ANTI CORRUPTION EFFORTS & POLICIES

The V2X values of integrity, respect, responsibility, and professionalism are the foundation for the way V2X conducts business. In line with the vision and values, corruption is never permitted nad all employees and partners are expected to adhere to all applicable anti-corruption laws and regulations, which include the U.S. Foreign Corrupt Practices Act (FCPA), UK Bribery Act, and similar laws in the countries where we operate. Specifically, employees and partners must not:

Directly or indirectly offer, authorize, promise or give bribes, kickbacks, payoffs, or other payments to any U.S. or non U.S. government officials to influence their judgement or ensure a particular outcome or action
Directly or indirectly offer, authorize, promise or give bribes, kickbacks, payoffs or other payments to commercial (non-government) customers in order to obtain or retain business; or an advantage in the conduct of business
Directly or indirectly request, agree to receive or accept kickbacks, payoffs or other personal payments in connection with V2X business

These mandates are true under all circumstances, even if making such payments is customary under local practices. Employees and partners must also avoid any actions that may create even the appearance of improperly influencing a government official or commercial customer. Any exceptions to this policy must be in writing and approved by the V2X Chief Legal Officer.

This policy is applicable to all employees, vendors, subcontractors, and business partners of V2X and all V2X programs, projects and affiliated operations worldwide. For more information, please read:

THE LEGAL STANDARD

The United Stated Foreign Corrupt Practices Act prohibits a company’s employees, as well as its Third Parties, from offering or providing money or anything of value to officials or employees of foreign governments, including persons who work at state owned or controlled enterprises if offered or given in order to obtain an improper business advantage. The UK Bribery Act prohibits a company’s employees as well as its third parties from bribery of Foreign Officials, Commercial Bribery, and failing to prevent bribery.

A Resource Guide to the U.S. Foreign Corrupt Practices Act

The Bribery Act - Quick Start Guide

The Bribery Act - Guidance

ANTI-CORRUPTION TRAINING & V2X UNIVERSITY

It is important that employees understand their responsibilities regarding anti-corruption. Therefore, V2X has developed a training program that covers company policies and procedures, instruction on applicable laws, practical advice to address real-life scenarios, and case studies. The training is designed to ensure that employees understand their responsibilities and include courses on:

Anti-Corruption Training Courses
Anti-Bribery: Working Responsibly with Third Parties Course
Anti-Bribery: Questionable Conduct