Ethics Code of Conduct

This Code of Conduct confirms Northeast Data, Inc.'s commitment to ethical behavior wherever we work. As employees of Northeast Data, Inc., we are obliged to adhere not only to the provisions of this code but also to recognize the benefits of conducting ourselves in a professional manner that will attract and retain customers, secure good standing in our communities, protect our company’s interests, and maintain our reputation for quality and excellence.

On or off duty, an employee’s conduct reflects on the company. All employees are expected to observe the highest standards of professionalism at all times.

Being ethical includes not only following the law but also choosing the ethical path in your decisions and actions. For that reason, Northeast Data, Inc. does not tolerate and prohibits wrongful, illegal, unethical, or harmful behavior by its employees or any other person who interacts with Northeast Data, Inc.

It is not possible to list all forms of behavior that are considered unacceptable in the workplace. The following examples may result in disciplinary action, up to and including termination of employment without prior warning. Prohibited wrongdoing includes, but is not limited to:

• Stealing: Whether from Northeast Data, Inc., customers, vendors, suppliers, coworkers, or any other participant in Northeast Data, Inc.’s workplace.
• Embezzlement: Including embezzlement of Northeast Data Inc.’s funds or the funds of coworkers, customers, clients, vendors, suppliers, or other workplace participants.
• Fraud: Including, but not limited to, providing false or misleading information on time sheets, account sheets, expense forms, and making false claims under Northeast Data Inc.’s insurance or benefits policies.
• Pilfering: Taking Northeast Data Inc.’s property for personal gain.
• Intentional Destruction: Destroying Northeast Data Inc.’s property or the property of coworkers, customers, clients, vendors, suppliers, or other workplace participants.
• Improper Use of Resources: Utilizing personnel for projects, tasks, or work outside the scope of business; using computer, Internet, and telephone resources and privileges for personal or financial gain; or using your affiliation with Northeast Data, Inc. for personal or financial gain.
• Illegal Gambling: Placing or taking illegal bets during work hours, on Northeast Data, Inc.’s property, or by using Northeast Data, Inc.’s resources, including computer resources, for gambling.
• Unethical Accounting or Business Practices: Engaging in illegal or unethical accounting or business practices.
• Improper Interaction: Engaging in unprofessional interaction with other employees, vendors, customers, or workplace participants, including sexual, racial, and other forms of illegal harassment, and other abusive or disrespectful behavior meant to degrade others.
• Illegal Billing Practices: Submitting false statements or invoices, overcharging or undercharging for products or services, mischaracterizing products or services, or any other billing practice prohibited by local, state, or federal law.
• Harmful Practices: Engaging in illegal practices that can harm the public, contravene public policy or the public good, or harm Northeast Data, Inc. in any manner.
• Improper Disclosure: Disclosing confidential information improperly or illegally.
• Illegal Acts: Performing illegal or improper acts as part of your employment, including any breach of duties.
• False Claims: Making knowingly false claims, bearing false witness, or knowingly or recklessly creating false light against other employees, management, customers, or others that interact with Northeast Data, Inc.
• Retaliation: Engaging in improper or illegal retaliation, including the denial of employment opportunities to employees for filing a complaint or making a report, reporting a violation of this employee handbook, filing a complaint of wrongdoing like discrimination or harassment, or blowing the whistle or acting as a witness to any illegal activity.
• Policy Violations: Intentionally violating the policies in this employee handbook.

Retaliation Prohibited

Retaliation can include, but is not limited to, harassment, discrimination, or any other unfair treatment or abuse of power. Northeast Data, Inc. prohibits retaliation of any kind against those who, in good faith, report wrongdoing or who assist in the investigation of a report of wrongdoing. Any employee or workplace participant who retaliates against another employee or workplace participant for making a good faith report of a violation of this policy or for assisting in an investigation of a report of a violation of this policy may face disciplinary action, up to and including termination of employment without prior warning.

If you believe you (or another) are being subjected to retaliation for reporting a violation of this policy or for participating in an investigation of a violation of this policy, you should report the retaliation immediately in the manner provided above, regardless of the accused’s identity or position. Please note that you do not have to confront the person who is the source of the retaliation before reporting it, but you must report it as soon as you experience or discover it. Discussing or reporting acts of retaliation to any person not listed above does not constitute a report.

Workplace Investigations

A report of retaliation for reporting a violation of ethics that is made to those listed above will result in an appropriate investigation of the allegations. Northeast Data, Inc. may use third parties to investigate allegations. All employees and workplace participants have a responsibility to cooperate fully with any investigation. The interviews, allegations, statements, and identities will be kept confidential, on a need-to-know basis, consistent with the law and the investigation process and goals. Unreasonable refusal to participate in an investigation may result in disciplinary action, up to and including termination of employment.

Those found to have committed an ethics violation or retaliated against another in violation of this policy may face disciplinary action, up to and including termination of employment.

Knowingly False Reports Prohibited

Any employee or workplace participant who makes a knowingly false report of an ethics violation or retaliation will be subject to discipline, up to and including termination.

Questions About This Policy

If you have questions, suggestions, or concerns about this policy, you should direct them to your manager.

If you feel uncomfortable discussing your questions, suggestions, or concerns about this policy with those listed above, you can direct them to the Human Resources Department.

Note: Northeast Data, Inc. reserves the right to modify this policy at any time.