boozallen-code-of-ethics

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boozallen-code-of-ethics

GREENLiving Our Core ValuesThe Booz Allen Hamilton Code ofBusiness Ethics and ConductBOOK


Table of contentsIntroduction: Living Our Core Values . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .3Chapter I: Getting It Right . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .41. Our Ethics Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .52. Ethics at Work . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .53. Non-Retaliation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .84. Mandatory Reporting of Violations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .85. Cooperation with Internal Investigations and Government Oversight . . . . . . . . .96. Disciplinary Principles . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .11Chapter II: Competing for Work and Serving Our Clients . . . . . . . . . . . . . . . . . . . . .121. Competing for Work . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .122. Accepting Engagements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .143. Performing Client Engagements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .164. Conducting Business Internationally . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17Chapter III: Time and Expense Reporting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .191. Time Reporting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .192. Expense Reimbursement and Reporting . . . . . . . . . . . . . . . . . . . . . . . . . . . . .21Chapter IV: Creating the Absolute Best Place to Work . . . . . . . . . . . . . . . . . . . . . .231. Encouraging Diversity and Teamwork . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .232. Manager Responsibilities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .243. Workplace Security and Safetyand Reporting Certain Criminal Charges and Convictions . . . . . . . . . . . . . . . .254. Drugs and Alcohol in the Workplace . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .26Chapter V: Confidentiality and Protection of Information . . . . . . . . . . . . . . . . . . . . .271. Confidentiality of Client and Third Party Information . . . . . . . . . . . . . . . . . . . .272. Security Clearances and Protecting Classified Information . . . . . . . . . . . . . . .303. Firm Information and Ownership of Work Product . . . . . . . . . . . . . . . . . . . . . .304. Insider Trading . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .315. Technology Resource Usage, Access, and Security . . . . . . . . . . . . . . . . . . . . .326. Records Retention; Accuracy of Records and Entries . . . . . . . . . . . . . . . . . . . .33Chapter VI: Conflicts of Interest . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .351. Organizational Conflicts of Interest . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .352. Personal Conflicts of Interest . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .363. Personal Conflicts of Interest from Outside Activities . . . . . . . . . . . . . . . . . . .374. Gifts, Gratuities, and Business Courtesies . . . . . . . . . . . . . . . . . . . . . . . . . . .395. Post-Government Employment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .406. Use of the Firm Name/Marks . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .407. Corporate Opportunities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .418. Political Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .42Chapter VII: Subcontracting and Purchasing on Behalf of the Firm . . . . . . . . . . . . .431. Fair Competition Among Suppliers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .432. Boycotts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .44Chapter VIII: Modeling Corporate Citizenship and Fairly Representing Ourselves . . .461. Representing the Firm to the Public and Media . . . . . . . . . . . . . . . . . . . . . . . .462. Investor Relations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 473. Lobbying . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 474. Environmental Commitment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .485. Community Involvement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .49Index . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .51The Booz Allen Hamilton Code of Business Ethics and Conduct | GREEN BOOK 1


Entrepreneurshipcore valuesClient serviceRESPECTF A I R N E S SINTEGRITYT R U S TProfessionalismExcellenceteamworkDIVERSITY2THE GREEN BOOK | The Booz Allen Hamilton Code of Business Ethics and Conduct


Introduction: Living Our Core ValuesOur Core Values are not simply statements of principle or aspirations for what we endeavorto achieve—they are bonds that connect us in everything we do.They represent a commitment from Booz Allen and, indeed, each of us, to our clients,letting them know what they can expect when they receive our services. They alsorepresent an understanding between the firm and its employees regarding the standardsthat we adhere to in conducting our business and working with each other. Finally, ourCore Values bind our firm’s past to our present and our future, representing the enduringcharacter of Booz Allen and what makes it unique and distinctive as an organization.Our Green Book translatesour Core Values intoaction and connectsthem to our operatingpolicies and procedures.It explains how we upholdour commitment to ethicalbusiness and adhere toboth the letter and spirit oflaws and regulations thatapply to us.Accordingly, while ourGreen Book is composedof many discrete itemsspanning a vast array ofsubjects, it should beviewed as a compositewhole—not a collectionof component parts. Itdoes not address eachrule applicable to ourbusiness or every difficultdecision that each ofus may have to make.Instead, it provides anunderstanding of how weas an organization thinkabout these issues and, asimportant, information onthe resources and supportavailable to each of uswhen confronted with anethical challenge at work.ooooooWorking at Booz Allen Hamilton provides unparalleled professional opportunitiesfor you to achieve your absolute best:A values-based, inclusive culture that encouragesindependent thinking and continuous learning andindividual initiativePride in a client-centric organization focused onresultsInspiration from collaborating with leaders andcolleagues in the relentless pursuit of innovativesolutionsooooAn opportunity to grow through meaningful work indiverse assignmentsResources that allow you to thrive at work, in yourcommunity, and at homeThe Booz Allen Hamilton Code of Business Ethics and Conduct | GREEN BOOK 3


Chapter I: Getting It RightA fundamental notion underlying ethical business is that whileeach of us acts individually, we do not act in isolation—each of ouractions affects those around us and radiates into our future. Thisapplies equally to our firm as a whole and to each of us individually.All of us will confront ethical challenges; each of us must determinehow to respond. At Booz Allen, you are expected to make thosechoices consistent with our Core Values. And, as a firm, we havemany resources available to help you do so.In this chapter, we provide an overview of our EthicsFirst programand how it enables you to lead in ethics at work. We also revieweach of our obligations to report suspected misconduct andcooperate with internal and external reviews and the consequenceseach of us faces if we do not adhere to our Core Values, this Code,firm policies, or applicable laws and regulations.With a military background and a husband“on active duty, Booz Allen’s value systemmirrors my own. My parents ingrained thegolden rule in me to treat others as you wantto be treated, so I have both a high standardand clear expectations for how I behaveand what I expect of others. Most of mycolleagues are the same way. That’s powerful,working with so many people so willing to notonly do the right thing, but go the extra milealong the way. As a firm, we are quick toown up and step up.”—Angela ColeVIP Award Winner 2012 (San Diego, CA)Professionalism4THE GREEN BOOK | The Booz Allen Hamilton Code of Business Ethics and Conduct


1. Our Ethics ProgramThe Audit Committee of the Board ofDirectors and Firm Leadership Underits charter, the Audit Committeehas been delegated ultimateauthority over the firm’s ethics andcompliance program. In this role, theAudit Committee is responsible forensuring that the firm maintains thehighest ethical standards and actswith integrity at all times. The firm’sChief Executive Officer and executivemanagement are responsible forensuring that the firm has a strongethical culture, reflects its CoreValues in its operations, and hasan effective ethics and complianceprogram. To assist with this, thefirm has established an Ethics andCompliance Committee (EthicsCommittee) and appointed a ChiefEthics and Compliance Officer (EthicsOfficer) supported by the Ethics andBusiness Integrity Office (BusinessIntegrity Office).We call our ethics and complianceprogram “EthicsFirst.” The principalmessage of EthicsFirst is that tocontinue to succeed in business, wemust always make ethics our firstpriority.The Ethics and Compliance CommitteeThe Ethics Committee providesexecutive leadership and oversight forthe EthicsFirst program. As detailedin its charter, the committee setsthe EthicsFirst program strategyand priorities, issues all compliancepolicies, provides oversight of allcompliance functions, and ensuresthat appropriate incentives for ethicalconduct exist in the firm. Becauseethics is integral to our firm’sbusiness, the committee is composedof officers drawn principally from ourclient service organization.The Ethics Officer and BusinessIntegrity Office The Ethics Officer,who reports directly to the ChiefExecutive Officer and leads the firm’sEthics and Business Integrity Office,is responsible for implementingthe EthicsFirst program. The EthicsOfficer ensures that leaders and staffunderstand the firm’s expectationsregarding ethics and compliance, haveadequate tools and training to enablethem to adhere to such expectations,and can effectively and safely raiseconcerns without fear of retaliation orother negative consequences.The Ethics Advisor Program EthicsAdvisors are high performing SeniorAssociates that have been selectedby Group, Account, and Locationleaders to take on a more formal,part-time role within our EthicsFirstprogram. Our Ethics Advisors areadvocates of the EthicsFirst program;serve as frontline resources foremployees to ask questions, raiseconcerns, or report suspectedmisconduct; and advise firmleadership and the Ethics Officerso that our program continues tomeet the evolving needs of ourbusiness and employees. For moreinformation on the program and a listof the Ethics Advisors, refer to theEthicsFirst site.All It Takes Is You Although the AuditCommittee, the Ethics Committee,and the Ethics Officer have authorityover our ethics and complianceprogram, you are the “owner” ofethics at Booz Allen. The committeesand management can prescribepolicies and explain our expectations,but they cannot make us “ethical” asan organization. That must come fromyou each day, living our Core Valuesand reflecting them in your actions.Our EthicsFirst program is there tohelp you do just that.2. Ethics at WorkBooz Allen employees are expectedto reflect the firm’s Core Values andadhere to the letter and spirit of allapplicable laws and regulations andthe firm’s policies and procedures.The firm provides employees withvarious resources and tools toeffectively address ethical challenges.Leading in Ethics Booz Allen’s CoreValues are the foundation of ourbusiness, and we regard ethicalleadership as the foundation of goodleadership. Both concepts are criticalto growing our business and ensuringthat we develop the highest qualityprofessionals.As further detailed in this Code,we hold ourselves to the higheststandards and expect more ofourselves than the law might require.This is one of the many things thatseparate us from other firms.As a Booz Allen employee, you areexpected to demonstrate ethicalleadership in how you deal with yourclients; management, peers, andsubordinates; subcontractors andsuppliers; and members of the public.Simply because something is lawfuldoes not mean that it is right or wouldreflect positively on us, individuallyor as a firm. Indeed, upholding ourcommitment to ethical businessmeans that we will voluntarily refuseto do something—even though it isallowed legally—if it is not consistent with ourCore Values.Confronting Ethical Challenges Atsome point in your career, you willface an ethical challenge or dilemmaat work—some situation in which theright course of action is not entirelyclear or something you are beingasked to do just doesn’t sit rightwith you, even if you cannot explainThe Booz Allen Hamilton Code of Business Ethics and Conduct | GREEN BOOK 5Chapter I


precisely why. For example, you mightthink: “It’s only this once,” “I’m beingtoo sensitive,” “This helps only theclient—not me or the firm,” or, “All ofour competitors are doing it.”There is no instruction manual forthese situations, but there aresome questions that you should askyourself before you act:ooooooDo I know all the rules? Especiallyin a highly regulated industry suchas government contracting, rulescan be complex and overlapping.Make sure that you understandthe rules or inquire of the peoplewho do before deciding how toact. You are not expected to knowall of the answers—you are onlyexpected to raise a question whensomething does not seem right.Am I the right person to makethis decision or take this action?Each day, you have the ability totake actions potentially affectingthousands of other employees andtheir families. Your choices haveconsequences. So, before makinga decision or taking action, youmust ensure that you are indeedthe right person to do so.Even though I might mean well,how would this look to someonewho doesn’t know me, to mychildren, or in the newspaper?ooOften, the wrong thing is done forthe right reasons. Regardless ofthe pressures that you are facing,a bad decision cannot be undone.Take or make time to examine thesituation objectively; if you cannot,contact one of our resources whocan help you do so.Why am I afraid of contactingsomeone about my concerns?When ethical issues arise,especially those involving theconduct of others, reaching outcan be difficult. You might wonderwhat would happen if you werewrong or how your choice mightaffect the other person involved.Think about how you would feel ifyou were right and did nothing.Booz Allen Supports You Althoughethical dilemmas might surprise youlike a pop quiz, they are never closedbookexams. Many tools are availableto you to help you reach a decisionthat you can not only live with butalso take pride in. Remember thatwe encourage you to ask questionsand raise concerns, and our Non-Retaliation Policy protects you whenyou do so.Here are some steps that youcan take:ooooooReview applicable firm policiesand guidance, all of which areavailable in our Policy Library.Discuss the matter with yourcareer or job manager or moresenior leadership in your Group.You will be surprised how manyof them have encountered similarissues in their careers.Contact any of the followingresources:––An Ethics Advisor––The Ethics and BusinessIntegrity Office (ethics@bah.com)––The appropriate BusinessPartner or Corporate Coreresource, for example:• HR Business Partner orEmployee Relations(GO_PS_Employee_Relations@bah.com)• Computer Incident ResponseTeam (CIRT) (cirt@bah.com or703-984-1933) for observedor suspected informationsecurity incidents• Security Services (security_services@bah.com) forsecurity or safety concernsQ: What should I do if my job manager is askingour team to do something that does not violate thelaws or our policies, but I do not think it is ethicallycorrect?A: You should constructively discuss the issue withyour manager. Don’t be confrontational or assume thatyour manager knows everything that you do—or thatyou know everything that he or she does. UnderstandQ&Athat where no violation of law or policy is involved,you may need to agree to disagree and comply withduly-given instructions. If you are the manager in thissituation, consider the employee’s concerns with anopen mind and, depending on the situation, respondto the employee, take the matter under furtherconsideration, or raise the concerns to your leadership.As appropriate, explain the final decision to theemployee.6THE GREEN BOOK | The Booz Allen Hamilton Code of Business Ethics and Conduct


• Regulatory Compliance(regulatory_compliance@bah.com) for time reportingmatters––A member of the LawDepartment––Chief Ethics and ComplianceOfficer––EthicsFirst Line at 800-501-8755 (US) or international,+1-888-475-0009), or https://boozallen.alertline.comEthicsFirst Line Our EthicsFirstLine provides a central means forseeking guidance, raising concerns,and making reports about ethicsand compliance matters. You canaccess the EthicsFirst Line viaphone at 800-501-8755 (UnitedStates)/+1-888-475-0009(international), or via our secureInternet portal at https://boozallen.alertline.com. When you contact theEthicsFirst Line, you can expect to—ooBe treated respectfully and fairlyooooooHave your identity keptconfidential to the greatest extentpossible and to be given theoption of making an anonymousreport if you so choose (phonesto the EthicsFirst Line do not haveCaller ID)Have an appropriate group withinthe firm answer your question orreview and/or investigate yourconcernReceive appropriate follow-upon the resolution of the matter,understanding that because ofconfidentiality considerations,certain matters may not bedisclosed to you.The Core Values are instilled into your head on“the first day. Where they came alive to me though,was when I first went on client site. There’snot only a clear difference in how Booz Allenemployees act, it’s how we are perceived.Clients see us as the fair and honest brokersupporting the client mission. They respect us.They count on us. That was my first experienceseeing values in action.”—Janie RobinsonVIP Award Winner 2012 (McLean, VA)FAIRNESSThe Booz Allen Hamilton Code of Business Ethics and Conduct | GREEN BOOK 7Chapter I


Q&AQ: What does it mean whenwe say that there are no“negative consequences” forraising issues or reportingmisconduct?A: It means that we do nottolerate retaliation in anyform. Retaliation includesactions such as terminationof employment, denial ofpromotion, or negativeperformance assessmentsresulting from raising anissue or making a report. Italso includes other things likedenying favorable assignmentsor educational opportunities,being excluded from meetings,or giving someone the“cold shoulder.” All forms ofretaliation are prohibited byour Non-Retaliation Policy.3. Non-RetaliationAs further elaborated in the firm’sNon-Retaliation Policy, Booz Allendoes not retaliate or tolerateretaliation against any employee whoraises a question or concern; reportssuspected misconduct related to thefirm’s business or the conduct of anyof its directors, officers, employees,clients, suppliers, or subcontractors;or participates or cooperates in anyinvestigation or oversight related tothe firm’s business.Our commitment to non-retaliationis a cornerstone of our EthicsFirstprogram. It assures you that in posingany question, raising any concern,reporting misconduct, or cooperatingin any investigation, you will not sufferany negative consequences for doingso—period. Anyone who violatesthis policy is subject to disciplinaryconsequences, up to or includingtermination of employment.In raising any question or concern,reporting misconduct or cooperatingwith any investigation, you must actin good faith. This does not meanthat you need to be right, nor does itmean that your question or concernmust have substantial facts tosupport it. It requires only that theinformation that you are providingnot be fabricated or presented in anintentionally misleading manner.In addition, as further detailed inthe Non-Retaliation Policy, the firmcomplies with all statutory andregulatory requirements relatedto reporting concerns about a USGovernment contract.Key policies related to thisCode section:ooNon-Retaliation4. MandatoryReporting ofViolationsWhenever an employee observesor has good reason to suspect aviolation of law or regulation, thisCode, or any Booz Allen policy,the employee must report thematter. Booz Allen will investigateappropriately all reported matters.Mandatory Reporting of ViolationsJust as the firm protects you under itsNon-Retaliation Policy, you must actto protect the firm when you observe,or have a good reason to suspect,that someone is violating the law orregulations, our Green Book, or afirm policy. You do so by reporting thematter via any one of the followingavenues:ooooooooYour career or job manager or amore senior leaderAn Ethics AdvisorThe Ethics and Business IntegrityOffice (ethics@bah.com)The appropriate Business Partneror Corporate Core resource, forexample:––HR Business Partner or EmployeeRelations (GO_PS_Employee_Relations@bah.com)––Computer Incident ResponseTeam (CIRT) (cirt@bah.com or703-984-1933) for observed orsuspected information securityincidents––Security Services (security_services@bah.com) for security orsafety concerns––Regulatory Compliance(regulatory_compliance@bah.com)for time reporting matters8THE GREEN BOOK | The Booz Allen Hamilton Code of Business Ethics and Conduct


ooooA member of the Law DepartmentChief Ethics and ComplianceOfficerooEthicsFirst Line at 800-501-8755(US) or international, +1-888-475-0009), or https://boozallen.alertline.comYou should take care to not report aviolation to someone that you believeis involved in the matter.Managers to whom a potentialviolation is reported must report thematter to the appropriate complianceteam in the firm, or an attorney in theLaw Department.Other than reporting the suspectedviolation, you should treat the matteras confidential and not discuss it withanyone unless instructed otherwiseby the Law Department.When a matter is reported, the firmwill conduct an investigation. Exceptas specifically authorized by theLaw Department, you may neitherinvestigate independently nor resolveany alleged misconduct or violationof firm policy. If you report a matter,you will be provided appropriateinformation regarding its finalresolution, respecting confidentialityand legal constraints that may limitwhat you receive.Contacting the Audit Committee ofthe Board of Directors If you haveconcerns about the accuracy ofBooz Allen’s financial reports or itsfinancial reporting processes orinternal controls, in addition to theabove points of contact, you maydirect your concerns to the Chairmanof the Audit Committee of the Boardof Directors by writing to:Chairman of the Audit Committee ofthe Board of Directorsc/o Corporate SecretaryBooz Allen Hamilton, Inc.8283 Greensboro DriveMcLean, VA 22102Any correspondence to the AuditCommittee Chairman will be deliveredto him or her unopened. Any matterreported to the Audit Committee willbe investigated fully and addressedas appropriate.Confidential Treatment In reportingany matter, you can expect that youridentity will be kept confidential to thegreatest extent possible under thecircumstances. As further discussedin Section I.2–Ethics at Work,you have the option of reportingmisconduct anonymously via theEthicsFirst Line.Key policies related to thisCode section:ooMandatory Reporting andDisclosure5. Cooperationwith InternalInvestigationsand GovernmentOversightBooz Allen employees must betruthful and cooperate with internalinvestigations and governmentoversight related to the firm’sbusiness. They must preserve alldocuments, data, and other materialsrelated to any matter subject toinvestigation, audit, or review, but,consistent with this section, maynot disclose or provide such itemsto any government agency or otherthird party without first coordinatingwith the Law Department. Employeesmust contact the Law Departmentif the Government or a third partyinvestigator (other than a DefenseContract Audit Agency [DCAA]auditor performing a floorcheck)contacts them regarding the firm’sbusiness activities or if they receive asubpoena or search warrant relatingto Booz Allen or requesting materialsowned or possessed by the firm.Cooperating With InternalInvestigations You must cooperatefully with any internal investigationthat the firm conducts. This meansthat you must be accurate andtruthful in providing completeresponses and all relevantQ: I was just visited outside my home by aninvestigator from an inspector general’s office askingme to meet with her tomorrow morning and provideher copies of all my internal e-mails regarding mycurrent project. She left me a letter stating that Ineed to comply with her request and told me not todiscuss it with the client. What should I do?A: Booz Allen fully cooperates with all investigationsand we expect each employee to cooperate withthem as well. You are encouraged to contact the LawDepartment prior to speaking to the investigator soQ&Athat our cooperation is provided in a coordinatedmanner, and to ensure you understand your obligationsand the firm’s rights in US Government investigations.Because your e-mails are the firm’s property, you maynot provide the investigator any documents or othermaterials unless authorized by the Law Department;you should direct the investigator to contact the LawDepartment if she would like to obtain copies ofthese materials. When you learn of any investigationor inquiry related to a project, you must retain allinformation and materials (electronic, paper, orotherwise) you have that are in any way related to it.The Booz Allen Hamilton Code of Business Ethics and Conduct | GREEN BOOK 9Chapter I


information in response to inquiries,even if doing so means revealingviolations of rules by yourself orothers.If you have violated rules, admittingwrongdoing and cooperatingin resolving misconduct will beconsidered favorably in determiningan appropriate disciplinary action.On the other hand, if you are notforthright in an investigation, you willbe subject to heightened disciplinaryaction or consequences attributedsolely to your refusal to cooperate.Cooperating With GovernmentOversight Government oversight cantake many forms (e.g., audits, floorchecks, investigations). As part of theoversight process, the Governmentmay use various techniques to obtaininformation from us (e.g., subpoenas,search warrants, interviews, informalrequests for information). BoozAllen and each employee must becooperative, truthful, forthright, andas accurate as possible in respondingto such oversight.To facilitate cooperation and ensurethat the firm’s rights are respectedin the oversight process, we havedesignated expert resources suchas the Investigations Unit in the LawDepartment, Regulatory Compliance,and Security Services. You shouldcontact one of these resources if youhave questions about the oversightprocess. For example, audits are aregular facet of our business, andthe Regulatory Compliance team canassist if you are asked to participatein an audit. During a DCAA floorcheck, you may provide the auditor apaper copy of your time report, taskauthorization, and our Time ReportingPolicy if requested.Retaining Documents and MaterialsEven when you do not receivea formal records-hold notice, ifyou learn that a matter is underinvestigation, audit, or reviewinternally or by the Government ora third party, you must retain allinformation, including all relatedpaper and electronic files anddocuments. Before destroying ordeleting any such items, contacteither the group conducting theinvestigation or the Law Departmentto verify that the matter is closed,and ascertain whether you maydispose of such records.External Disclosure ObligationsWe comply with all applicable legaland regulatory disclosure andcooperation obligations that applyto our business. Reflecting our CoreValues, where we determine illegalconduct related to our business hasoccurred, we voluntarily discloseit to the appropriate authoritiesunless disclosure is prohibited byapplicable law.To the extent required by applicablelaw, we regularly file certain reportswith and make submissions to theSecurities and Exchange Commissionand the New York Stock Exchangeto disclose material events affectingour business. These reportsmust comply with all applicablerequirements and may not containmaterial misstatements or omitmaterial facts. All employees who areinvolved in preparing these reportswill ensure that such reports are full,fair, timely, accurate, understandable,and meet all legal requirements.The firm’s Disclosure Committee,in consultation with the LawDepartment, determines whether tomake such a report.In accordance with the FederalAcquisition Regulation (FAR)Mandatory Disclosure Rule, weproperly disclose and provide fullcooperation to the US Governmentwhere we determine there iscredible evidence of a violation offederal criminal law involving fraud,conflicts of interest, bribery, orgratuity violations; violations of theFalse Claims Act; or a significantoverpayment under a federalcontract. The Law Departmentcoordinates all determinations ofcredible evidence and cooperationwith the US Government. You maynot disclose on behalf of Booz Allenunder the Mandatory Disclosure Rulewithout Law Department approval.In addition, in coordination withthe Law Department, the firmcomplies with required disclosureobligations arising under the USAnti-Kickback Act, anti-boycott andhuman trafficking statutes, lawsand regulations related to facilityand personal security clearances,and tax laws, among others. It alsonotifies US Government clients whenthe firm receives competition-relatedinformation that it should not havereceived.Key policies related to thisCode section:ooFloor Checks, Audits, andInvestigations10THE GREEN BOOK | The Booz Allen Hamilton Code of Business Ethics and Conduct


6. Disciplinary ACTIONPrinciplesThis Code applies to all employees,officers, directors, agents, andothers acting on Booz Allen’sbehalf. Any employee who violatesthis Code, firm policy, or laws orregulations applicable to the firm’sbusiness operations or engages inpersonal misconduct that reflectsnegatively on the firm is subjectto disciplinary action, up to andincluding termination of employment.Any waiver of this Code for directorsor executive officers may be approvedby the Board of Directors only or itsduly authorized committee and shallbe disclosed promptly to the firm’sshareholders. Any waiver of this Codeor firm policies for other employeesmust be approved in accordance withfirm policy and documented in writing.Determining Appropriate DisciplinaryAction The firm’s Disciplinary ActionCommittee (or a firm team-delegatedauthority pursuant to the DisciplinaryAction Committee’s charter)determines disciplinary action forethics and compliance violations,as defined in firm policy, at its solediscretion based on the specificcircumstances involved in the matter.In determining the disciplinaryaction in a particular situation,the Disciplinary Action Committeeconsiders all relevant factors,including, but not limited to:ooooooooooooooooThe nature/severity of the ethicsand compliance violationThe impact on the firm (e.g., therisk or potential risk created)Harm (actual or perceived) causedto a client or its reputationThe impact to othersThe employee’s knowledgeor intentThe employee’s seniority, becausemore senior-level employees areexpected to model behavior andhave a greater understanding ofacceptable business practicesAny prior misconduct by theemployeeThe employee’s conduct andcooperation related to theinvestigationUnless they form the basis for thedisciplinary action, the followingfactors are NOT considered indetermining what disciplinary actionwill be imposed:ooooWork performanceCurrent or proposed project roleooooooAbility to develop business for thefirmPersonal relationships withmanagementClient relationshipsThe Booz Allen Hamilton Code of Business Ethics and Conduct | GREEN BOOK 11Chapter I


Chapter II: Competing for Work andServing Our ClientsAt Booz Allen, we understand that it is not just what we do but how we do it that matters. Nowhereis this more important than in how we compete for work and serve our clients. By competing fairlyand performing in strict adherence to our standards and Core Values, we remind our clients why theychose us to be their most trusted advisor.1. Competingfor WorkBooz Allen competes vigorously forwork in a manner that reflects itsCore Values, advances the firm’slong-term interests, and models howwe would want to be treated if wewere the client or a competitor. BoozAllen employees must have functionalknowledge of, and scrupulouslyadhere to, laws and regulationsthat apply when we compete inthe marketplace, including theProcurement Integrity Act andantitrust statutes. Employees andothers acting on behalf of the firmmay not use non-public informationobtained during employmentelsewhere in competing for work onbehalf of the firm unless authorizedto do so by the owner of theinformation.Representing Ourselves and OthersTruthfully and Professionally Everystatement that we make to a client orprospective client to win workshould be treated as a commitment,because, in their eyes, it is. Thismeans that when contingenciesor assumptions are essential toour ability to perform work, meet aschedule, or deliver for a particularprice, we clearly and accuratelycommunicate those contingencies orassumptions.We ensure that all documentationand other information submitted toa client in proposing work is current,complete, and accurate. For contractscovered by the Truth in NegotiationIntegrity is essential to the concept ofethics and crystallizes how the Core Valuesboth define and ground us as a firm. Clearly,we know better than most how importantit is to exemplify the firm’s value system.There can be no wavering on this point.As our own experience has shown,our constant commitment to integrity,teamwork, and excellence will bethe foundation of our resolve andguide us through even the mostchallenging circumstances.”—Tony Zertuche (San Antonio, TX)INTEGRITY12THE GREEN BOOK | The Booz Allen Hamilton Code of Business Ethics and Conduct


Q: A new employee just joined our team. Hepreviously worked for the incumbent on a projectthat will be up for recompete soon. Before we decidewhether to pursue it, we want to ensure we would beprice-competitive. Can I ask him general questionsabout their project costing methodology as long as Ido not get into “hard facts”?Q&AA: Unless the costing methodology is publicly available,you cannot. Even at a summary level, this would beproprietary information that could give us an unfairadvantage and may violate the new employee’s dutiesto his prior employer.Act, we verify that covered informationremains so at the time of finalagreement on a contract price.We win work based on, among otherthings, our qualifications and pastperformance. We neither makestatements nor engage in activitiesthat unfairly or untruthfully portrayour competitors. Statements aboutcompetitors that are intended toimprove our competitive position mustbe based on demonstrable facts.Engaging in Competitive IntelligenceGathering We do not gather anyproprietary information about ourcompetitors for competitive purposesthat is not in the public domain orotherwise available publicly. You maynot seek to obtain such informationfor such purposes either on your ownor by acting through a third party.When we team on an opportunityor engage a competitor as asubcontractor, we often receiveproprietary or other sensitiveinformation under contractualconfidentiality restrictions that limithow that information may be used.When this is the case, you must usethe information only for the purposesallowed by the contract and no others.Similarly, as a result of prioremployment elsewhere, you orother employees might possess acompany’s or client’s proprietaryinformation. You may neither disclosethat information to other employeesnor use it in conducting the firm’sbusiness unless the information hassince become available publicly. Thisrule applies regardless of whetheror not you signed a non-disclosureagreement (NDA) with your formeremployer. You also may not ask otheremployees for proprietary informationobtained from their prior employers.If you improperly receive a company’sor client’s proprietary information(even inadvertently), you must retainit with any e-mail or other meansused to transmit it, not provide it toanyone else, and immediately contactthe Law Department or EthicsFirstLine for direction.Prohibition on Paying Contingent FeesWe must avoid situations in whicha third party may be tempted to dosomething on our behalf that wewould not endorse. Consequently,we do not pay fees or commissionsto agents or other non-employees tosecure client referrals or assignmentsor enter into other arrangements inwhich we make payments contingenton the firm’s winning work.Prohibition on Lobbying for Award ofContracts Section VIII.3–Lobbyingaddresses our rules regardinglobbying activities. As furtherdescribed in that section, we donot hire or engage lobbyists andstrictly restrict lobbying activities byemployees.Q&AQ: I am on several cliente-mail distribution listsrelated to my work there. Thismorning, I got an e-mail thatwas inadvertently sent to thewrong list. The e-mail saidits attachments containedthe technical evaluations fora project (unrelated to mywork) for which Booz Allenis competing. I did not openthe attachments. Can I justdelete the e-mail and let thesender know that I received itin error but did not open theattachments?A: No. You must preservethe e-mail, not open theattachments, and contact theLaw Department orEthicsFirst Line right away.This way we can documenthow we addressed the matterto minimize risk to the firm andthe client.The Booz Allen Hamilton Code of Business Ethics and Conduct | GREEN BOOK 13Chapter II


Complying With the ProcurementIntegrity Act (PIA) The PIA is afederal statute meant to ensurefair competition for US Governmentcontracts. It does so by regulating(1) employment discussions withcertain government employees, (2)the hiring of certain officials by primecontractors, 1 and (3) the handlingof “source selection information”and “contractor bid or proposalinformation.”You must carefully reviewinformation that you receive toensure compliance with PIAinformation-related provisions.Source selection information isrelated to the US Government’sevaluation of proposals (e.g.,contractor selection plans, technicalor cost evaluations, competitiverange determinations, proposalrankings, and selection boardreports). Contractor bid or proposalinformation is non-public informationthat an offeror provides, such as costor pricing data, technical information,or other proprietary data. Informationthat falls into one of these categoriesmay or may not be marked as such.You must not solicit either of thesetypes of information. Just as withimproperly received competitorproprietary information, if you receiveit, you must retain it along withany e-mail or other means used totransmit it, not provide it to anyoneelse, and immediately contact theLaw Department for direction.The only exception to this ruleis when you are required bycontract to receive PIA-covereddata in connection with renderingprocurement advice. If you are1 Our Post-Government EmploymentPolicy protects against violations of theemployment-related provisions of thePIA. See Section VI.5–Post-GovernmentEmployment.performing such an engagement,you must safeguard the PIA-coveredinformation, use it for only yourassignment, and not disclose it toother employees.The PIA does not apply to competingfor non-US Government contracts.When competing for such work, youare expected to adhere and complywith the terms and conditions includedin any applicable request for proposalor any agreement executed by thefirm in connection with the competition.Complying With Antitrust LawsAntitrust laws prohibit Booz Allenfrom entering into agreements orother arrangements to eliminatecompetition or restrain trade.Other than teaming agreementsand subcontracts negotiated andexecuted in accordance with thefirm’s policies, such as the ContractReview and Approval Policy, you maynot enter into any formal or informalarrangement with a competitorunder which either the firm or itscompetitor agrees to not pursue abusiness opportunity. We do notenter into teaming agreements totake a potential competitor “off thestreet”; rather, we do so only tocomplement our capabilities. Underno circumstances may you enter intoany arrangement or understandingwith a competitor involving pricefixing,client term-setting, bid-rigging,bid-rotating, or market-dividing.Respecting Organizational Conflictof Interest and Non-DisclosureCommitments For certain clientengagements, we enter into anorganizational conflict of interest(OCI) mitigation plan that may includefirewalls or other protections so thatour performance of the engagementdoes not threaten the firm’s eligibilityto compete for future work. Similarly,certain clients require that eachemployee working on an engagementexecute a personal NDA that restrictstheir future business activities.(Section VI.1–Organizational Conflictsof Interest discusses OCI mitigationplans and NDAs in further detail.)When you work on a project thatincludes a mitigation plan or you signan NDA, you must review and strictlyadhere to any restrictions. This mightmean that you are restricted fromcertain project pursuit and captureactivities to preserve the firm’seligibility to participate.Key policies related to thisCode section:ooooOrganizational Conflicts of InterestProcurement Integrity ActCompliance2. AcceptingEngagementsIn accepting work, Booz Allen carefullyweighs all pertinent risks and rewardsto act in the best interests of the firmand its clients, shareholders, andemployees. Only those officers andemployees who have been officiallydelegated authority to bind Booz Allenand execute contractual documentsmay accept work for the firm. Priorto signing a proposal or contract onbehalf of the firm, all reviews andapprovals required by the firm’s RiskMatrix must be obtained. Writtendocumentation of compliance withthe Risk Matrix is mandatory.Weighing Engagement RisksWhenever you are involved in helpingthe firm obtain work, you also musthelp it evaluate associated risks.In deciding whether to acceptwork, we take into account allrelevant information—for example,personnel safety, profitability, typeof work involved, strategic impactof assignment, legal and regulatoryconstraints, contractual termsand conditions, potential financialexposure and risk, reputationalimpact of the work, potentialconflicts of interest, and other ethicalconsiderations. You must candidly14THE GREEN BOOK | The Booz Allen Hamilton Code of Business Ethics and Conduct


provide our leadership with allrelevant information so that the firmcan make an informed decision.We conduct business with onlyreputable organizations thatbehave ethically and legally. Webase decisions to perform servicesin particular countries primarilyon business rather than politicalconsiderations while taking intoaccount social and other nonbusinessfactors.We do not accept work from the USGovernment that would require us toperform an inherently governmentalfunction or that is otherwise notappropriately performed by the firm.We accept only assignments that weare qualified to undertake and thatcan be conducted under conditionsthat do not impair our objectivity,independence, and integrity.Accepting a Subcontracting RoleWorking as a subcontractor requiresthe same due diligence as workingfor the ultimate client. You mustweigh the risks and rewards,obtain the same approvals, andimpose the same quality standardsas we impose when we are theprime contractor. We serve as asubcontractor only in situations inwhich we maintain control over thecontent and presentation of ourservices, deliverables, findings, andrecommendations. We accept workonly with prime contractors that shareour commitment to business ethicsand integrity.Contractually Binding Our Firmand Risk Matrix Compliance Theauthority to accept work is limited toemployees who are designated asfinal approvers and signatories onthe firm’s Risk Matrix and SignatureMatrix. You may not sign a clientproposal or contract on the firm’sbehalf unless authorized to do so bythese documents.“When I joined the firm, I was looking for stability.I found so much more. On day one, it was clear Booz Allenrespects its people and sets the highest standards.With a Marine for my father, I realized I was ‘home’ quickly.Now, 13 years later, it’s these same standardsthat keep me here.“Saying all the Core Values mean so much sounds likean easy answer. The fact is, the Core Values are myway of life at work, at home, and beyond. My work inthe community is testament that many, many people inHuntsville see us this way too. It’s why we have such agreat reputation here. ”—Jennifer IckesVIP Award Winner 2012 (Huntsville, AL)RESPECTThe Booz Allen Hamilton Code of Business Ethics and Conduct | GREEN BOOK 15Chapter II


The Risk Matrix specifies approvalsthat must be obtained based oncontract, compliance, employeesafety, business, and other riskfactors. All approvals required by theRisk Matrix must be obtained andappropriately documented within theproposal or contract file before, asapplicable, submitting a proposal orexecuting a contract.Key policies related to thisCode section:ooooooooContract Review and ApprovalRisk MatrixSignature MatrixContingent Payment Policy3. Performing ClientEngagementsBooz Allen delivers services withhonesty and diligence, strivingto meet the highest quality workstandards. In performing work,employees must adhere to workplacerules, protect firm and client assets,maintain confidentiality of protectedinformation, and represent the firm’sCore Values. Employees must alsoaccurately document work activitiesand not perform out-of-scope workwithout proper contract modification.Meeting Our Standards of Quality Thequality of the services that we deliverto our clients is our hallmark. Westrive to provide the highest possiblequality of service to all clients underQ&Aall engagements. We deliver servicesin accordance with applicable laws,rules, regulations, and engagementterms. We conduct all required qualityassurance procedures completelyand are truthful when certifyingcompliance with specifications andtesting requirements. If you have anyquestions or concerns about workquality or the legal or contractualrequirements of an engagement,you must seek appropriate guidancewithin the firm.Delivering With Integrity andObjectivity We serve our clients withintegrity and objectivity, making everyeffort to ensure that our servicesand counsel impartially considerall relevant facts and responsibleopinions. Under no circumstancesmay you obscure, distort, or omitpertinent findings or unwelcomerecommendations. Unless required byour client contract, we do not performassessments or reviews of clientpersonnel, facilities, vendors, or othercontractors.We endeavor to complete allclient assignments expeditiously,consistent with our high professionalstandards. Providing impartialservices to our clients always takespriority over any interests in securingnew business from them. We notifyour clients if conditions develop thatwould impair our ability to perform ourservices properly, and, if appropriateand allowed, we withdraw fromassignments on which we can nolonger perform services consistentwith our standards.As furtherdiscussed in Chapter III—Time andExpense Reporting, we report all timedevoted to an engagement and allreimbursable expenses associatedwith it accurately and timely inaccordance with the firm’s TimeReporting and Travel and ExpenseReimbursement policies.Working at Client Sites Any workthat we perform at a client site mustbe performed with the same careand commitment to quality as workperformed at a firm facility and withan understanding that all conduct atthat location reflects on all of us. Ifyou work at a client site, you mustcomply with client rules regardingpersonal conduct, use of equipment,and facility security that have beenprovided to you.Use of Government-FurnishedResources When working at a USGovernment client site, you will likelyreceive resources from the clientto perform your work. This mayinclude physical assets such as acomputer or other equipment andintangible assets such as softwareand network access. In addition tolegal and firm policy requirements,you must comply with any “terms ofuse,” license agreement, or otherterms and conditions applicable tothe use of such assets. Rememberthat such terms may be includedin our engagement agreement withthe client, a written document thatyou individually sign, “click-to-agree”terms, posted client policies, orQ: My current project involves helping develop ourclient’s organizational strategy. I gave a draft reportto my client’s technical lead that recommendsa change in strategic direction that includessubstantially reducing the size of his group’s staff.This aligns with established best practices. Heresponded that I needed to redo the report to reach adifferent conclusion that preserves his team. How doI address this?A: You should advise your job manager of the technicallead’s comments so that he or she can review themand, if needed, properly engage the client or instructyou how to do so. While we always consider our clients’representatives input, our final recommendations mustreflect our impartial evaluation. Our clients hire usbecause we have the ability to constructively help themmake hard, but necessary, choices.16THE GREEN BOOK | The Booz Allen Hamilton Code of Business Ethics and Conduct


Q&AQ: I completed my finaldeliverable in less than thenumber of hours allocated underour task order. My client sentme an e-mail telling me touse the remaining time tocomplete an additional report.Can I do so?A: You may not do so until youhave received authorizationfrom your Booz Allen jobmanager. Completing theadditional report may requirea contract modification. Also,your manager needs to approveany changes to your workactivities.other materials. Unless authorizedby such terms, you must inquirebefore using government resourcesfor activities other than performingan engagement for the clientsuch as proposal development orsimilar uses; you should seek suchguidance from your job or projectmanager who can then address thecontemplated use with the client ifappropriate.You must be attuned to specialethical considerations andchallenges that might arise whenworking at a client location,especially on an extendedbasis. These considerations andchallenges include having access toinformation that might give the firman unfair competitive advantage,circumstances involving giving orreceiving gifts with client staff, andsituations in which you might betempted to lose your objectivity indelivering your work and adopt theclient’s personnel’s positions asyour own.Accepting Direction From ClientPersonnel Although, whereappropriate for an assignment, youmay take reasonable direction fromauthorized client personnel, youmust ensure that your job manageris informed about your currentwork activities. You must notifyyour job manager and obtain hisor her approval to proceed if clientpersonnel provide you direction thatadds new services or deliverables,substantially modifies currentservices or deliverables, or changesour performance schedule. Notethat client representatives andcontracting officers can neither waivenor modify any of the firm’s policies(e.g., Time Reporting or Travel andExpense Reimbursement Policy) oryour obligation to comply with thisCode.Attributing Work Engagements areundertaken and performed on thefirm’s behalf. You may not takepersonal credit for services or workproducts because the value of ourservices results from the combinedefforts of the entire firm.Key policies related to thisCode section:ooooProcurement PolicyManagement Work Authorizations4. ConductingBusinessInternationallyWhenever the firm conductsbusiness internationally (includingwith non-US persons located inthe United States), all involvedemployees must exercise specialcare to understand and adhere toboth applicable US and non-US legalrequirements. Booz Allen expectseach employee to understand wherean export can occur in a businesstransaction and plan for suchsituations in advance. Booz Allenemployees must comply strictly withanti-corruption laws that govern ouroperations in countries where weconduct business, including the USForeign Corrupt Practices Act (FCPA)and similar anti-bribery laws andconventions of other countries.Trade ComplianceUnderstanding the Rules Internationalbusiness transactions may besubject to both US and non-US lawsthat often overlap and, in someinstances, conflict (e.g., laws relatingto boycotts). In addition to obtainingall approvals required by the RiskMatrix prior to engaging in businessinternationally, you should seekguidance from the Law Departmentto ensure that you understandspecial restrictions and requirementsthat may apply to your work.Exports Under US laws, the conceptof an export is very broad andincludes situations in which an item,data, or technology is transferredto a non-US location or personphysically (even one located in theUnited States), electronically, or evenverbally or visually. Export laws alsomay apply to situations in which a USproduct, technology, or software isre-exported from one non-US countryor person to another, or where UScontent is blended with non-UScontent.An export may occur without aperson or item ever leaving theUnited States. If a non-US person,even a fellow Booz Allen employee,receives controlled technology, data,or information without a license, anexport may have occurred. Beforean export occurs, the firm mustdetermine whether a license mustbe obtained under applicable exportcontrol rules. Export control rulesare complex and fact-specific. Toascertain whether a transaction issubject to licensing requirements,you must consult with the ExportManagement Office within the LawDepartment.The Booz Allen Hamilton Code of Business Ethics and Conduct | GREEN BOOK 17Chapter II


Q&AQ: We are about to signa contract with the USGovernment to help trackdisease trends in a developingcountry. The contract willmandate that we establisha local office with its ownnetwork running a specializedtype of epidemiology softwaredeveloped by a Californiauniversity. Because theGovernment has mandatedusing this technology, do weneed an export license?A: You may need a license.The fact that the export ismandated by a contract withthe US Government does noteliminate our obligation toobtain a license. Contact theExport Management Officebefore signing the contract todetermine whether we requirea license. When a license isrequired, we must budget timeto obtain it in our contractualdelivery schedule.You are responsible for understandingwhere and to whom technologyand information are being sentbefore sending it. Each of us mustalso understand when a clientengagement, subcontract, or otherbusiness arrangement may involvesending items overseas or to a non-US person.When an export may be involved,seek guidance from the ExportManagement Office beforehandand budget sufficient time into anycommitments to enable the firm toevaluate the situation and obtainany needed licenses. You may notmake any export until all requiredlicenses are obtained, even if a USGovernment client instructs you to doso. Failing to obtain a required licensecould have severe consequences forthe firm and individuals involved.The US Foreign Corrupt Practices Act(FCPA) The FCPA and other antibriberylaws and regulations prohibitpayments of money or giving any giftsor other items of value, directly orindirectly, to any non-US Governmentofficials to obtain or retain businessor to secure any improper businessadvantage. Specifically, it prohibitsyou, directly or through a third-partyintermediary, from giving, offering, orpromising anything of value to non-USGovernment officials—defined verybroadly—or political parties, officials,or candidates for the purpose ofinfluencing them to misuse theirofficial capacity to obtain, keep,or direct business or to gain anyimproper advantage. No businesscourtesy may be provided directly orindirectly unless it is (1) permissibleunder applicable US and locallaws, and (2) compliant with all firmpolicies (which may require advanceapproval).Improper payments by thirdparties, such as teaming partners,subcontractors, vendors, andindependent consultants, acting onour behalf are prohibited. Beforewe engage a third party for aninternational engagement, we mustconduct appropriate due diligence.Key policies related to thisCode section:ooooooooAnti-CorruptionExport ControlTechnology Control PlanTrade (Import and Export)18THE GREEN BOOK | The Booz Allen Hamilton Code of Business Ethics and Conduct


Chapter III: Time and Expense ReportingEvery workday, each of us has the opportunity to tangibly demonstrate our commitment to our CoreValues. We do so by responsibly recording time devoted to work activities and incurring and reportingreimbursable expenses. To our clients, our time and expense reporting is not merely a reflectionof what they pay us for our services—it is a reflection of the trustworthiness of our firm and each ofus individually.1. Time ReportingAccurate time reporting is not simplya business requirement; it is amatter of integrity. Every Booz Allenemployee must record accurately,completely, and in a timely mannerhis or her work activities and leavein conformance with the firm’sTime Reporting Policy. Managersmust authorize work performed andapprove time reports as required bythe policy.Understanding Our Time ReportingPolicy Each of us is expected tohave a working knowledge of ourTime Reporting Policy and apply it toour daily work activities. As furtherdetailed in the policy, you mustmaintain in your work location, at alltimes, electronic access to (or a hardcopy of) (1) the policy itself, (2) alltask authorizations issued to you forwork performed during the currenttime reporting period, and (3) yourcurrent time report. Each year, eachof us must take and successfullycomplete our Time ReportingCertification exam.Recording and Submitting TimeReports Subject to very limitedexceptions specified in the TimeReporting Policy, you must personallydocument daily all time devotedto work activities and reportableabsences in the firm’s Time Online(TOL) system and submit timereports semi-monthly for approval.For each work activity entry, providethe applicable charge number,work location, whether the locationconstituted a “telework” location,amount of time devoted to theactivity, and any other informationthat TOL requires.Accuracy and CompletenessAre Paramount Overreporting,underreporting, or misstating timeor other entries on a report—eventime devoted to non-billable activitiessuch as marketing, proposal, oradministrative work—may result inmischarging labor costs to clients.Although timely report submissionis important, it is more importantthat you correctly enter all requiredinformation.If you have doubts about how tocorrectly report, seek guidance. OurTime Reporting Policy provides youwith numerous helpful resources anda means for temporarily recordingtime while guidance is beingobtained. If you identify an errorin a previous entry, you must correctit immediately.In submitting a time report, youare certifying that all entries arecomplete, accurate, and conform tothe Time Reporting Policy.Authorizing Work, Educating Staff,and Approving Time Reports Ifyou are a manager, you mustappropriately authorize work,educate staff about their timereporting responsibilities, andexercise appropriate diligenceand scrutiny in approving timereports. All work activities otherthan administrative work for yourown Responsibility Center must beauthorized in advance via a writtentask authorization containing theinformation that our Time ReportingPolicy requires. In addition toQ: I’m a senior consultant, and I spent an hourreading a technology journal article over the weekendthat gave me a great idea for how Booz Allen couldmove forward in our market by reaching out to abroader client community. While I was home, I spent3 hours putting together a deck for my manager toshare my idea. What do I put on my timesheet?A: Nothing because your time spent creating thedeck was not a “work activity” as defined in our TimeReporting Policy. While we appreciate the creativityand commitment of our staff, it is the manager’sresponsibility to make work assignments.If you are unclear whether preparing this deckwas within the scope of your assigned duties,you should discuss this with your career managerbefore you start work. Other resources that canhelp clarify what activities are work activitiesinclude the Regulatory Compliance team or theLaw Department.Q&AThe Booz Allen Hamilton Code of Business Ethics and Conduct | GREEN BOOK 19Chapter III


providing a written authorization,you must give appropriate guidanceto staff, especially when they areconfronting a new time reportingsituation. You also must maintain an“open door” to answer any questionsthat might arise or direct them to theauthoritative firm resource.TRUSTIt’s important to me to come through for my“clients and my team every day. I want to betrusted. And I want to count on the people aroundme. The Core Values are a framework that bringsout the best in all of us. I see the Core Valuesalive throughout the firm. It’s very evident in clientmeetings where Booz Allen people acknowledgeeach other and help each other out, whether we’reon that task or not. It’s the common connectionand trust we have that drive us to do uncommonthings for each other and our client.”—Leo MartinezVIP Award Winner 2012 (San Diego, CA)In reviewing time reports, youmust act reasonably under thecircumstances to verify that theinformation on the time report iscomplete and accurate. This effortincludes being cognizant of situationsaffecting an employee that couldtempt him or her to misreport time(underreporting or overreporting)and looking out for red flags. If youhave any open questions or doubtsat the time report approval deadline,you must reject the time report. Ifyou believe that an employee mightbe mischarging time or otherwiseviolating our Time Reporting Policy,you must report the matter inaccordance with the policy. Youare not authorized to investigate orresolve the issue on your own.By approving a time report, you arecertifying to the firm that to the bestof your knowledge and belief, basedon reasonable inquiry under thecircumstances, entries are accurateand in compliance with our TimeReporting Policy.20THE GREEN BOOK | The Booz Allen Hamilton Code of Business Ethics and Conduct


Consequences for Policy Violations Ifyou suspect that another employeeis violating our Time Reporting Policy,you must report your concern asdescribed in Section I.4–MandatoryReporting of Violations. Anyone whoviolates our Time Reporting Policy orinstructs others to do so is subjectto disciplinary action, up to andincluding termination of employment,and may be subject to further criminalor civil legal action. Where timemischarging is identified, the firmalso corrects affected client invoicesand makes all disclosures as requiredby applicable laws, regulations, andcontract terms.Key policies related to thisCode section:ooooTime ReportingDual Time Sheet Reporting2. ExpenseReimbursement andReportingBooz Allen maintains acomprehensive suite of policiesthat specify how employees mustpurchase goods and services(including travel) for businesspurposes, which business expensesincurred by employees arereimbursable by the firm, and howsuch expenses are approved forreimbursement. Each employee muststrictly adhere to all firm policiesregarding incurring and reimbursingexpenses. In no case may anemployee use or manipulate theexpense reimbursement system forpersonal benefit or gain.Reimbursable Expenses Subjectto restrictions and limitations inthe firm’s expense reimbursementpolicies, you may be reimbursed foractual, reasonable, and necessaryexpenses incurred for businesspurposes if the expenses havebeen approved in advance by therequired level of management.Even where authorized, in incurringan expense, you should exerciseprofessional judgment and be mindfulof how the type and amount of theexpense may appear to a client,an auditor, a manager, a peer, or asubordinate. Where we have enteredinto a preferred vendor or sourcingarrangement, you must use it unlessproperly authorized to do otherwise.Submitting and Approving ExpenseReports Submit expense reportspromptly after incurring expenses andalways within the time specified infirm policies. This allows expenses tobe allocated and billed properly. Eachexpense report must be accurate,contain all required content, and besubmitted with all required receiptsand documentation. Where originalreceipts and other documentation arenot required to be submitted with areport, you must retain them for theperiod specified in the firm’s Recordsand Information Management (RIM)Policy.Exercise care in distinguishingbetween allowable and unallowableexpenses for federal contractingpurposes (which is different fromwhether an expense is reimbursableunder firm policy). Also, ensurethat you properly specify whichexpenses can be billed to a clientwhen the client contract has specialreimbursement rules.Your designated manager mustapprove your expense reports. Ifyou are a manager designated toapprove expense reports, you mustverify the business purpose for theclaimed expenses, cost allocations,supporting documentation, andcompliance with firm policies.The Booz Allen Hamilton Code of Business Ethics and Conduct | GREEN BOOK 21Chapter III


using firm-sponsored Credit andPurchasing Cards firm-sponsoredcredit and purchasing cards may beused only for reimbursable businessexpenses; you may not use thesecards for personal purposes. Chargeson such cards must be paid in atimely manner. if you have beenissued a firm credit or purchasingcard, you should use it wheneverpossible for reimbursable expenses.Personally benefiting from firmPurchases except as specifi callyauthorized by this Code or firmpolicy, you may not personally benefi tfrom firm purchases or expensesreimbursed by the firm. Any rebates,refunds, or discounts applied by asupplier or service provider must besurrendered to the firm. Providedthat you have complied with thefirm’s purchasing and expensereimbursement policies and unlessotherwise required by a clientcontract, you may retain for personaluse frequent flier miles or similarpoint-based rewards provided byvendors to all customers participatingin the reward program. note thatyou cannot participate in rewardsprograms (e.g., “planner points”)for events reimbursed under usGovernment contracts.Key policies related to thisCode section:oooooTime Reportingdual Time sheet Reportingexpense ReimbursementRecords and informationmanagementGifts and Business Courtesiesour Core values are not simply statements of principle or aspirationsof what we endeavor to achieve—they are bonds that connect us ineverything we do.—Pictured: Demola sholagbade (viP award winner 2011) and tom boone (viP award winner 2009)22THe green BOOK | The Booz Allen hAmilTon Code of Business eThiCs And ConduCT


Chapter IV: Creating the Absolute BestPlace to WorkBooz Allen’s success is predicated on our ability to deliver the highest-quality people with a range ofviewpoints to help solve our clients’ most pressing problems. To do that, each of us must be dedicatedto maintaining and reinforcing an open and supportive work environment that fosters professionaldevelopment and achievement.1. EncouragingDiversity andTeamworkTo be an employer of choice,Booz Allen must attract, develop,and retain talent from diversebackgrounds and ensure thatemployees and candidates foremployment are afforded equalopportunity in all employmentactions. By creating a culturecommitted to our Core Values, weleverage the unique make-up ofour professionals to solve complexissues. Every Booz Allen employeemust foster an inclusive workplace inwhich all individuals can contributetheir best work.Our Commitment to Equal Opportunityand Non-Discrimination We arededicated to the principles ofequal employment opportunity andproviding a workplace free fromdiscrimination based on race, color,religion, sex, national origin, age,marital status, sexual orientation,gender identity and expression,disability, veteran status, geneticinformation, or any other statusthat is protected by applicablefederal, state, or local law. Youare responsible for upholding thiscommitment and making equalemployment opportunity yourstandard for professional conduct. Allof our employment actions and oursocial and recreational programs areimplemented without regard to anyprotected status.In addition, we adhere to ouraffirmative action programs andcommitments. As a governmentcontractor, we are responsiblefor developing and implementingaffirmative action plans thatinclude specific action-orientedprograms and goals designed toadvance the principles of equalemployment opportunity in therecruitment, selection, advancement,and compensation of qualifiedwomen, minorities, individuals withdisabilities, and veterans. The ChiefPersonnel Officer, who reports onthese efforts periodically to the Boardof Directors and senior leadership,monitors firmwide results ofaffirmative action efforts.Preventing Workplace HarassmentEach one of us is responsible formaintaining a workplace free ofharassment. We will not tolerateany behavior that disrupts orinterferes with an individual’s workperformance or that creates anintimidating, offensive, or hostile workenvironment.This commitment applies regardlessof whether an employee, clientpersonnel, a subcontractor, or anyother third party engages in theharassing conduct.Reporting Concerns As detailedin this Code, our Non-RetaliationPolicy protects individuals whoreport discriminatory or harassingbehavior. You should direct reportsof discrimination and/or harassmentto Human Resources, EmployeeRelations, the Law Department,the EthicsFirst Line, or any of theother listed contacts in Section I.4–Mandatory Reporting of Violations.Key policies related to thisCode section:ooooEqual Employment OpportunityWorkplace and SexualHarassmentQ&AQ: What should I do if Ibelieve that a client is makingsexual remarks to a memberof our project team?A: We do not tolerateharassment of our employeesat any work location byanyone. When an allegationrelates to a non-employee’sconduct, we will work with theclient or other organization toensure that it is appropriatelyinvestigated and addressed.Any harassing behavior shouldbe reported immediately toHuman Resources, EmployeeRelations, the Law Department,the Ethics and BusinessIntegrity Office, the EthicsFirstLine, or any other listedcontact in Section 1.4 –Mandatory Reporting ofViolations.The Booz Allen Hamilton Code of Business Ethics and Conduct | GREEN BOOK 23Chapter IV


2. ManagerResponsibilitiesManagers must be role modelswho lead their teams in a mannerexemplifying our Core Values.Managers must be knowledgeable of,adhere to, and appropriately instructtheir staff on firm policies. Thisrequirement applies equally to day-todaymanagement matters and moreuncommon situations.Employees Raising Issues Asa manager, you have a specialresponsibility if an employee—regardless of whether he or shereports to you—poses an ethicalquestion or concern. It is incumbenton you to honor that trust and ensurethat the employee is put into contactwith the appropriate firm resourcesto address the matter whilesimultaneously remaining neutral indoing so. Under no circumstancesshould you conduct your owninvestigation, or dissuade or inhibitan employee from making a report oraccessing higher management or firmresources to seek guidance.As a manager, you cannot have aconfidential or “just between us”conversation with an employee whoreports a potential violation of lawor firm policy. You must immediatelycontact your Human ResourcesBusiness Partner or manager, amember of the Employee Relationsteam, or an attorney in the LawDepartment, even if only to relatethat an employee reported a matterto you.Ensuring Non-Retaliation Our Non-Retaliation Policy protects anyemployee who raises a questionor concern or reports suspectedmisconduct, or who participates in aninvestigation. This protection extendsto not only formal actions by the firmbut also informal conduct by you orfellow employees, or third partieswho work with the employee. As aQ&AQ: One of my directreports who was recentlyinvolved in an investigation isundermining my authority andthe team’s morale. Every timeI give a direction, he questionsit in front of the group and hasside conversations criticizingme. I understand that werespect employees who raiseconcerns, but is there anythingthat I can do here?A: You should first try to workwith the employee to helphim understand how to bestraise his concerns. While heis allowed to raise issues andreport concerns, he needs tobe respectful in doing so anduse established channels. Ifhe persists in being disruptive,you should raise the issue toyour management and HumanResources to help you address it.“Through strategic communications, it’s my job tohelp government clients tell their stories. To me, theCore Values are integral to telling, and living, our storyas a firm and as individuals.Inherently, people who are attracted to and successfulat Booz Allen already have this value system. It ‘fits’ tobe around great colleagues who reflect the same highstandards, to have leaders who model these values, andto have clients who respect us because of them.The Core Values are our brand. It’s that consistency inour brand that makes it really powerful. The way we carryourselves, our professionalism, client service,and excellence set us apart from the competition.This is consistent around the world. We’re this forceout there of amazing people who choose to do theright thing and be their best every day. ”—Lisa HunterVIP Award Winner 2012 (San Diego, CA)Client service24THE GREEN BOOK | The Booz Allen Hamilton Code of Business Ethics and Conduct


manager, you must ensure that whenan employee raises an issue about afellow employee, a client, or even you,he or she is not subject to retaliationbut rather is treated fairly and ina manner that would encourageanother employee to report undersimilar circumstances.Personal Relationships BetweenManagers and Staff As a manager,you need to exercise care toensure that your businessdecisions regarding your team arenot influenced by any personalrelationship that you have with them.In furtherance of this principle, allemployees must abide by the firm’sWorkplace Relationships Policy, whichaddresses familial and romanticrelationships between employees.Key policies related to thisCode section:ooooWorkplace Relationships PolicyNon-Retaliation Policy3. WorkplaceSecurity and Safetyand ReportingCertain CriminalCharges andConvictionsBooz Allen employees must complywith all firm policies related toprotecting our work locations;this includes an obligation toreport certain criminal chargesand convictions to the firm. Whenworking at a client or non-firm facility,employees must be familiar with andadhere to all security rules that havebeen provided to them.Complying With Facility SecurityRules Each of us must complywith all firm security protocols andprocedures (e.g., wearing firm-issuedidentification badges, controllingaccess to firm facilities and networks,registering visitors, and complyingwith instructions from securitypersonnel). To ensure the securityof our facilities, any personalproperty brought onto premises ora property controlled by the firmmay be searched.Carrying Weapons You may not carryany weapon, including ammunition,explosives or similar materials, onfirm property, client sites, or otherwork locations except where explicitlyrequired by a contract and permittedby applicable law.Workplace Violence and Threats Youmay not make threats or engagein threatening behavior or any actof violence against employees,contractors or subcontractors,clients, visitors, and/or their property.Acts of violence include battery;threatening or disruptive behavioror acts of intimidation, stalking,verbal or physical harassment; orharassing e-mails, telephone calls,and/or threatening messages of anykind, including text messages. Youshould direct all reports of any actsof violence immediately to SecurityServices or the Crisis ResponseHotline at (800) 291-9955.Reporting Criminal Convictions If youare charged with certain crimes asset forth in firm policy or convictedof a crime (other than a minor trafficviolation), you must report it to yourcareer manager or Human Resources.Such reports must be in writing andmust be made within 5 days of thecharge or conviction. This reportingdoes not relieve you of your obligationto personally report an arrest orconviction to agencies granting youa security clearance pursuant toapplicable regulation.Key policies related to thisCode section:ooooMandatory Reporting andDisclosurePhysical Access Security PolicyQ&AQ: What do I do if someone that I do not know and who is not displaying a visible Booz Allen ID tries to get intoour offices by following closely behind me after I swipe my access badge?A: In this situation, you should never do anything that makes you feel unsafe. If you are comfortable doing so, youshould ask the person to show you his or her ID. If an ID cannot be produced, please escort the individual to thereception desk for further action. If you are not comfortable confronting the person, you should proceed to youroffice and immediately contact Security Services.The Booz Allen Hamilton Code of Business Ethics and Conduct | GREEN BOOK 25Chapter IV


4. Drugs and Alcoholin the workplaceIn all its facilities and any otherlocation where Booz Allen’s workis performed, the firm strictlyprohibits the unlawful manufacture,distribution, dispensing, possession,or use of illegal drugs by anyemployee, as well as the use ofor dispensing of legal drugs oralcohol to the extent an employee’sperformance and/or conduct isaffected.Substance Abuse Screening Becausethe firm engages in client work thatrequires a US Government securityclearance for individuals assignedto such work or who may performsensitive work (and applicants forthese positions), we may require preemployment,random, or reasonablesuspicion drug testing if you hold asecurity clearance, are assigned toa program contractually requiringtesting for the use of illegal drugs,or are otherwise in a positiondeemed by the firm’s managementto have significant safety or securityresponsibilities or a special positionof trust. These positions generallyinvolve contract management oroperations for clients that requiretesting; employees who have accessto or handle classified informationor nuclear materials; or jobs thatpose a danger or high risk to life, theenvironment, public health/safety,national security, and the like.You must notify the firm in writing ofany criminal drug statute charge orconviction within 5 days after suchcharge or conviction.If you are experiencing problems withdrugs or alcohol, you may contact thefirm’s Employee Assistance Program(EAP) at 888-267-2183 (United States)/Country Code (IDD)-1-651-994-2910(International).The EAP provides confidentialassistance and can help you obtaincounseling for your problem.Key policies related to thisCode section:ooooDrug- and Alcohol-Free WorkplaceMeeting and Event26THE GREEN BOOK | The Booz Allen Hamilton Code of Business Ethics and Conduct


Chapter V: Confidentiality and Protectionof InformationGiven the nature of our business, information is our stock-in-trade. We earn the trust of our clients,employees, subcontractors, suppliers, and other business partners by scrupulously protecting theconfidential information they provide to us and safeguarding the information technology (IT) resourceswe use to receive, store, and transmit it. This is especially important when the US Government and ourcommercial clients entrust us with their most sensitive data and information.As reflected in this chapter, each of us has an obligation to use data we receive only as permitted,take all steps needed to protect it from unauthorized disclosure both inside and outside the firm, andproperly document and retain records related to the firm’s business. Each of us must also comply withthe non-disclosure and intellectual property ownership agreements executed with the firm.Q&AQ: We just started anengagement to evaluate thecost-effectiveness of differentmedical procedures. We needto know certain demographicinformation about the peoplereceiving the procedures andtheir post-treatment outcomesand complications. The clienthas offered to provide us copiesof the medical files of the peoplereceiving the procedures togather the information ourselves.Can we accept the offer?A: No. In this situation, you shouldrequire the client to provide youde-identified information regardingthe recipients of the procedures.Unless contractually requiredfor our work, we do not acceptpersonally identifiable informationfrom our clients.1. Confidentialityof Client and Third-Party InformationSafeguarding client information isfundamental to our Core Values.Every Booz Allen employee mustexercise care and comply withcontract and legal requirements tosafeguard sensitive, proprietary,or non-public information obtainedfrom our clients and third parties.Special care must be taken wherean employee signs a personal NDAor receives personally identifiableinformation (PII).Presuming Confidentiality of Clientand Third-Party Information Youshould presume that any informationthat you receive from a clientis confidential unless the clientspecifies that it is not or you arecertain that it is publicly available(e.g., the client has posted theinformation on its website). Thispresumption applies to information inany form (e.g., hard copy, electronic,or verbal information acquiredduring meetings or through otherconversations).Protecting Client and Third-PartyConfidential Information The bestway to protect client information isnot to take possession of it. Eachof us must restrict receipt of clientinformation to only information thatis reasonably necessary to proposeor conduct an engagement even ifgreater information access is offered.After confidential information isreceived, we must take all reasonableprecautions to safeguard and protectit from unauthorized or inadvertentdisclosure. The exact precautionswill depend on the nature of theinformation, how it is stored, thepurposes for which it will be used,Q: I’m putting the final touches on a client deliverableand found additional statistical information I receivedfrom another client that I would like to include. I’d alsolike to include a copy of an article I obtained from anonline journal publication. Is this allowed?A: Regarding the statistical information, you must firstverify that we have the right to use the data outside ofthe engagement for which you received it. We presumeall client data is confidential unless it can beshown to be otherwise.Q&AWith respect to the article, you must always be sure youhave permission to use it in a client deliverable or if youjust want to make copies for others. It’s quite likely thearticle contains re-publication or distribution restrictions,and you will need permission to include copies in a clientdeliverable.The Booz Allen Hamilton Code of Business Ethics and Conduct | GREEN BOOK 27Chapter V


DIVERSITY“Some people consider the Core Valuesa foundation. Some see them as aspirations.To me though, they’re not something we worktowards but part of who we are. I put thatexpectation on everyone. You start from aplace of excellence. Of diversity. Of trust. Ofentrepreneurship. Of professionalism. ”—Michael DumlaoBEA Winner 2012, Diversity & Inclusion(Washington, DC)and any applicable contractual orlegal requirements. You must befamiliar with these factors beforestarting an assignment. As a generalmatter, avoid discussing confidentialinformation in public areas.Your obligation to maintain theconfidentiality and security of clientinformation continues not onlyduring and after the engagementends but also during and after youremployment with the firm.Using Client Information Protectinginformation from improper internalsharing is as important as preventingimproper external disclosure of it.You must only use client informationas permitted by our engagementcontract and/or applicable terms ofuse or NDAs that you have signed forthe engagement. You may disclosesuch information within the firmonly to those who have a “need toknow” and only then if contractuallypermitted.A critical asset that we bringto our clients is our ability tocomprehensively understand theirproblems and needs, even thoseoutside the scope of a currentengagement, and to identify firmresources that can help addressthem. If, based on client information,you learn of needs that otheremployees in the firm might be ableto help address, you should mentionthose resources to the client andobtain the client’s consent to providethem with relevant information.Returning, Destroying, or RetainingInformation After an EngagementEnds At the conclusion of anengagement, comply with allcontractual requirements for thereturn, destruction, and/or retentionof confidential information. Wheresuch requirements do not apply,the firm’s Records and InformationManagement Policy determineswhether and how to maintain theinformation.28THE GREEN BOOK | The Booz Allen Hamilton Code of Business Ethics and Conduct


Executing Client NDAs For certainengagements, a client or third partymay request or require that youexecute an individual NDA. Unlessyou have been informed by yourmanagement that an NDA will berequired, you should not sign aclient or third-party NDA until youhave received direction from yourmanagement and/or cognizantcontract administrator.When an NDA is required, you mustreview it carefully and abide by itsprovisions, including those that limitsharing information within the firm.You may be personally liable forfailing to adhere to the terms ofan NDA.Accessing and Handling PII PII isinformation that can be used touniquely identify, contact, or locatea single person, or that can be usedwith other sources to uniquely identifya single individual. This informationmay include names, addresses,Social Security numbers, credit cardnumbers, banking and financial data,health information, or other similardata.Before accepting PII, be sure thatwe have a contractual obligationto do so. Often, our work can beaccomplished with de-identified oraggregated information. When this isthe case, we require the party to giveus the data in that format.All engagements involving accessing,handling, or storing PII must beapproved in advance by the ChiefInformation and Security Officer(or designee) and must obtain allother approvals required by theRisk Matrix. When access to PIIis required, handle it according toapplicable contract provisions andprivacy laws. PII must only be sharedwith engagement team memberswho have a “need to know” theinformation and have completedall prerequisites (e.g., executingan NDA or completing training) forreceiving it. Under no circumstancesmay you use PII for any purposeexcept contract performance. Unlessrequired otherwise by our contract,you must return or destroy the PII(if applicable, in accordance withcontract requirements) when it is nolonger needed for the assignment.If you suspect that the securityof such information has beencompromised, you must notify theComputer Incident Response Team(CIRT) at cirt@bah.com or the LawDepartment immediately beforetaking any further action.Access and Handling Protected HealthInformation (PHI). For certain clientengagements, you may be requiredto access, use, or disclose PHI. PHIincludes all individually identifiablehealth information accessed, used,or disclosed by an entity required tocomply with the Health InsurancePortability and Accountability Act(HIPAA). PHI may be in any form ormedium, whether electronic, paper,or oral, and includes informationthat relates to an individual’s past,present, or future physical or mentalhealth or condition; the provision ofhealth care to the individual; or thepast, present, or future payment forthe provision of health care to theindividual. Employees accessing PHImust comply with all Code, policy,and contract requirements applicableto both PII and PHI.All engagements involving PHI mustbe approved in advance by the firm’sChief Information and Security Officerand all approvers identified in theRisk Matrix. If a client provides youPHI and you are not certain whetherthe engagement has been approvedfor PHI handling, you must safeguardthe PHI, contact your job manager,and not take further action untildirection is provided. Access to PHImay be granted to a subcontractoronly under an executed subcontractagreement that includes all relevantPHI requirements and an appropriatebusiness associate agreement ifrequired.Booz Allen and each employeeaccessing PHI are expected tocomply with the “minimum necessarystandard” regarding the information.This means that we first ensure thatthe work cannot be done with non-PHI data (e.g., de-identified data). Ifwe determine that we must accessPHI to perform the work, we willonly access and use the PHI that isminimally necessary to perform theclient engagement and only shareit with authorized members of theproject team who (1) have a need toknow the information to perform theirwork and (2) have complied with anycontract requirements for accessingthe PHI such as training.In accessing and handling PHI,you must comply with applicableregulations and terms in our clientcontract, including any associatedbusiness associate agreement aswell as any NDA, “Terms of Use,”or “Rules of Behavior” documentyou have signed or other handlinginstructions that you have beenprovided. In particular, you mustcomply with any data encryptionrequirements and limitations onmodifying PHI.You are prohibited from using anyPHI for any purpose other thanperforming your client engagement.Neither Booz Allen nor you may, underany circumstances, sell PHI receivedfrom a client or use PHI for marketingpurposes (other than client marketingspecified in the client contract) or anyother unauthorized purpose.You must immediately report anyactual or suspected unauthorizeddisclosure of PHI (including disclosuresby clients or other contractors) tothe CIRT at cirt@bah.com. Observed,suspected, or reported misconductrelated to PHI must be reported toone of the resources identified inThe Booz Allen Hamilton Code of Business Ethics and Conduct | GREEN BOOK 29Chapter V


Section I.4 – “Mandatory Reportingof Violations.”Key policies related to thisCode section:ooooooConfidentiality and Security ofClient InformationRecords and InformationManagementContract Review and Approval2. SecurityClearancesand ProtectingClassifiedInformationBooz Allen adheres to all legal andcontractual obligations related tothe facility security clearancesthat it possesses. Each employeewho holds a personal securityclearance must comply with alllaws, regulations, and commitmentsassociated with his or her clearance.Each employee receiving classifiedinformation must exercise the utmostcare and discretion in how suchinformation is used and stored, andmust relinquish such information assoon as it is no longer needed for thebusiness purpose for which it wasprovided.Handling Classified Information If yourwork involves classified information,you must follow all contractualclassification specifications,protection requirements, andsecurity processes. Protection ofthis information applies not only toclassified documents but also toclassified computer systems that thefirm maintains at our cleared facilitiesor to which you have access at aclient site. Classified information maybe provided only to properly clearedemployees as necessary to submit aproposal or to fulfill obligations undera classified contract or subcontract.Booz Allen Standard Practices &Procedures (SPP) Manual The SPPManual sets forth security programpolicies, responsibilities, procedures,and guidelines that allow us tocomply with the requirements of theNational Industrial Security ProgramOperating Manual (NISPOM) for thesafeguarding, release, and disposalof classified information. Our SecurityServices Team maintains the SSPand can advise you regardingwhether a facility is authorized toreceive, generate, or store classifiedinformation and, if so, at what level.Conduct Affecting Security Clearancesand Reporting Adverse ActionsMatters in your personal life mayaffect your ability to obtain or retaina security clearance. This includesconduct that reflects unfavorably onyour integrity or character, impairsyour ability to safeguard classifiedinformation, or indicates that accessto classified information may not bein the interests of national security.We comply, and expect you tocomply, with all legal and contractualrequirements to report any adverseinformation related to a current orpending security clearance. This mayinclude, but is not limited to, arrestor indictment, treatment for mentalor emotional disorders, excessiveindebtedness or recurring financialdifficulties, legal or credit actions, orinvolvement with illegal substances. Ifyou have any doubt about what mustbe reported, check with our SecurityServices team.Key policies related to thisCode section:ooCorporate Standard Practicesand Procedures3. Firm Informationand Ownership ofWork ProductBooz Allen employees may notdisclose any non-public firminformation (including personal dataregarding employees) to any thirdparty except as authorized by thefirm. An employee may internallyshare such information only withemployees who need to know suchinformation. As further detailed inthe intellectual property ownershipagreement that each employee signs,the firm owns all work products thatan employee creates during the termof his or her employment.Identifying and Labeling FirmInformation Much like you shouldpresume that any informationreceived from a client is confidential,you should also presume that anyinformation you receive from thefirm is proprietary and confidential.Accordingly, you must safeguard theQ: I have a top secret clearance for my work at thePentagon. About a month ago, I started casuallydating a woman from Germany who is a permanentresident who has lived here for 10 years. It has nowprogressed to where we see each other about twicea week. Do I need to report that I am dating her? Willthat affect my clearance?Q&AA: Yes, you need to report this to SecurityServices. Any close and continuing contact with aforeign national must be reported to comply with termsof your clearance. Any report may be investigated byDefense Security Services but, absent unusual factors,this dating relationship will not affect your clearance.30THE GREEN BOOK | The Booz Allen Hamilton Code of Business Ethics and Conduct


firm’s information and prevent it frombeing disclosed or made availablepublicly.When you create documents andother materials for the firm, labelthem appropriately to reflect theirproprietary and/or confidentialnature in accordance with firmpolicy. Whenever you receive firminformation containing a proprietarymarking, you must maintain themarking on all copies you makeand apply the same marking to anynew documents incorporating theinformation (e.g., summarizing theinformation in another document orcutting and pasting excerpts into anew document).Disclosing Firm Information The firmusually requires that any disclosureof its proprietary information bemade pursuant to an NDA. Beforedisclosing information to a third partyunder an NDA, you must verify that itis marked appropriately as requiredby the NDA.Our Responsibilities as Employeesof a Publicly Held Company As apublicly held company, in accordancewith applicable law, the firm has anobligation to provide all current andprospective investors equal access tomaterial information concerning ourbusiness and financial performance.Selective disclosure of material nonpublicinformation is prohibited. OurLaw Department is responsible forensuring that we satisfy our legal duties.Discussing non-public firm informationwith clients, subcontractors, orothers, even in a social settingor anonymously via social media,can affect our compliance withthese duties and potentially triggerdisclosure obligations. Each ofus must carefully consider eachstatement that we make regardingour business and ensure that we onlydiscuss and characterize activitiesin accordance with what the firm haspublicly disclosed.To help minimize the risk of aninadvertent disclosure, if you havenon-public information concerning thefirm, you must limit internal sharingof, or access to it, to those who havea need to know it to perform theirbusiness role.Employee Personal Data Each of usmust exercise extra caution whenhandling an employee’s personaldata. We do not disclose current orformer employees’ personal data tothird parties other than confirmationof employment dates and positionwithout prior written consent fromthe employee or former employeeunless the information is required tofulfill a legitimate business need—such as employee benefits—or asrequired by law.No employee or representative ofthe firm may provide a reference orrelease information regarding theperformance of a current or formeremployee without a signed writtenrelease from the employee on a formapproved by the Law Department.If you believe that an unauthorizedperson has gained access toemployee personal data, disclosed itinappropriately, or used it in violationof our policies or the law or for nonbusinesspurposes, promptly notifythe Law Department.Continuing Obligations Your nondisclosureobligations regardingfirm information apply both duringand after employment with the firm.Upon termination of employment, youmust return all papers, firm records,documents, deliverables, and otherinformation. You may not keep copiesof any of the firm’s information.Key policies related to thisCode section:ooooooProtection of ProprietaryInformationInformation SecurityRecords and InformationManagement4. Insider TradingThe term “insider trading” isnot defined in any of the federalsecurities laws, but generally refersto trading in securities on the basisof material non-public information asfurther described below. The term“tipping” means sharing material nonpublicinformation with a third party,whether or not it is for compensation.Understanding What Is “MaterialNon-Public Information” Whetherinformation is material is difficult toevaluate in the abstract and typicallyis assessed with the benefit ofhindsight. There always is informationabout the firm or its affiliates thatis not generally known to the public.This information is “material” if itwould be likely to affect the stockprice of the firm or its affiliates, or ifit would be important to a reasonableinvestor in making a decision aboutwhether to buy, hold, or sell securitiesof the firm or its affiliates.Either positive or negative informationmay be material. Note also thatmaterial information does not have torelate to the firm’s business.Q&AQ: When I started with BoozAllen, I signed an agreementconcerning intellectual propertyand the protection of firminformation. Does this still applywhen I leave the firm to pursueother career opportunities?A: Yes. You must adhere to therestrictions on disclosing firminformation, even after youremployment with Booz Allenterminates for any reason.Unless such information ispublicly available, you cannotfreely discuss client or firmbusiness when you move on inyour career.The Booz Allen Hamilton Code of Business Ethics and Conduct | GREEN BOOK 31Chapter V


Unlawfully Using Material Non-PublicInformation You may not, directly orindirectly, purchase or sell securitiesof the firm or its affiliates while inpossession of material non-publicinformation concerning the firm or itsaffiliates. Similarly, you may not tradein the securities of another companyif you obtained material non-publicinformation about that company inthe course of your employment withthe firm.In addition, you may not give materialnon-public information to anotherperson. You and any person to whomyou provide any material non-publicinformation would potentially besubject to fines and imprisonment.Insider trading and tipping arecivil and criminal violations of law.Transactions that may be necessaryor justifiable for independent reasons(such as the need to raise moneyfor an emergency situation) are noexceptions to the prohibition oninsider trading.Protecting Non-Public InformationEnsuring the confidentiality of nonpublicinformation is the single mostimportant step to minimizing the riskof illegal insider trading and tipping.As detailed further in this chapter,you must ensure the confidentialityof information to which you haveaccess. This means that unless theinformation is otherwise publiclyavailable, you must limit accessto that information to Booz Allenemployees who have a reasonableneed to know the information forthe purpose of carrying out theassignment for which the informationis furnished.Special confidentiality agreementsmay be required for others (includingoutside business associates,governmental agencies, and tradeassociations) seeking access tomaterial non-public information. Donot discuss business matters inpublic places, such as elevators,hallways, lobbies, restrooms, andpublic transportation facilities.Key policies related to thisCode section:ooInsider Trading5. TechnologyResource Usage,Access, and SecurityProper use of Booz Allen and clientIT assets helps protect both firmand client networks and data. AllIT asset use must adhere to firmpolicies and standards, including thefirm’s IT Acceptable Use Policy. Whileemployees may engage in limitedpersonal use of firm IT assets, theyhave no expectation of privacy insuch use. When using personal ITassets for firm business, employeesmust do so securely and in a mannerthat does not jeopardize firm or clientinformation.Defining IT Assets IT assets includeall information processing andtelephony hardware, software, andrelated services. Examples includecomputers, servers, personal digitalassistants/smartphones, telephones,facsimile machines, e-mail andnetwork accounts, network access,and software applications.Using IT Assets The firm (and oftenour clients) provide IT assets to youto advance business purposes andfacilitate work. How you use IT assetsentrusted to you reflects upon yourcharacter and the firm’s reputation.In using such IT assets, you mustalways be cognizant of protectingthem and data stored or accessiblefrom them from security threatsand unauthorized access. You maynever allow any third party, includingfamily members, to use any IT assetprovided to you by the firm or a client.You also may not circumvent orsubvert security measures such asencryption software or virus scanninginstalled by the firm to protect itsIT assets.Limited Personal Use You areresponsible for all uses that youmake of IT assets provided to you.The line between acceptable limitedpersonal use and unacceptableexcessive personal use cannot beprecisely defined in all circumstancesand will vary from employee toemployee. For example, acceptablepersonal use for an employee onfrequent travel may be different fromthat of a person who works from alocal Booz Allen office all of the time.Personal use must not degrade theperformance of resources, resultin any significant added costs tothe firm, negatively affect the firmor client business operations orreputation, or otherwise disadvantagethe firm or its clients. Especially notethat you may not record any personaluse time as a work activity for timereporting purposes when makingpersonal use of IT assets.Using Client-Issued IT Assets If aclient entrusts you with an IT asset,you may only use it in accordancewith any terms of use, licenseagreement, or other terms andconditions applicable to the use ofsuch assets, and in a manner thatwould reflect positively on Booz Allen.Unless authorized by such terms,you must inquire before using clientresources for activities other thanperforming an engagement for theclient; you should seek such guidancefrom your job or project manager, whocan then address the contemplateduse with the client if appropriate.In addition to firm policies, youmust review and adhere to all clientpolicies regarding permitted personaluse of the asset.In using a client-issued IT asset(including client-provided e-mailaccounts), limit the businessinformation that you store or transmiton it to information related to the32THE GREEN BOOK | The Booz Allen Hamilton Code of Business Ethics and Conduct


engagement or purpose for which theasset was provided. Because clientscan monitor and inspect use of theirIT assets, do not store or transmitBooz Allen or third-party proprietaryor confidential information on them—other than information intended fordelivery to the client.Prohibited Uses You are prohibitedfrom using any firm or client IT assetsfor any inappropriate, wrongful, orillegal purpose, or from engaging inany activity that could cause harmor violate the rights of the firm, ourclients, or others.You may not use firm or clientIT assets to obtain or processinformation that you do not have theright to access and use. You maynot install or use peer-to-peer, filesharing, or other similar softwaredownloading applications or serviceson firm or client IT assets unlessspecifically authorized. Further, youmay never use firm or client IT assetsto compete with the firm or performpermitted secondary employment (asfurther described in Section VI.3–Personal Conflicts of Interest FromQ&AQ: A free version ofcollaboration software isavailable on the Internet.Can my team download thesoftware for use on our latestproject?A: It depends. The particularsoftware you are interested inmay be prohibited by the firm,and the software license termsof use may exclude using it ina business environment or forcommercial purposes. Alwayscheck with Information Servicesbefore downloading anysoftware and make sure youwork with the purchasing teamwhen licensing software (evenat no cost) for business use.Outside Activities); engage in politicalactivities (as further described inSection VI.8–Political Activities); viewor store sexually explicit or otherinappropriate or offensive materials;or harass, defame, intimidate, orthreaten others.No Expectation of Privacy You haveno expectation of privacy regardingyour use of any firm or client-issuedIT assets. We reserve the right tomonitor and inspect your use offirm IT assets at any time withoutnotice to you and without yourconsent. Clients may also performsimilar inspection or monitoring inconnection with the use of their ITassets. Also, remember that all datastored on a firm IT asset is owned by,or licensed to, the firm, and clientsmay have similar ownership rights todata stored on their IT assets.Using Personal IT Assets to ConductFirm Business You are responsiblefor the security of any firm or clientinformation that you place on apersonal IT asset such as a homecomputer, tablet, or smartphone toconduct firm business.Before performing work or storingfirm or client information on apersonal IT asset, you must ensureyou are appropriately protectinginformation. For client information,discuss the contemplated usewith your job manager to ensurethat such use does not placesensitive information at risk andcomplies with client contractrequirements. For firm information,discuss the contemplated usewith the information’s owner; anypermitted use must comply with allapplicable firm policies, including theInformation Categorization Policy.Where use of a personal IT assetis permitted, you must keep firmand client information secure fromunauthorized access (including fromfamily members or others with whomyou share a computer or device).The firm or a client may require thatyou enter into an agreement prior tousing a personal device to connectto certain firm or client IT assets;when such an agreement is required,you must adhere to its terms andconditions. Regardless of whethersuch an agreement is required, if youstore firm or client information on apersonal IT asset, you must allow thefirm to access such device to recoveror secure any such information. Anysuch accessing of a personal ITasset will be done in accordance withfirm procedures and, to the extentpractical, will avoid accessing anynon-firm or non-client informationstored on the IT asset.Key policies related to thisCode section:ooooooIT Acceptable UseCopyrighted MaterialWorkplace and SexualHarassment6. Records Retention;Accuracy of Recordsand EntriesBooz Allen records are firm assetsthat must be retained in a specifiedmanner for prescribed periods.All entries in firm records must beaccurate, and no employee may alterany entry to conceal or misrepresentthe underlying transactionrepresented by it.What Constitutes a Record A record isdefined as any recorded information,regardless of format, which is madeor received as evidence of a businesstransaction, decision, or has value tothe firm. Records include electronicand paper documents (e.g., e-mail,personnel data, financial transactionsand reports, marketing and clientinformation, and intellectual capital).In creating any record, you mustbe truthful. Specifically, each of usmust ensure that the record fully andThe Booz Allen Hamilton Code of Business Ethics and Conduct | GREEN BOOK 33Chapter V


“To me, the Core Values are more than rules ofthe road. They’re an ideology that defines us as atop-level consulting firm and a set of practices that helpme be the best I can be—because of Booz Allen’s strongvalue system, my professional and personallives complement each other.Our Core Values speak to many elements ofgood business. With both internal and externalclients, entrepreneurism and professionalism stand outin my Booz Allen experience. Exemplifying these valueshas led to new roles, new challenges, and new skills. ”—Jeremy RankinVIP Award Winner 2012 (Herndon, VA)EntrepreneurshipQ&AQ: My project has ended andI have a box full of monthlystatus reports delivered to myclient. I’m moving to a newassignment. Because thecontract is over, can I get ridof them?A: It depends. Consult theRecords and InformationManagement Policy for theretention period associated withthese reports.Remember that even if theretention period for thesedocuments has expired, youmust retain them if they aresubject to a records hold orare otherwise required to beretained under this Code or firmpolicy. Never destroy or disposeof records until you havedetermined that they meet allappropriate criteria.accurately represents the transactionor event being documented.Retaining and Disposing of RecordsYou must preserve firm records inyour custody in conformance withfirm policy. Except as authorizedin firm policies, you must retainthe records in their original formor media. For example, a paper filemust be retained physically unlessfirm policy permits conversion of it toelectronic format.You may destroy or properly disposeof records in your possession atthe end of the prescribed retentionperiod, except where (1) the recordsare subject to a Records Hold Orderissued by the Law Department, or(2) you are aware of any existing,imminent, or likely audit, claim,dispute, investigation, or other similarproceeding to which the record maybe responsive or relevant.Key policies related to thisCode section:ooRecords and InformationManagement34THE GREEN BOOK | The Booz Allen Hamilton Code of Business Ethics and Conduct


Chapter VI: Conflicts of InterestObjectivity and independence are fundamental to the value of the services we render to our clientsand the duties each of us performs for the firm. The exact point when one firm activity or one ofour personal activities or relationships creates a conflict of interest with another firm activity, or ourobligations to a client or the firm, cannot always be precisely defined. Moreover, the mere appearanceof a conflict can be just as damaging as where one actually exists. Each of us must understandwhen actual or perceived conflicts could arise and take appropriate action as soon as we identify thepossibility of one.1. OrganizationalConflicts of InterestBooz Allen does not accept workassignments that create anorganizational conflict of interest(OCI) with other client work thatthe firm performs without a clientapprovedconflict mitigation plan.Every employee must be aware of,and proactively identify, potentialOCIs applicable to the firm’s work.Employees may not engage inactivities that violate US Governmentprocurement rules related to ImpairedObjectivity or Biased Ground Rules(as defined below), violate contractualOCI restrictions and obligations,or use non-public information in amanner that could create an UnfairCompetitive Advantage (as definedbelow) for the firm.Types of Organizational Conflictsof Interest For US Governmentengagements and procurements,OCIs involve circumstances in whichthere is “Impaired Objectivity,”“Biased Ground Rules,” or“Unfair Competitive Advantage.”Impaired Objectivity involves acontractor providing services thatmay inappropriately influence theGovernment’s decisions relatedto its other contractual interests,such as by overseeing, managing,directing, evaluating, or testingits own products, services, ordeliverables. Biased Ground Rulesmay exist when, under contract, acontractor helps its clients define theterms of a competitive procurementfor which the same contractor mayhave an interest in competing. UnfairCompetitive Advantage involves acontractor’s unequal access to nonpublicinformation in a competitive USGovernment procurement.Identifying Potential Conflicts ofInterest Effective conflict screeningand identification requires yourdiligence during all phases ofstrategic planning, businessdevelopment, proposal development,and contract execution. If youidentify a potential OCI regardingeither current or contemplated work,contact your job manager, contractadministrator, and/or the OCIProgram Office. Prompt action mayQ&AQ: I discussed a potentialconflict of interest with myclient’s technical lead andhe said not to worry aboutit because it doesn’t affectthe task I’m working on. DoI have to do anything else?A: Potential conflicts ofinterest must be reportedto the Booz Allen OCIProgram Office, contractadministrator, or job managerwho will assess the situationand address any potentialconflict with the clientcontracting officer.permit certain types of conflicts tobe mitigated through client-approvedmeasures (e.g., through the use ofNDAs and firewalls). Other types ofconflict cannot be mitigated and mustbe avoided through current or futurebusiness restrictions.Using Competition-SensitiveInformation In performing anengagement, you may have accessto non-public information that couldbenefit the firm in seeking futurework. Such information may take theform of sensitive government programinformation or proprietary informationof other companies. Remember thatsuch information may be used onlyfor performing the current clientengagement. The firm may not usesuch information to compete forfuture work. If you are involved in aproposal effort, you may not seek toobtain such information from others.Working Under a Conflict of InterestMitigation Plan or a NDA If you areassigned to a project on which thefirm has implemented a conflict ofinterest mitigation plan with the client(e.g., internal firewalls or personalNDA requirements), you mustensure that you fully understandhow the plan affects you beforestarting to work and adhere to theplan’s restrictions throughout andfollowing the assignment. Firewallsmay limit future client assignmentsand proposal work that you can do.When you must personally executean NDA, carefully review it (obtainingThe Booz Allen Hamilton Code of Business Ethics and Conduct | GREEN BOOK 35Chapter VI


your contract administrator’s reviewas necessary) before signing, andensure that you understand anyspecial restrictions it imposes. Youare responsible for informing futureproposal and program managersof any restrictions on your ability tosupport the firm’s business activitiesbased on the work you may havepreviously performed, including NDAsand OCI Mitigation Plans.2. PersonalConflicts of InterestBooz Allen’s ability to deliverobjective, independent, and unbiasedadvice and assistance to a clientcan be affected by an employee’spersonal conflicts of interest. Allpersonal conflicts of interest affectingan employee must be disclosed toBooz Allen. The firm takes appropriatesteps under the circumstances toavoid, mitigate, address, or obtain awaiver of personal conflicts identifiedby employees.Understanding Personal Conflicts ofInterest A personal conflict of interestarises when an individual’s personalinterest interferes with the interestsof our firm as a whole, includingwhen judgment is compromised, ora reasonable person would questionhis or her objectivity, because ofpersonal interests that compete withthe interests of the firm or our client.For purposes of this Code, a conflictof interest exists where there iseither an actual or perceived conflict.Some conflicts will be specific to anassignment or task, while othersmay affect all work for the firm. Theymay be present at the beginning ofyour employment at the firm or workon an assignment or may arise laterdue to changes in your personalcircumstances, the firm’s business,or the scope of an engagement.Identifying and addressing personalconflicts requires diligence andsituational awareness by each ofus, especially because each andevery type of conflict cannot beprescriptively defined. Two of themost common types (discussedbelow) involve personal financialholdings and interests of immediatefamily members. Others that canarise from personal activities arediscussed later in Section VI.3–Personal Conflicts of Interest FromOutside Activities. The fact that atype of conflict is not specificallyaddressed in this Code does notreduce or eliminate your obligation todisclose it.Personal Financial HoldingsA personal financial holding hasthe potential to create a conflictof interest if you provide advice orassistance that has a direct andpredictable effect on that holding.For example, a conflict of interestcould exist if you are advising a clientregarding a procurement where youhave a financial stake in a companythat provides the product or servicebeing procured, or you are advising aclient on policies that directly affecta company in which you have invested.Interests of Immediate FamilyMembers Interests of immediatefamily members can create apersonal conflict of interest for anemployee if the family member’sinterest affects (or reasonablycould be perceived as affecting) theemployee’s objectivity regarding hisor her assigned duties. For example,a conflict could exist if you areassisting a client or the firm withsource selection and one of thepotential awardees is your spouse’semployer. Alternatively, a conflict mayexist where a family member worksfor the client and your work involvesor could affect him or her.Disclosing Personal Conflicts ofInterest Unless another provision ofthis Code (e.g., Section VI.3–PersonalConflicts of Interest From OutsideActivities) or a firm policy requiresdisclosure to a different individual orgroup in the firm, personal conflictsof interest related to a specificassignment must be disclosedto your job manager; and generalconflicts must be disclosed to yourcareer manager.You must immediately make eachdisclosure in writing (e-mail beingacceptable) and fully identify thenature of the conflict and all relevantfacts as soon as you become awareof it.Contractually Required DisclosuresCertain client contracts require ouremployees to disclose financial andother types of personal interests.Where these obligations apply, youQ&AQ: My brother works for a client who will be issuinga new RFP that my team intends to pursue. While hehas access to some information tangentially relatedto the procurement, he is not directly involved in it;also, he and I never discuss work matters. His managerknows I’m his sister and has not expressed anyconcerns. Do I have to report this to my job manager?A: Yes. The appearance of a conflict can be just asserious as an actual conflict of interest and must bemanaged appropriately. Remember that, if the firm winsthe project, a competitor could raise concerns and weneed to be able to demonstrate how we mitigated thesituation beforehand.36THE GREEN BOOK | The Booz Allen Hamilton Code of Business Ethics and Conduct


must make the disclosures identifiedto you by the job manager. You alsohave a continuing duty to update yourdisclosures during the periodof performance.3. PersonalConflicts ofInterest fromOutside ActivitiesAlthough Booz Allen respects therights of its employees to conducttheir personal lives and non-workendeavors as they choose, severaldifferent types of activities posepotential conflicts of interest andthus must be disclosed to and/orapproved by the firm asdetailed below.Secondary Employment Except asauthorized, you may not operate anoutside business or be employed,under contract or otherwisecompensated simultaneously byanother entity. If you wish to obtainan exception to this prohibition, youmust obtain prior written approvalfrom Human Resources and yourmanagement, up through yoursupervising officer. You shouldcontact your Human Resourcesrepresentative for instructionsregarding this process. Approvalmay be conditional (e.g., basedon your undertaking only certainactivities or limiting the amount oftime you dedicate to the secondaryemployment).Outside Leadership or AdvisoryPosition You must obtain approvalfrom the Law Department andmanagement to serve on the boardof directors or advisory board ofanother private entity (including anonprofit or charitable organization);hold a leadership position in anindustry, civic, or other organization;or serve on a governmental board,commission, or panel. Based onits review, the Law Departmentwill identify the appropriate level ofRespect and fairness are so essential to teamwork.“When you treat others the right way, it has a ripple effectthat inspires trust and motivates people to deliver a betterquality product. Everyone comes here with some type ofethics and value system. As you’re with the firm, and seepeople exhibit our Core Values, succeed because of them,and be rewarded for them, you find that our value systemreinforces your own beliefs, not just at work but in yourpersonal life as well. Acting with integrity has a profoundeffect on all aspects of life.I’m really impressed—and proud—that our values are“so important to the organization and my teammates. ”—Cynthia HernandezVIP Award Winner 2012 (San Antonio, TX)teamworkThe Booz Allen Hamilton Code of Business Ethics and Conduct | GREEN BOOK 37Chapter VI


“The Core Values are fundamental to who and what weare as a firm. I have always told my team, you may getoffers with more money and big promises. At the endof the day, ask the important questions. Can you trustthe people who are leading you? There is value thatsurpasses just dollars. It’s the team that sustains us. ”—Marc AsherVIP Award Winner 2012 (San Antonio, TX)EXCELLENCEmanagement that must approve theleadership role. Approval may beconditioned on your recusing yourselffrom certain matters for the otherorganization or taking other steps toavoid a conflict of interest.Volunteer Activities We encourageemployee participation inprofessional, educational, civic, andcharitable organizations. However,you may not engage in volunteeractivities that constitute a conflict ofinterest. In any non-firm-sponsoredvolunteer work, you must act in yourown name, and you may not authorizethe organization to use the firm’sname or otherwise imply that wesupport its activities. Also, take extracare when volunteering for groupsthat perform advocacy work or lobby.Outside Speaking Engagementsand Interviews You must obtainapproval from your supervisingofficer prior to accepting a publicspeaking engagement or mediainterview outside the firm eitheras a representative of the firm orin a personal capacity (other thanthose required by a client contract).In obtaining such approval, youmust disclose any fees or othercompensation (e.g., free conferenceattendance) you will receive.Authoring Works To avoid conflictswith the firm’s client engagementsand the intellectual propertyownership agreement you signed withthe firm, you must obtain approvalfrom your officer, the Law Department,and Marketing and Communicationsbefore (1) authoring works (outsideof your work activities and not inconnection with an approved outsidespeaking engagement) such asbooks, articles, blogs, or onlinepostings for general publication inyour professional capacity or in anyway related to the firm’s business orclient engagements (regardless ofwhether you are personally involvedin them), or (2) signing any publishingagreement. The firm’s name may beused in a publication only when thecontent is related to, or the directresult of, activities on our behalfand only with prior approval fromMarketing and Communications.Payments and Awards forProfessional Activities In general,employees may not accept fees,payments, or other items of valuefrom companies whose products orservices they may recommend toa client. You must obtain approvalfrom your officer-in-charge beforeentering any competition or acceptingany other type of payment or awardrelated to your professional activities.This includes competitions andawards from clients, vendors, orcompanies whose products you haveimplemented for an assignment.Discussing Employment Witha Current Client Employmentdiscussions with your current client—initiated by you or the client—mayconstitute a conflict of interest. Youmust inform your officer-in-charge ofany such discussions or if your clientsolicits you for employment.Q&AQ: One of the client’s taskleads from my project askedme about coming to work forthe firm. He has a clearanceand skills that we need. Whatshould I do?A: Thank him for his interestin the firm but do not get intoan employment discussionwith him. Put him in touchwith the recruiter responsiblefor your group. Given hisposition, he may need tonotify his supervisor beforehaving any employment-relateddiscussions with the firm.38THE GREEN BOOK | The Booz Allen Hamilton Code of Business Ethics and Conduct


Loans Providing loans to, orguarantees of obligations of,employees or their family memberswill not be allowed without the priorwritten approval of the Law Departmentand, if appropriate, the Board ofDirectors or a committee of the Boardof Directors. Booz Allen will not extend,maintain, or arrange for any personalloan to or for any director or officer.4. Gifts, Gratuities,and BusinessCourtesiesBooz Allen employees (eitherpersonally or via an intermediary)may not give gifts to, or receivegifts from, clients, subcontractors,suppliers, or other current or potentialbusiness contacts in exchange forfavorable treatment or entry into anybusiness relationship or transaction.Employees are generally prohibitedfrom giving or receiving gifts or loansto or from government personnel.Employees may give or receive giftsand other business courtesies toor from non-government businesscontacts only as permitted by ourGift and Business Courtesies Policy(“Gift Policy”).Gifts Involving Government PersonnelYou and your immediate family areprohibited from giving or offeringgifts or loans to, or accepting giftsor loans from, US Governmentpersonnel (including US federal,state, and local governmentemployees) except as specificallyauthorized by our Gift Policy. Withrespect to US Government personnel,our Code is more restrictive thanthe requirements of applicableregulations. There is no “minimalvalue” exception, and this ruleapplies equally to giving and receivinggifts and loans from governmentpersonnel.Gifts Involving Non-GovernmentBusiness Contacts You may offer,give, or accept a gift from a nongovernmentbusiness contact if it(1) is of reasonable value, (2) iscustomarily provided in the contextof the existing or contemplatedbusiness relationship, (3) doesnot create a conflict of interest orappearance of impropriety, (4) is nototherwise prohibited by contract,and (5), if required, is approved inadvance pursuant to our Gift Policy.Similar to our prohibition on givinggifts or business courtesies to USGovernment personnel, limitedexceptions apply as set forth in ourGift Policy.What Constitutes a Gift For ourpurposes, a “gift” is anything givenfrom one party to another for whichthe full value of the item is not paidby the recipient. Gifts include tangibleobjects; hospitality, such as food,beverages, or accommodations; andtransportation to and attendanceat events or gatherings that areprovided free of charge or below cost.They also include donations madeto a charity or other organization insomeone else’s name. Gifts excludeitems that the recipient reimbursesunder the terms of a contract, or forwhich the recipient pays the providerthe full cost of the item, whereappropriate, via a “fair share” or“honor” box.Key policies related to this Codesection:ooooGifts and Business CourtesiesPost-Government EmploymentQ: Can I give or accept a ride from a client staffmember from our work site to an offsite project event,or is that considered an impermissible gift?A: It depends. You should consult our Gifts andBusiness Courtesies Policy and/or contact the LawDepartment, the Ethics and Business Integrity Office,or EthicsFirst Line for guidance. In some situations(e.g., where providing transportation to the client iscontractually required or reimbursable as an“other direct cost” or ODC) it would not constitute agift. In other situations, it might.In addition to compliance with our gift rules, we alsoneed to consider the potential liability associated withproviding transportation to a client. Consult with theRisk Management team for guidance regarding liabilityissues.Q&AThe Booz Allen Hamilton Code of Business Ethics and Conduct | GREEN BOOK 39Chapter VI


5. Post-GovernmentEmploymentBooz Allen employees must complywith safeguards implemented bythe firm to avoid violating postgovernmentemployment rules when(1) recruiting or having employmentrelateddiscussions with any currentgovernment employee, (2) hiringany current or former governmentemployee, or (3) deploying anyemployee who used to work forthe Government.Understanding the Rules Currentgovernment employees are subjectto various legal restrictions whenseeking employment in the privatesector. Once employed in the privatesector, former government employeesmay face limitations regardingtheir work activities. The intent ofthese legal requirements is to avoidcreating the appearance of a conflictof interest or undue influence. Howeach rule related to recruiting, hiring,and deploying individuals subjectto post-government employmentrestrictions is applied to a particularsituation is highly fact dependent;often, seemingly small details canhave a large impact.Safeguarding Against ViolationsOur Post-Government EmploymentPolicy uses various safeguardsto avoid possible violations. Eachof us must be familiar with itsrequirements before having anyemployment-related discussions witha current government employee. Forgovernment employees with whomthe firm has a “business relationship”(as described in our policy), specialrestrictions apply.Before hiring a current or formergovernment employee, we mayrequire that the individual obtainan ethics opinion (known as aDesignated Agency Ethics Official[DAEO] letter in the US Government)as a condition of hiring so that wecan evaluate whether the candidatecan fulfill his or her intended role.As an individual moves throughassignments, follow-up guidance maybe required to ensure compliancewith the rules.Understanding Your Restrictions andThose of Staff You Manage If you area former government employee, youmust understand the restrictionsthat apply to you and seek guidancebefore accepting any work that maybe restricted. For most former USGovernment employees, this willrestrict certain activities regardingmatters on which you worked orwere under your official responsibilitywhen working for the Government.If you manage former governmentemployees, familiarize yourself withtheir restrictions and seek guidancebefore assigning them to work towhich a restriction might apply.Key policies related to this Codesection:ooPost-Government Employment6. Use of the FirmName/MarksThe goodwill associated with BoozAllen’s name is one of the firm’s mostvaluable assets. To protect this assetand avoid even the appearance ofcompromised objectivity, all uses ofthe firm’s name or marks must beappropriately authorized. Employeesmay not use the firm’s name or theiraffiliation with it for personal gain orin connection with non-firm activities(e.g., charitable or volunteer worknot sponsored by the firm under itscommunity partnerships programs).Authorizing Use by a Third-PartyGenerally, any use of the firm’s nameby a third-party must be definedin a contract. We limit use of ourname by a teaming partner to theparticular teaming effort underapproved contract terms. Similarly,we limit use by service providers todelivering the contracted services.When you represent the firm at anevent, the event organizer may usethe firm’s name solely in connectionwith your role at the event. All otheruses of our name by a third-partymust be approved by Marketing andCommunications.40THE GREEN BOOK | The Booz Allen Hamilton Code of Business Ethics and Conduct


Q&AQ: Can I reference my BoozAllen employment within myprofessional biography?A: Yes. You can generallyreference your position at thefirm, but you may not includethe name of any client you’veworked with or any specificsabout the work you’ve done onbehalf of a client.Personal Use of the Firm’s Name Youmay use the firm’s name in personalmatters not involving personal gainto you when factually representingyour employment here (e.g., in abiographical statement). However,take care that your use does notimply firm sponsorship of you or yourpersonal activities.Endorsements Except in very limitedsituations, we do not explicitlyendorse or imply endorsement ofother companies or their products orservices. No organization, includingclient organizations, can use thefirm’s name in promotion of productsor services without prior writtenapproval. Any exception to thisgeneral rule must be approved byMarketing and Communications,the Law Department, and thesupervising officer.7. CorporateOpportunitiesExcept as expressly provided inour Certificate of Incorporation,Booz Allen employees, officers, anddirectors are prohibited from (1)personally taking for themselvesopportunities that are discovered byusing the firm’s property, information,or position, (2) using corporateproperty, information, or position forpersonal gain, or (3) competing withthe firm.Understanding Firm BusinessOpportunities In the course of yourwork for the firm, you may learnof business opportunities that arewithin the firm’s scope of businessor that the firm might pursue. Youmay not take personal advantageof these opportunities (e.g., pursuethem on your own or refer them tosomeone else for a fee) because youowe a duty to the firm to advanceits interests when the opportunityto do so arises. Rather, each of usmust direct such opportunities toour management so that they maybe pursued by the firm if it is sointerested.Using Firm Resources Similarly, youmay not use the firm’s property,information, or position for personalgain or to compete with the firm.Pay close attention when anothercompany asks for a quote ortestimonial or for permission toreference the firm’s use of a productor service. Even if it will not mentionBooz Allen by name, the contextmay make the firm’s (or our client’s)identity obvious. Any such userequires approval as an exception toour endorsement prohibition.The Booz Allen Hamilton Code of Business Ethics and Conduct | GREEN BOOK 41Chapter VI


8. Political ActivitiesBooz Allen does not engage in anypolitical activities or endorse anypolitical candidates or organizations.Employees may engage in politicalactivities only in their personalcapacity, on their own time, andwithout using firm resources orfacilities.Defining Political Activities Politicalactivities include running for publicoffice; supporting or opposing acandidate for office or a politicalparty, political cause, or ballotinitiative; political fundraising;assisting with political transitionactivities; and other election-relatedactivities, whether partisan or not,such as voter registration and get-outthe-votecampaigns.We do not have a Political ActionCommittee (PAC) and do not makepolitical contributions as a firm.Any financial contributions to apolitical activity must be made fromyour personal funds and will not bereimbursed by the firm. This includespayments to trade associations,civic or nonprofit groups, andother organizations for fundraisingevents even where other events youundertake with such groups wouldotherwise be reimbursed.Running for Office If you plan to seekpublic office, you must contact theLaw Department before registering asa candidate or otherwise starting tocampaign or raise funds.Protecting the Firm’s Neutrality Youmay not use or permit others to usethe firm’s name or your associationwith the firm in any political activities.If questioned, and where otherwiseappropriate, you must make it clearthat the firm does not directly or byimplication endorse your views or anypolitical candidate or organization.You may not use any firmresources—including, withoutlimitation, offices, conference rooms,computers, computer networks,copying machines, fax or telephoneequipment, or e-mail accounts—forpolitical activities.Q&AQ: In my role at the firm, I attend several eventseach year held by a local business association withthe cost of attendance reimbursed by the firm. Theassociation has endorsed our current member of theHouse for re-election and is holding a fundraisinglunch where he will speak. Can I attend?A: Yes, you may attend, but only in your personalcapacity. You may not attend on behalf of the firm, andyour cost of attendance will not be reimbursable as afirm expense. If you decide to attend, you should makeit clear that you are not attending as a representativeof the firm (e.g., not include the firm’s name on yourregistration or name tag) and that the firm does notendorse the candidate.42THE GREEN BOOK | The Booz Allen Hamilton Code of Business Ethics and Conduct


Chapter VII: Subcontracting andPurchasing on Behalf of the FirmLike all organizations, we rely on others to help us fulfill our work requirements and achieve ourobjectives. Regardless of whether we are subcontracting to a small business for a particularopportunity, forming a strategic relationship with another company, or simply purchasing supplies froma vendor, we act as required by our Core Values—just as we would want to be treated when we arethe subcontractor or supplier.1. Fair CompetitionAmong SuppliersBooz Allen fosters fair competitionamong suppliers to procurematerials, supplies, and services atfair and reasonable prices consistentwith quality and other requirements.In soliciting bids, the firm makesspecial effort to reach out to smallbusinesses and small disadvantagedbusinesses to provide opportunitiesfor them to compete for our business.All competitions and purchasesare based on truthful negotiationsconducted at arm’s length to avoidany actual or apparent conflictof interest.Compliance With Subcontractingand Purchasing Procedures. Asfurther set forth in firm policies,you must engage the Subcontractsand/or Purchasing teams to defineQ&AQ: My client’s projectmanager asked that wesubcontract some work to avendor who has worked forhim in the past. Can we goahead with the subcontractbased on his direction?A: No. We must award thesubcontract competitivelyunless we receive officialdirection in writing from thecontracting officer.subcontracting requirements forUS Government projects. Onlydesignated members of such teamsmay authorize a subcontractoror vendor to begin work and/ordeliver goods. You may not provideoral or written authorization to asubcontractor or vendor to start workoutside of such procedures.Competition Among Subcontractorsand Suppliers Competition amongsuppliers is a fair and efficient wayof procuring goods and services forthe firm and its clients. By doing so,we obtain fair and reasonable prices,maintain documentation of our makebuydecisions, and ensure we receivehigh-quality goods and services.Each of us must comply with all firmpolicies, including those relatedto environmental sustainability, inselecting a subcontractor or teammember for a project or a supplier tothe firm.We comply with all laws, rules,and regulations that apply to oursubcontracting work. In particular, forsubcontracts under federal contracts,we comply with the Competition inContracting Act and Anti-KickbackAct; “flow-down” all clauses andrequirements in accordance with theFAR and other laws and regulations;complete all subcontract awardprocedures that we disclose to theUS Government; and verify thata contemplated subcontractor isnot on the Excluded Parties List orotherwise restricted from acceptingthe subcontract.Following execution of a subcontract,we monitor performance to verify thatthe subcontractor meets all qualityand performance standards andcomplies with its obligations.We generally offer competitiveopportunities to supply the firmwith goods and services for its ownconsumption. Often this results inthe firm’s contracting with a preferredsupplier or group of suppliers fora class of items or services tomaximize the long-term benefits wereceive. Where the firm has enteredinto such an arrangement, each ofus must use it unless an exceptionis authorized.Contracting With Small andDisadvantaged Businesses We arecommitted to contracting with smallbusinesses and small disadvantagedbusinesses. We believe incontributing to the communities inwhich we work and in helping theircitizens obtain a fair share of theeconomic opportunities available.We also recognize the importantcontributions that small businessconcerns and minority institutionsmake to the firm—enhancing ourcompetitive edge, our performanceon contracts, and our bottom line—and the part they play in our industryand our future in a global economy.The Booz Allen Hamilton Code of Business Ethics and Conduct | GREEN BOOK 43Chapter VII


Consequently, we are committedto providing subcontractingopportunities to the full range ofsmall businesses and in particularsmall disadvantaged businessessuch as:ooooooooooHistorically UnderutilizedBusiness Zone (HUBZONE)small businessesWomen-owned small businesses(WOSB)Service-disabled veteran-ownedsmall businesses (SDVOSB)Historically black colleges anduniversities (HBCU)Minority institutionsPayments to Nonprofit EntitiesAll firm payments to nonprofitentities—regardless of whetherthey are a donation or a paymentmade pursuant to a contract—mustbe processed via the ContributionsPortal, which is managed by theCommunity Partnerships team withinMarketing and Communications.Such processing supports accuratereporting of the payment for taxpurposes.Truthful Negotiations In dealing withcurrent or potential suppliers, each ofus must be candid and truthful aboutour requirements, accurate in ourstatements, and fair in negotiations,ensuring that all competitors forthe opportunity have equal accessto the same pertinent information.We also do not share proprietaryinformation of other vendors, engagein technical leveling, or otherwiseengage in practices that do notcomply with applicable laws, rules,and regulations.Key policy related to this Codesection:ooProcurement Policy2. BoycottsBooz Allen does not conduct anyoperations or activities that arerestricted under US anti-boycottinglaws and regulations.Understanding Boycotts “Boycotts”are activities that are designed tolimit trade with certain countries,entities, or individuals. US antiboycottlaws and regulations restrictUS firms from participating inforeign boycotts or other restrictiveinternational trade practices that theUS Government does not support.Prohibited Actions You are prohibitedfrom taking any action that furthersor supports a boycott against acountry that is friendly to the UnitedStates and/or a boycott that the USGovernment does not sanction. Theanti-boycott laws and regulationsinclude prohibitions on the following:ooAgreements to refuse or actualrefusal to do business withboycotted countries or companiesorganized under the laws ofboycotted countriesQ: I received a draft contractfrom a prospective clientthat requires us to provideinformation concerning thefirm’s business with thegovernment of Israel. If Iknow the firm has no currentbusiness with the Israeligovernment, may I report thatinformation in our proposaland accept the clause in anyresulting contract?A: No. United States antiboycottlaws prohibit us fromagreeing to any such clause.Moreover, we may be requiredto report the fact that theprospective client includedsuch a clause in its contract.The clause must be removedfrom the contract before wecan execute it, and you shouldcontact the Law Departmentregarding our disclosureobligations.Q&A44THE GREEN BOOK | The Booz Allen Hamilton Code of Business Ethics and Conduct


ooooooAgreements to discriminate oractual discrimination against otherpersons based on race, religion,sex, national origin, or nationalityAgreements to furnish or theactual furnishing of informationabout business relationships withor in boycotted countries or withblacklisted companiesAgreements to furnish or the actualfurnishing of information about therace, religion, sex, or national originof another personThe firm reports to governmentagencies situations in which we arerequested to participate in a boycottor requested to engage in a prohibitedactivity as required by applicable law.Contact the Law Department if youbelieve that we are being asked toengage in an activity that supports aboycott.Key policies related to thisCode section:ooRisk Matrix“The Core Values are a roadmap for life,not just work. Each of them is importantin their own way and help guide my own behavioron the job and at home. Integrity risesto the top for me. Everything stems from there.If you act with integrity, people look at you differently.They trust you. They count on you. They turn to you.Without integrity, you have nothing.”—Linda RyanVIP Award Winner 2012 (Dayton, OH)core valuesThe Booz Allen Hamilton Code of Business Ethics and Conduct | GREEN BOOK 45Chapter VII


Chapter VIII: Modeling Corporate Citizenshipand Fairly Representing OurselvesOur Core Values are not just a model for how we operate internally and deliver enduring results to ourclients. They guide how we represent ourselves to the public and contribute to our communities. OurCore Values also form the basis of our decision to not hire lobbyists and to strictly limit activities byemployees who may be considering lobbying.1. Representing theFirm to the Publicand MediaIn communicating via any publicchannel, Booz Allen truthfullyand accurately represents itselfwhile respecting its confidentialitycommitments to its clients,employees, suppliers, and others.Employees must not discloseinformation through any publicchannel about the firm’s business,client work, or co-workers withoutprior approval from Marketing andCommunications. Any inquiriesfrom the news media must bereferred directly to Marketing andCommunications.External Communications ChannelsPublic channels include any venueor medium that exposes informationabout the firm’s business, clients,or people to the public. For example,public channels include face-tofaceevents (e.g., speeches andconferences); traditional mediachannels (e.g., newspapers, radio,television, books, or magazines);digital and social media channels(e.g., websites, blogs, or other sitessuch as Facebook and Twitter); and“about the firm” marketing materials(e.g., factsheets, brochures, andadvertising).We do not make statements to anythird party that are untrue, inaccurate,or omit relevant information thatmake the statements misleading.Marketing and Communicationsensures that public communicationsconvey relevant facts, maintainour objectivity, and adhere to alllaws, regulations, and contractualobligations.Client References or InquiriesInquiries about a client relationshipor assignment from any outsideorganization must be referred toMarketing and Communications.You may not respond to anysuch inquiries—even to say “nocomment”—without prior approvalfrom Marketing and Communications.Contractual terms and conditionsmay limit our ability to identify ourclients, our contracts with them,or the work that we perform. Thenames of clients and descriptions ofspecific assignments may be usedin business promotion only when theproperly authorized client official hasgranted written permission, or whenthe result of the assignment and ourassociation with the client is a matterof public knowledge or public record.Public Relations Activities on Behalfof Clients You may participate inclient public relations activitiesonly with the prior approval of yourofficer-in-charge and Marketing andCommunications. Approval will beQ&AQ: We just completed amajor report for our client,which is publicly releasedand, in doing so, praised thefirm’s work in helping set itsfuture priorities. A reportercontacted me seeking justa short generic quote abouthow we were pleased tohelp the client to include inher story. Can I provide thequote?A: No. You should refer thereporter to Marketing andCommunications. They willdetermine whether providingthe quote is in the firm’sinterest and, if so, who wouldbe the best spokesperson.Q&AQ: My alma mater has requested an interview for itsalumni newsletter. Can I discuss my employment atBooz Allen?A: Yes. You may generally discuss your employmentwith the firm (e.g., your areas of functional expertise),but you may not specifically reference any clientsor details about your projects. Marketing andCommunications can provide you with additionalinformation on current career opportunities at the firmthat might also be of interest to your alma mater.46THE GREEN BOOK | The Booz Allen Hamilton Code of Business Ethics and Conduct


granted only when the activity isrelated directly to services performedfor the client and only when the clientrequests such participation and thesubject and situation do not call intoquestion Booz Allen’s objectivity orexpertise. In performing any suchactivities, be clear that you arespeaking for the client—not Booz Allen.Key policies related to thisCode section:ooooExternal CommunicationsTradeshows and Event Marketing2. Investor RelationsBooz Allen provides shareholdersand other parties in the financialmarkets with equal and simultaneousinformation necessary to makereasoned investment decisionsabout our securities. Our disclosurepractices are designed to give allcurrent and prospective investorsfair access to this information andcomply with all US securities laws,including Regulation FD as adoptedby the Securities and ExchangeCommission.Our contacts with investors andanalysts within the investmentcommunity are handled by ourInvestor Relations group. No director,officer, or employee of Booz Allen mayrespond to individual inquiries fromthe investment community unlessspecifically asked to do so by anauthorized individual in the InvestorRelations group.3. LobbyingBooz Allen neither employs norengages lobbyists. In limitedcircumstances, the firm mayauthorize an employee to engage inan activity that constitutes lobbyingunder applicable law. Any suchactivities must be authorized inadvance by the Law Department.Understanding What Constitutes“Lobbying” The definition of lobbyingfor federal purposes is very detailedand complex; each state and manylocalities have their own definitions.For our purposes, lobbying includesany communication—written or oral,including testimony—with seniorfederal, state, or local legislativebranch officials (e.g., politicalappointees, flag or general officers, orpolicy makers) intended to influencelegislation, regulations, executiveactions, programs, or contracts.Lobbying may include targetedmarketing activities and preparationfor the types of communicationsdescribed above.Engaging Business DevelopmentConsultants Many firms or individualsthat help government contractorsdevelop their business also lobby.The Law Department must approveany contract with such consultantsin advance to ensure that thecontracted services do not includelobbying or require the consultant toregister as our lobbyist.Participating in Trade Associationsand Other Organizations That LobbyWe belong to various associationsand groups that may engage inlobbying activities. In our participationwith such groups, we avoid directlyengaging in their lobbying activities.If you represent the firm to such agroup, seek guidance from the LawDepartment to understand whatyou are permitted to do. Also, asfurther discussed in Section VI.3–Personal Conflicts of Interest FromOutside Activities—any employeewho becomes involved in a personalcapacity with such groups needs toclearly distinguish between his orher personal involvement and thatof the firm.Direct Contact With Legislative BodiesThe Law Department must approveany direct interaction between anemployee and a legislative bodyon behalf of the firm. Because ofpotential conflicts and lobbying rules,you may not provide testimony oradvice to a legislative body or engagein conversations with legislatorsor their staff regarding any matterrelated to the firm’s business—evenin a personal capacity—withoutprior written approval from the LawDepartment.Lobbying on Behalf of Clients We donot lobby on behalf of clients. TheFAR bans federal agencies fromcontracting for lobbying services. Thisban includes testifying on behalf of afederal agency, drafting testimony forits officials to deliver, or respondingto questions from Congress.The Booz Allen Hamilton Code of Business Ethics and Conduct | GREEN BOOK 47Chapter VIII


4. EnvironmentalCommitmentBooz Allen is committed to creatingsignificant and lasting improvementsto the sustainability of our world—through the work the firm does forclients and in the way we work.Fulfilling Our Commitment We developinnovative and sustainable solutionsfor our clients to help addressglobal challenges while promotingresponsible consumption ofresources in operating our business.Our partnerships and philanthropyin the communities in which we liveand work further strengthen oursustainability commitment.Consistent with our CoreValues, in our operations, weendeavor to reduce our impacton the environment (e.g., energyconsumption, greenhouse gasemissions, water use, and wastegeneration).We comply with all applicableenvironmental laws and regulations,as well as operate in a manner thatincorporates leading practices suchas pollution prevention techniques,efficient use of resources, andminimizing waste generation.We have established groups withinthe firm to ensure that sustainabilityconcepts are fully incorporated intofacilities infrastructure, procurement,travel, human resources, andinformation systems. These groupsinclude a Sustainability SteeringCommittee comprised of officers, aSustainability Program ManagementOffice that implements our program,and a Sustainability Committeeconsisting of senior employees.Your involvement is critical to ourprogram. Our offices have establishedemployee-led Green Committeesthat develop sustainability programsunique to their locations, offer freshideas, and coordinate local volunteerenvironmental activities. To becomeinvolved, contact the SustainabilityProgram Management Office or yourlocal Green Committee.48THE GREEN BOOK | The Booz Allen Hamilton Code of Business Ethics and Conduct


5. CommunityInvolvementBooz Allen is committed to beinga model corporate citizen thatcontributes to the communitiesin which we work and live. TheCommunity Partnerships team withinMarketing and Communicationsmust approve all firm charitablecontributions to organizations.Q&AQ: My leadership wantsto sponsor a charity eventimportant to our businessand team. How do I processthat donation?A: Through the ContributionsPortal. All payments tocharitable, civic, professional,or any other nonprofitorganization by the firm mustbe processed through thefirm’s Contributions Portal toensure that they are properlyapproved and categorized.Payment of Contributions andSponsorships We must ensurethat resources and the goodwillassociated with our sponsorshipof an organization are given toorganizations that prudently managetheir operations and make a positiveimpact on the community.All payments to charitable, civic,professional, or any other nonprofitorganization by the firm mustbe processed through the firm’sContributions Portal, through whichthe Community Partnerships teamreviews and approves them. Theteam will ensure not only thatcontributions are categorizedappropriately in accordance with FARand IRS regulations but also that theorganization efficiently delivers valueto its beneficiaries and does notappear on any terrorist watch lists.The Community Partnerships teamalso reviews all requests for firmsponsorship of a group or event, aswell as proposed pro bono work bythe firm.Pro Bono Work Our consultingservices are called pro bonowhen Booz Allen is deliveringprofessional consulting servicesat no charge to a client that is anonprofit organization or accreditededucational institution. Firm policiesand guidance are applicable to thestaff, client relationship, and workperformed, including policies relatedto time and expense reporting, andthe use of Booz Allen’s name andexternal communications. All probono projects must be reviewed byCommunity Partnerships (for riskmitigation) and approved by thefunding group’s senior leadership.Skills-Based Volunteerism The firmdefines a skills-based volunteeras someone who voluntarilydonates his or her specializedprofessional skills to help a nonprofitorganization increase its capacityand effectiveness. Skills-basedvolunteerism includes activitiessuch as strategic planning, programevaluation, and communicationsdevelopment. To mitigate riskto you (the volunteer) and to thefirm, when you support skillsbasedvolunteer opportunities,you and a representative of thenonprofit organization are askedto acknowledge that your skills,knowledge, and abilities are offeredon a personal basis and not on behalfof the firm. Time spent on skillsbasedvolunteer projects is not awork activity. Work products cannotbe branded as Booz Allen material.Contact the Community Partnershipsteam for additional guidance.Getting Involved Rather than simplyencouraging cash contributions tocharitable, educational, and civicorganizations, we encourage youto take an active approach to yourand the firm’s involvement in thecommunity.You can do so by working throughan established group within the firmor by participating in a sponsoredactivity, or you can start your owngroup or activity. If you would like todo so, please contact the CommunityPartnerships team.The Booz Allen Hamilton Code of Business Ethics and Conduct | GREEN BOOK 49Chapter VIII


“We have two constants at Booz Allen, our CoreValues and change. Our Core Values help usnavigate change. We’ve made a commitment—toourselves and our clients—that we will maintain thehighest ethical standards in running the business.As such, our Core Values and the Green Book mustbe the basis for every decision we make each day,from how we pursue and win business and treatour clients, to the professionalism and respect withwhich we engage each employee.”—Gale Smith, Chief Ethics and Compliance Offi cerThe Ethics and Business Integrity Offi ce coordinates the EthicsFirstprogram. It is accountable to the Ethics Committee, CEO, Board ofDirectors—and, most important, you.This mission of the Ethics and Business Integrity Offi ce is to mitigateenterprise risks and promote the highest ethical behavior by:o Holding leaders and staff accountable for making the right choiceo Providing them the tools to be effective in doing so, ando Providing mechanisms to document and enforce those behaviorsindividually and collectively as a firm50THe green BOOK | The Booz Allen hAmilTon Code of Business eThiCs And ConduCT


IndexAAffirmative action 23Alcohol usage 26Anti-Kickback Act 10, 43Antitrust Laws 14BBoard of Directors/Audit Committee 5, 9, 11, 23, 37–38, 50Boycotts 17, 44Business development consultants 47CClassified information 26, 29–30ClientsClient-furnished equipment and resources 32–33Confidential information. See Information handlingContract execution 12, 35Contracting officers 17Drug screening requirements 26Employment-related discussions 39–41Engagement performance 13, 16–18, 35–36Engagement risks 15–16Expense allowability 21–22Giving or accepting gifts or loans. See Gifts and gratuitiesHarassment 6, 23, 25International 17–18Onsite work and direction 17Oversight and regulators 9–10Preparation of testimony or lobbying 13, 46–47Proposals 13–15Public relations activities 47References 41, 46Rendering procurement advice 13–14Statements on behalf of firm 13, 46Competitive intelligence 13–14, 35–37Confidentiality/confidential information.See Information handlingConflict of Interest Mitigation Plan.See Conflicts of interest, organizational (OCI)Conflicts of interestDisclosures 36–37Familial/romantic relationships 24, 36Financial 35–37Organizational (OCI) 14–15, 35Personal 36–37Contingent fee prohibition 13Contract signing 15, 17, 27–29Contributions portal 43, 48Copyright infringement 30–31Credit and purchasing cards—firm issued 22Criminal convictions—reporting obligation 25DDisciplinary action 10–11Disclosure Committee 10Disclosure of information or documents.See Information handlingDisclosures to the government 10Discrimination and equal opportunity 23, 44Document retention and preservation.See Information handlingDrug usage and screening 26EEndorsements and testimonials 41Environmental and sustainability commitments 43, 48Ethical decision making 5–8Ethical leadership 5–8Ethics and Compliance Committee 5EthicsFirst Line 7–9, 13, 23, 25, 39EthicsFirst program 4, 5–8Ethics guidance 5–8Expense reimbursement, reporting, and approval 17, 21–22Exports 17–18FFair Share or Honor Box 39False Claims Act 10FAR Mandatory Disclosure Rule 10Firm name/mark usage 41Floor checks 10Foreign Corrupt Practices Act (FCPA) 17–18Frequent flier miles 22GGifts and gratuities 17–18, 22, 39Government oversight 9–10The Booz Allen Hamilton Code of Business Ethics and Conduct | GREEN BOOK 51


IInformation handlingClient information 12–17, 27–29, 32–33Employee personal data 30–31Firm information 9–11, 30–31, 46–48Improper receipt of information 12–14Labeling and marking information 31NDAs and other contractual confidentiality obligations 13–14,16, 27–29, 32, 35, 46Prior employer 13Retention, management and preservation 9–10, 13, 19–22,28, 32–33Solicitation of information 13–14Source selection and bid and proposal information 14–18, 36Third-party information 14, 27–29, 32Inherently government functions 15–16Insider trading 32Internet usage 32Investigations 8–10Investor relations 47LLegislative body contacts or testimony 47–48Lobbying 13, 46–47MManager obligations 5–9, 14, 17, 19–21, 24–25, 33–38, 44Media relations 46–47NNon-Disclosure Agreements.See Information handling—Contractual confidentialityobligationsNon-Retaliation 6, 8, 23–24OOrganizational Conflicts of Interest.See Conflicts of interest, organizationalOutside board, advisory or leadership positions 37–38Outside employment or business opportunities 37–38, 40Outside payments 18, 38–39PPeer-to-Peer (P2P) software 32–33Personal computer or IT asset usage for firm business 32–33Personally Identifiable Information (PII) 27–29Personal use of firm IT assets 32–33Political activities and fundraising 33, 42Post-government employment rules 14, 40Prior employer information. See Information handlingProcurement Integrity Act 12–15Proprietary information. See Information handlingPublic company obligations 9–10, 31Public statements 12–13, 31, 41–47Publishing works 38Pursuing public office 42RRecordsDefinition and accuracy 33Retention.See Information handling—Retention, management,and preservationReporting misconduct 4–9, 11, 24–25Risk Matrix 15–18, 45SSecurityClearances 10, 26, 29–30Facilities 25Signature Matrix 16Small and disadvantaged business contracting 43–44Software downloading and usage 17–18, 32–33Speaking engagements 38, 46–47Standard Practices & Procedures (SPP) Manual 29Subcontracting 16, 43–45Subcontractor role 6, 8, 13, 16, 18, 23, 27, 31, 39, 43Subpoenas 10TTeaming arrangements 14–15, 41Technology usageClient-provided.See Clients—Client-furnished equipment and resourcesFirm-provided 32–33Time Reporting 19–22Trade associations 32, 42, 47Travel 17, 21–22, 33, 48Truth in Negotiation Act (TINA) 12–13, 44VVendorsPreferred vendors 21, 43–44Reward programs 22Selection and negotiation 43–44Volunteer activities 38, 41, 48–49WWeapons 25Work product ownership 27, 30–33, 3852THE GREEN BOOK | The Booz Allen Hamilton Code of Business Ethics and Conduct


This Code is effective April 1, 2014, and supersedes any prior version as ofsuch date.This Code applies to all directors, officers, and employees of Booz AllenHamilton Holding Corporation, Booz Allen Hamilton, Inc., and all subsidiariesthereof.To aid understanding of the firm’s policies that relate to subjects coveredin a section, at the end of certain sections, some specific firm policies areidentified. These policies may be revised, revoked, or superseded at anytime, and new relevant policies may be issued subsequently. The absenceof a policy in this Code does not in any manner limit the effectiveness of thepolicy, and as further described in this Code, all employees are expectedto adhere to all of the firm’s active policies and procedures, whether or notthey are identified in this Code.This Code applies to Booz Allen’s non-US operations insofar as it doesnot conflict with applicable local law. Should such conflict occur, this Codeshall be deemed modified so as to avoid the conflict and shall be deemedeffective to the fullest extent allowed by such law.Photographs by Melissa Blackall© 2014 Booz Allen Hamilton Inc.

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