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Code of Ethics

Our Mission and Values: We never Compromise Our Ethics and Integrity

Introduction Our Mission and Values: We never Compromise Our Ethics and Integrity At Stenson Tamaddon, we are driven to bring innovative and result-oriented solutions to our clients—while never compromising our commitment to the highest standards of ethical conduct and integrity. Each of us plays a role in shaping our culture and protecting our hard-earned reputation and brand.

This Code of Ethics reflects our deep commitment to our people, clients, and brand, and it reflects our core values. By applying these principles every day, we will make smart business decisions, continue to build trust with our clients and partners, and foster our values-based culture of forward-thinking, partnership, ethics, and reliability.

This Code of Ethics is an investment—in our reputation, brand, and our team—and we are all shareholders. Every day, we all must strive to build trust within our teams, with our clients and partners, and with the community. We build this trust by always acting ethically and within the letter and spirit of the law. To that end, every employee must know, understand, and comply with our Code of Ethics and the policies incorporated into this Code.

If you have an ethical or compliance question or concern, I urge you to raise them through the StenTam Speak Up Program, as outlined in this Code.

Thank you for your dedication and all that your do.

At Stenson Tamaddon, we are driven to bring innovative and result-oriented solutions to our clients—while never compromising our commitment to the highest standards of ethical conduct and integrity.

Eric Stenson, Founder & CEO

Ryan Louis, Founder & Partner

Our Values

Forward-Thinking      Ethics

Partnership       Reliability

Always Act With Integrity

Why do we have a code of ethics?

StenTam and its leadership are committed to conducting our business in an accountable, transparent, and ethical manner. This Code sets forth our commitment to always doing the right thing and aids us in making good and ethical business decisions. Compliance with the law and this Code must guide all aspects of our business. We are all required to understand and comply with the obligations and standards outlined in the Code. Failure to comply may result in discipline, up to and including termination.

This Code of Ethics is our road map that guides how we conduct ourselves and govern our business and incorporates StenTam’s policies, standards, and procedures.

Our goal is to act lawfully and ethically at all times. This Code and our underlying policies cannot address every situation that may arise, but by following the letter and the spirit of this Code and our policies, we can maintain and protect our reputation and achieve continued success. If the Code does not specifically address a situation or you are unsure about the right course of action, before acting, always consult with your supervisor or Legal.

Our Core Values

Forward-Thinking

We achieve results by being confident and candid about our business, and we protect our proprietary technology.

Partnership

We provide our customers with personalized, professional
support, while always being honest and transparent.

Ethics

Trust is our bedrock principle. We treat others with respect and
dignity, we are committed to making a positive difference, and
we speak up when we see questionable or illegal conduct.

Reliability

We always do the right thing and act within the letter and spirit
of the law while we continue to deliver value to our clients.

Our Code Applies to Everyone

This Code applies to everyone in our Company (without regard to geographic location), including subsidiaries, and we expect everyone with whom we do business will comply with our expectations.

The principles set forth in this Code must be at the core of every decision you make and every action you take.

When in doubt, ask! Asking a question is often the best way to determine if an action is lawful and to ensure compliance with applicable laws or StenTam policies. If you are unsure if a proposed action is appropriate, stop and seek guidance before you act!

StenTam’s Chief Legal Officer is responsible for monitoring and enforcing this Code. Any waiver of our Code requires the prior written approval of the Chief Legal Officer, or his designee.

This Code does not constitute a contract, guarantee of employment, create any specific employment rights or other procedural or substantive rights.

Individual Responsibility – You are Part
of Our Commitment to Compliance

We are all individually responsible for protecting our hard-earned reputation and brand. Your compliance with this Code and StenTam’s policies, standards, and procedures is a crucial part of protecting our reputation and brand.

It is your responsibility to understand and comply with the Code and the policies that apply to the work you do and the decisions you make. If you violate the law, this Code, or Company policies, standards, and procedures, you will be subject to disciplinary or corrective action or other legal consequences. Disciplinary or corrective action may include counseling, additional training, termination, or other appropriate action. In addition, compliance with this Code and Company policies, standards, and procedures is an essential component of your performance reviews, eligibility for bonuses, and promotions. Finally, a violation of the law could result in criminal and/or civil penalties imposed by a government agency or court.

 

Faced with a Difficult Decision?
Consider the Following:

  • Is the action or decision legal and consistent with StenTam’s code, policies, and any applicable law?
  • Am I putting myself, others, or the Company’s property or
    assets at risk?
  • How will my action or decision look on the Internet, a newspaper, or in a courtroom?
  • Will the action or decision harm StenTam’s reputation or brand?
  • Am I acting transparently, honestly, and truthfully?

Our Code Applies to Everyone

This Code applies to everyone in our Company (without regard to geographic location), including subsidiaries, and we expect everyone with whom we do business will comply with our expectations.

The principles set forth in this Code must be at the core of every decision you make and every action you take.

When in doubt, ask! Asking a question is often the best way to determine if an action is lawful and to ensure compliance with applicable laws or StenTam policies. If you are unsure if a proposed action is appropriate, stop and seek guidance before you act!

StenTam’s Chief Legal Officer is responsible for monitoring and enforcing this Code. Any waiver of our Code requires the prior written approval of the Chief Legal Officer, or his designee.

This Code does not constitute a contract, guarantee of employment, create any specific employment rights or other procedural or substantive rights.

Speak Up

If you see, hear, or learn of any actual or suspected violation of this Code of Ethics, Company policies, standards, or procedures, or the law, we want, encourage, and expect you to report it. Under StenTam’s Speak Up Program, you can report in good faith—even anonymously—any actual or suspected violation, and StenTam is committed to providing a safe reporting environment.

To protect yourself, your teammates, and StenTam, any person who learns of or suspects a violation of this Code, Company policies, standards, or procedures, or the law or regulations in the jurisdictions where we do business, should report his or her suspicion promptly via the following channels:

  • StenTam’s Speak Up Hotline
  • StenTam’s Legal Department
  • Human Resources
  • Any executive, supervisor, or manager

We encourage reporters to provide contact information and the confidentiality of all reports will be respected and will be limited to only those people who have a legitimate reason to know. Nonetheless, we will always accept anonymous reports.

Why it Matters

Unreported misconduct can have severe consequences for you, your colleagues, and the Company. Undisclosed misconduct can result in significant financial consequences for StenTam, the loss of jobs to uninvolved employees, and criminal and/or civil sanctions for those involved.

Ethical Leadership Matters

As a manager or supervisor, you are also responsible for:

  • Creating a culture of compliance and serving as an example by acting with the highest ethical standards.
  • Promoting a collaborative atmosphere and fostering an environment for raising questions and addressing compliance issues that come to your attention.
  • Ensuring and confirming that your direct reports understand and apply the standards outlined in this Code and StenTam’s policies, standard, and procedures.
  • Setting, monitoring, and enforcing performance goals consistent with this Code, Company policies, standards, and procedures and regulatory obligations.
  • Providing appropriate corrective action when this Code or StenTam’s policies, standards, or procedures are violated.
  • Enforcing and supporting StenTam’s non-retaliation policy against any person who reports in good faith any suspected violation of law, this Code, or Company policies, standards, or procedures.

Lead by Example

Encourage Ethical Decision Making

Reward Integrity

Prevent Retaliation

Foster a Safe Work Environment

Our Core Policies

All employees are required to learn and comply with StenTam’s policies.

Conflicts of Interest

StenTam is committed to reducing and avoiding conflicts of interest. A conflict of interest is any situation or activity that involves, appears to involve, or creates the perception of a conflict between your personal or financial interests and StenTam’s interests. A conflict of interest may interfere with your obligation to objectively and effectively perform your work in the best interest of StenTam. A conflict of interest may include participation in outside activities, personal interests, or financial interests.

  • StenTam is committed to reducing and avoiding conflicts of interest and candidly, openly, and honestly communicating and interacting with its employees. Employees are expected to do the same when dealing with StenTam. No employee should have, or appear to have, an undisclosed conflict of interest, as defined by the StenTam Conflict of Interest Policy.
  • When required by the StenTam Conflict of Interest Policy, you must report, in writing, a conflict or potential conflict of interest to the Chief Legal Officer, or his designee.

Why it Matters

Promptly disclose any actual or potential conflict of interest. If a conflict of interest exists, waivers will be considered and granted on a case-by-case basis.
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