Code of Ethics | nychallways.com

NYC Hallway and Lobbies Corporate Code of Ethics

I. Client Relationships

Fiduciary Obligations Employees shall at all times exercise loyalty to the interests of NYC Hallways and Lobbies clients and shall not engage in any activity which could be reasonably construed as contrary to the best interests of the client. Employees shall not represent personal or business interests divergent or conflicting with those of NYC Hallways and Lobbies clients, unless the client is first notified in writing of the activity or potential conflict of interest and consents in writing to allow the employee to proceed.

Confidentiality  NYC Hallways and Lobbies professional relationships with its clients are confidential and maintaining this confidentiality is essential to NYC Hallways and Lobbies business relationships. Business affairs must not be discussed with family or friends, nor discussed with other employees in public places. This duty of confidentiality applies to all information which may be proprietary or sensitive regarding clients’ businesses or information.

Employees shall not disclose to any third party any confidential or proprietary information which would be injurious or damaging to a client concerning the client’s business or personal affairs without the client’s prior written consent, unless such disclosure is required or compelled by law or regulation.

In certain cases, employees may gain knowledge of unethical or illegal activity conducted by a client. Employees should immediately report such activity to their immediate supervisors. Employees may also at a later time be required by law or regulation to disclose their knowledge of such activity to government officials.

Client Gratuities

Property and/or Monetary Gifts: Employees must receive prior written approval from their immediate supervisor before accepting any gifts from clients, their representatives, vendors, or subcontractors. In general, employees will not be allowed to accept gifts of substantial value, but they may be allowed to retain gifts of a symbolic nature.

Requested or Offered Services. Employees are allowed to receive services from clients and subcontractors only at industry rates. All work completed by a NYC Hallways and Lobbies client for an employee must be approved by the employee’s supervisor.

Socializing with Clients and Subcontractors  NYC Hallways and Lobbies recognizes the importance of employee participation in social activities provided by the client. Employees will be allowed to accept, with prior approval of their immediate supervisor, the invitation of a client to a reasonable event (e.g. Grand Opening party, Christmas party, business dinner). Reasonable events do not include vacations, recreational events that last more than a day, adult theme activities or the like. If employees are unsure about what type of events they may attend, they should consult their immediate supervisor.

Documentation of All Client Related Activities All activity with a client shall be documented and presented to the employee’s immediate supervisor who will be responsible for record maintenance. At no time are employees allowed to accept or offer anything to a client without the approval of an immediate supervisor.

Kickbacks  Kickbacks are not limited to direct cash payments. Any transaction in which employees or their families can gain personally through a transaction between NYC Hallways and Lobbies and a client or vendor is prohibited. These transactions are not only unethical but may also be illegal.

Reciprocity NYC Hallways and Lobbies often purchases goods or services from vendors who may also buy services from NYC Hallways and Lobbies. Although this is normal practice, employees must not ask vendors to buy NYC Hallways and Lobbies services in order to become or continue to be a vendor with NYC Hallways and Lobbies.

Payments to Clients  Employees shall not pay, or offer to pay, any benefit to any client or prospective client in order to induce the client to purchase NYC Hallways and Lobbies services.

II. Proper Work Conduct

Use of Contraband or Other Inebriating Substances  Possession, sale, or use of alcohol, narcotics, or any other intoxicating drug or controlled substance without a valid prescription, on the premises of NYC Hallways and Lobbies, or being under the influence of alcohol, narcotics or any other intoxicating drug or controlled substance without a valid prescription during working hours, is prohibited.

Violations of Law  All employees are expected to adhere to all federal, state, local and administrative laws, rules and regulations in and out of the office. Employees involved in the theft or misuse of NYC Hallways and Lobbies funds or property will be prosecuted to the full extent of the law.

Physical Violence All employees are expected to act in a manner above reproach in their relationships with business associates, fellow employees, competitors and the public generally. At no time should employees threaten or implement physical violence against any other person. Any threats or physical violence directed towards a NYC Hallways and Lobbies employee in the course of the performance of the employee’s job should be reported to the employee’s supervisor.

Appearance  NYC Hallways and Lobbies considers its employees to be its most important representatives. All employees should remember that their personal appearance and their attitude towards their work are a reflection of the company.

Conflicts of Interest  Employees shall not represent personal or business interests divergent or conflicting with those of NYC Hallways and Lobbies. Employees are to avoid any outside financial interests that may influence the employee’s corporate decisions. Employees are also to avoid outside employment and activities that may negatively impact their job performance, conflict with the obligations of NYC Hallways and Lobbies or negatively affect NYC Hallways and Lobbies reputation. If employees are unsure about whether a situation constitutes a conflict of interest they should discuss the matter with their immediate supervisor.

Books and Records  Employees shall not intentionally, either through deliberate omission or by entry of false information, cause NYC Hallways and Lobbies books or records to be inaccurate. Legal and regulatory practices require NYC Hallways and Lobbies to retain its books and records for a certain period of time.

Safety and conditions  To provide a clean and safe environment for its employees, NYC Hallways and Lobbies encourages all employees to report any conditions they believe to be unsafe, unhealthy or hazardous to their immediate supervisor.

Personal Relationships with Fellow Employees

Harassment and Discrimination.  NYC Hallways and Lobbies is committed to maintaining a work environment free of harassment and discrimination. In keeping with this commitment, NYC Hallways and Lobbies will not tolerate harassment of, or discrimination against, its employees by anyone, including any supervisor, co-worker, vendor or customer. Employees should consult their Employee Handbooks for a more detailed description of NYC Hallways and Lobbies harassment policy.

Sexual Conduct. NYC Hallways and Lobbies strongly advises its employees against engaging in any intimate relations with co-workers, subcontractors or clients.

Disclosure of Corporate Information  Employees shall not disclose to others outside NYC Hallways and Lobbies, or use for their benefit, any proprietary, secret or confidential information concerning NYC Hallways and Lobbies and its business of which employees become aware during their employment with NYC Hallways and Lobbies without NYC Hallways and Lobbies written consent.

If any employee has knowledge of unethical or illegal activity conducted within NYC Hallways and Lobbies or by outside agencies, the employee should immediately report such activity to their immediate supervisor. Employees may also at a later time be required by law or regulation to disclose their knowledge of such activity to government officials.

Payments to Government Employees  Employees shall not give or offer to give, or provide or offer to provide, money, gifts, services, entertainment or anything of value, directly or indirectly, to any government employee in order to induce any change in the performance of his or her responsibilities.

III. Enforcement

Employees are obligated to report any suspected violation of this Code to their immediate supervisor. NYC Hallways and Lobbies reserves the right to discipline employees by any legal method necessary to ensure adherence to proper conduct and to this Code, up to and including discharge.

Employees are expected to cooperate fully in any investigation of a suspected violation of this Code. Employees making good faith reports of suspected violations will not be subject to any reprisals. To ensure a better working environment for all employees, NYC Hallways and Lobbies encourages all employees to seek the guidance of their supervisors if they have any questions concerning this Code.