Code of conduct
Modern Training Solutions, LLC is committed to conducting business ethically, transparently, and in compliance with all applicable laws and regulations. This code of conduct applies to all employees, contractors, officers, and agents acting on behalf of the company.
Anti-corruption and anti-bribery
We comply with the United States Foreign Corrupt Practices Act (FCPA) and all applicable anti-corruption laws. No employee, contractor, or agent may offer, promise, authorize, or provide anything of value to any government official, political party, or candidate for political office for the purpose of obtaining or retaining business, securing an improper advantage, or influencing any official act or decision.
This prohibition includes, but is not limited to:
- Cash payments, gifts, or entertainment intended to influence a government official
- Payments to third parties with the knowledge or intent that any portion will be used for corrupt purposes
- Facilitation payments, regardless of local custom or practice
- Political contributions made on behalf of the company without prior written approval
Accurate books and records
We maintain books, records, and accounts that accurately and fairly reflect all transactions and dispositions of company assets. No undisclosed or unrecorded fund or account may be established or maintained for any purpose. All transactions must be recorded in conformity with generally accepted accounting principles and the company's internal controls.
Internal controls
The company maintains a system of internal accounting controls sufficient to provide reasonable assurances that:
- Transactions are executed in accordance with management's authorization
- Transactions are recorded as necessary to permit preparation of financial statements and to maintain accountability for assets
- Access to assets is permitted only in accordance with management's authorization
- Recorded accountability for assets is compared with existing assets at reasonable intervals and appropriate action is taken with respect to any differences
Third-party due diligence
Before engaging any third-party agent, consultant, or intermediary who will interact with government officials on the company's behalf, we conduct appropriate due diligence to evaluate the third party's qualifications, reputation, and associations. All third-party agreements must include anti-corruption representations and compliance obligations.
Gifts, hospitality, and entertainment
Modest and reasonable business courtesies, such as meals or event attendance, may be offered to government officials only when they are:
- Lawful under all applicable laws
- Consistent with local custom and practice
- Not offered with the intent to influence an official act or obtain an improper advantage
- Properly documented and approved in advance
Conflicts of interest
Employees and contractors must avoid situations where personal interests conflict, or appear to conflict, with the interests of the company. Any actual or potential conflict of interest must be disclosed promptly to company leadership.
Confidential information and data protection
All confidential and proprietary company information must be protected. Employees and contractors may not disclose confidential information to unauthorized parties or use it for personal benefit. We handle personal data in accordance with applicable privacy laws and our privacy policy.
Fair dealing
We compete fairly and honestly. No employee or contractor may take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or any other unfair dealing practice.
Reporting violations
Anyone who becomes aware of a violation or suspected violation of this code of conduct, the FCPA, or any other applicable law must report it promptly to company leadership. Reports may be made without fear of retaliation. The company prohibits retaliation against anyone who reports a concern in good faith.
Consequences of violations
Violations of this code of conduct may result in disciplinary action, up to and including termination of employment or contract. Violations of the FCPA and other anti-corruption laws can also result in significant civil and criminal penalties for individuals and the company.
Training and awareness
All employees and contractors are required to review this code of conduct and complete anti-corruption compliance training. Training covers the requirements of the FCPA, recognizing red flags for corrupt activity, and the procedures for reporting concerns.