i) any project in
which they were substantially involved while in Government service, or (ii) any
project for which they had responsibility during the two (2) year period before
they left Government service. In addition, certain former Senior Government
employees should not communicate with their former department or agency on any
business matter for one year after leaving the Government.
Senior Government employees are: (a) those who were compensated at the
executive level; (b) active-duty Armed Services officers compensated at a pay
grade of 0-9 or above; (c) employees designated as having significant
decision-making or supervisory responsibilities and who were compensated as a
GS-17 or above; and (d) former active duty Armed Services officers having had
significant decision-making or supervisory responsibility and who were
compensated at a pay grade of 0-7 or 0-8.
These laws prohibit the former official or employee from appearing before or
communicating to the government agency on behalf of another person. The former
official or employee may, however, work on or provide advice about matters
pending before government agencies "behind the scenes" here at ManTech.
However, because of the complexities of the laws, employees should refer
questions regarding whether a former Government employee, who is currently a
ManTech employee, may participate in a project, presentation or contact with a
Government agency to their supervisor or to the Corporate Compliance Department.
I. Books and Records
1. Falsification of Books and Records
Federal law requires that ManTech's books and records accurately reflect the
nature of the transactions represented. ManTech will maintain its books and
records in accordance with the Generally Accepted Accounting Principles. It is
a violation of these Standards for any employee to cause ManTech's books and
records to be inaccurate. Employees may not create or participate in the
creation of any records that are intended to mislead or to conceal anything
improper. Examples of prohibited conduct:
a. Making records appear as though payments were made to one person when,
in fact, they were made to another;
b. Submitting expense accounts which do not accurately reflect the true
nature of the expense;
c. Creation of records that do not accurately reflect the true nature of
the transaction.
d. Creation of "slush fund," hidden, or "off-book" accounts, where there
is no accounting for receipts or expenditures on corporate books.
2. Retention of Books and Records.
Federal and state law require that ManTech retain certain records for
various periods of time, including tax, employment, health and safety records,
and records relating to government contracts. In addition, when litigation or a
government investigation or audit is pending, relevant records cannot be
destroyed or otherwise disposed of until the matter is closed and only then if
doing so is within the terms of the investigation or audit close-out.
Destruction of records relevant to a legal proceeding, audit, or investigation
may be a violation of law. All approved documents destruction should be
conducted in strict compliance with ManTech's document destruction policy.
J. Drug Free Workplace/Workforce
1. General Principles.
All ManTech employees and worksites should be drug-free. The unlawful
manufacture, distribution, dispensing, possession or use of controlled
substances by employees on ManTech or assigned premises is strictly prohibited.
Employees who violate this policy will be subject to adverse employment action,
up to and including discharge. After prior consultation with Corporate Human
Resources, illegal drug use may be reported to the proper authorities
ManTech employees working at non-ManTech locations are subject to these
Standards and are also expected to comply with related regulations at the host
site, whether it is that of a customer or another company with which ManTech
has a business relationship.
2. Employee Assistance.
Confidential employee assistance on drug abuse (and other personal or family
problems) is available to employees and their families through a
ManTech-provided counseling and referral service. Any employee or family member
can reach a nation-wide network of Employee Assistance Programs through a
24-hour toll-free telephone line (800/225-8451).
If a supervisor/manager perceives a possible drug problem, he/she must
consult with the appropriate Human Resources representative about the process
of intervention with the employee. Referral to the Employee Assistance Program
should not be made in lieu of regular disciplinary action.
3. Violations of the Drug Policy.
With respect to violations of this Policy the employee may be terminated in
any of the following circumstances:
a. Confirmed illegal drug abuse and refusal to accept counseling or seek
rehabilitation.
b. Failure to be rehabilitated after a reasonable period of assistance
and suspension.
c. Manufacture, trafficking, possession or use of illegal drugs on
ManTech premises or the premises of ManTech business partners.
d. Conviction of an illegal drug offense, whether the offense occurred on
ManTech premises or elsewhere.
4. Reporting of Drug Offenses.
If an employee is convicted of a criminal drug offense, the employee is
required to inform ManTech within five (5) days. Depending on the customer, the
contract type and/or the position held by the convicted employee, ManTech may
have an obligation to notify the contracting officer(s) of the employee's
conviction. In addition, for employees holding a security clearance, ManTech is
required to report such convictions to the appropriate security officials.
K. Reporting Wrongdoing
Each ManTech employee has a duty to report any actual or suspected violation
of these Standards. If any employee reasonably suspects that any employee or
agent is involved in any sort of wrongdoing, has violated or is violating these
Standards, the employee must immediately report those suspicions. In the event
that an employee feels that their report has not received appropriate
attention, the employee shall report that information to the Corporate
Compliance or Human Resources Departments.
ManTech encourages employee discussion with appropriate personnel regarding
suggestions for preventing potential violations of these Standards. ManTech
urges employees to work with their supervisors and their designated Ethics
Representatives on these matters. However, if circumstances preclude effective
resolution through these channels, employees should contact the Corporate
Compliance Department directly. Employees who provide information may do so
verbally or in writing. All information will be treated in confidence and
ManTech will protect the anonymity of the employee to the maximum extent
practicable.
HELP AND INFORMATION
ManTech has designated a number of personnel to assist its employees in
resolving any questions involving ethics and conduct. Do not hesitate to seek
help as needed.
Supervisors
Any employee that needs help or information regarding these Standards is
encouraged to consult with his or her immediate supervisor. When this is not
feasible, the employee should discuss the matter with the local or corporate
Ethics Representative.
Ethics Program Representatives
The respective Human Resource Representatives have been designated as the
local Ethics Program Representatives for each ManTech operation. These
individuals have been identified to provide assistance to line management in
the execution of these Standards.
Operations Compliance Representatives
In addition to the local Human Resources staff, the Group Presidents have
designated senior staff members as Compliance Representatives for their
respective organizations. It is the responsibility of these representatives to
promote, reinforce and assist in the enforcement and execution of these
standards. Please contact your supervisor or the Sr. Vice President of
Corporate Compliance for the name of the Compliance Representative for your
organization.
Senior Vice President of Corporate Compliance/Senior Vice President of Human
Resources
These senior corporate representatives will respond to inquiries and resolve
questions from the ManTech Human Resource Representatives as to actual or
suspected violations of these Standards. They are also available to provide
assistance to line management and employees with regard to these Standards.
Ethics Hotline
For those circumstances warranting complete anonymity of the employee, the
Corporation has established an anonymous ethics hotline that is maintained by
the Corporate Compliance office. The hotline is available to all employees
Monday through Friday from 10:00 AM to 4:00 PM Eastern time.
Ethics Program Corporate Representatives Contacts:
1. Diane Moberg, Sr. Vice President, Corporate Compliance (703) 218-6309
2. David Scarfpin, Director Internal Audit (703) 218-6491
3. Margo Mentus, Sr. Vice President, Human Resources (703) 218-6008
Ethics Hotline: Toll Free: (877) 637-8892 DC Metro: (703) 218-6120
DISCIPLINARY ACTIONS
Violations of these Standards will not be tolerated. Disciplinary action
will be taken:
. against employees who authorize or participate in actions which are a
violation of these Standards;
. against employees who deliberately fail to report a violation of these
Standards or who deliberately withholds relevant and material
information concerning a violation of these Standards;
. against supervisors and management employees, to the extent that the
circumstances of the violation reflect inadequate supervision or a
lack of diligence;
. against supervisors or management employees that retaliate, directly
or indirectly, or encourage or knowingly permit others to retaliate,
against employees who report violations of these Standards.
Disciplinary action will result in one or more of the following sanctions,
as appropriate:
. Verbal Warning;
. Written Reprimand (to be part of the employee's permanent personnel
record);
. Probation;
. Demotion;
. Suspension;
. Discharge;
. Required reimbursement of losses or damages;
. Referral for criminal prosecution or civil action.
As with all matters involving disciplinary action, principles of fairness
will apply. Any allegation of a violation of these Standards will be reviewed
and any employee charged with a violation of this code will be afforded an
opportunity to explain his/her actions before any adverse disciplinary action
is taken.
SUMMARY
ManTech seeks to conduct business at the highest possible ethical standards.
As a result, ManTech's employees are responsible for ensuring that our personal
conduct is above reproach. In cases where employees become aware of suspected
violations of these Standards, they should report the situation to their
supervisor(s) or Ethics/Compliance Representative(s).
These Standards will be enforced consistently in all subsidiaries and at all
levels of ManTech. ManTech will keep confidential, to the extent possible, the
identity of anyone reporting a possible or actual violation of these Standards
subject to ManTech's Policy and Procedure and its obligations under the law.
Ethical conduct is everyone's obligation and the maintenance of these
Standards is dependent on the collective judgment, knowledge and courage of all
ManTech employees.
In addition to the local Human Resources staff, the Group Presidents have
designated senior staff members as Compliance Representatives for their
respective organizations. It is the responsibility of these representatives to
promote, reinforce and assist in the enforcement and execution of these
standards. Please contact your supervisor or the Sr. Vice President of
Corporate Compliance for the name of the Compliance Representative for your
organization.
Please fill in the required information below, sign and return this page
immediately to your Human Resources Representative.
ACKNOWLEDGEMENT
I have read and understand the ManTech International Corporation booklet,
"Standards of Ethics and Business Conduct" and agree to comply with the
policies set forth therein.
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Name (please print)
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Subsidiary Company
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Location
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Signature
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Date