boozallen-code-of-ethics

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