boozallen-code-of-ethics

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