SFC Code of Ethics and Business Conduct

Statement of Our Core Values

Company Vision

Sierra Forestry Consulting LLC (SFC) creates solutions in our industry, opportunities for our employees, and customer satisfaction and safety within our communities.

Values

Sierra Forestry Consulting LLC (SFC) was built through perseverance, accountability, and integrity, with safety being our utmost priority. We empower our leaders to use their critical thinking and problem-solving abilities. We are open to questions, criticism and all other feedback from all employees, partners, and clients. These values continue to guide and define the members of our team as we continue to grow and change. Our team is expected to embrace the same values that built SFC and to provide our customers and clients with a professional, well informed, and positive interaction.

Mission

We at Sierra Forestry Consulting LLC (SFC) believe in empowerment through employment. We never compromise safety for production. We have a passion for our jobs and the company. We expect 110% integrity and effort of ourselves at all times. We strive to be “The Solution,” collectively working to bridge the gaps on any challenge. SFC was built on this mindset, and that is what distinguishes us from others. Our work should always speak for itself.

Build Trust and Credibility

The success of our business is dependent on the trust and confidence we earn from our employees, customers, and stakeholders. We gain credibility by adhering to our commitments, displaying honesty and integrity, and reaching company goals solely through honorable conduct. It is easy to say what we must do, but the proof is in our actions. Ultimately, we will be judged on what we do.

When considering any action, it is wise to ask; will this build trust and credibility for SFC Will it help create a working environment in which SFC can succeed over the long term? Is the commitment I am making one I can follow through with?

The only way we will maximize trust and credibility is by answering “yes” to those questions and by working every day to build our trust and credibility.

Respect for the Individual

We all deserve to work in an environment where we are treated with dignity and respect. We are committed to creating such an environment because it brings out the full potential in each of us, which, in turn, contributes directly to our business success. We cannot afford to let anyone’s talents go to waste.

SFC is an equal employment/affirmative action employer and is committed to providing a workplace that is free of discrimination of all types from abusive, offensive, or harassing behavior. Any employee who feels harassed or discriminated against should report the incident to their supervisor or to the Human Resources Manager.

Employees are expected to support an inclusive workplace by adhering to the following conduct standards:

·         Always treat others with dignity and respect.

·         Address and report inappropriate behavior and comments that are discriminatory, harassing, abusive, offensive, or unwelcome.

·         Foster teamwork and employee participation, encouraging the representation of different employee perspectives.

·         Seek out insights from employees with different experiences, perspectives, and backgrounds.

·         Avoid slang or idioms that might not translate across cultures.

·         Support flexible work arrangements for co-workers with different needs, abilities and/or obligations.

·         Be open-minded and listen when given constructive feedback regarding others’ perception of your conduct.

SFC will not tolerate discrimination, harassment or any behavior or language that is abusive, offensive, or unwelcome.

Culture of Open and Honest Communication

At SFC everyone should feel comfortable to speak their mind, particularly with respect to ethics concerns. Supervisors have a responsibility to create an open and supportive environment where employees feel comfortable raising such questions. We all benefit tremendously when employees exercise their power to prevent mistakes or wrongdoing by asking the right questions at the right times.

We will investigate all reported instances of questionable or unethical behavior. In every instance where improper behavior is found to have occurred, the company will take appropriate action. We will not tolerate retaliation against employees who raise genuine ethics concerns in good faith.

SFC’s whistleblower policy is as follows:

Employees are encouraged, to address issues with their supervisor or the Human Resources Manager, as most problems can be resolved swiftly. If for any reason the employee feels uncomfortable in bringing the issue to their supervisor, they should reach out directly to the Human Resources Manager without fear of any retaliation. The Chief Executive Officer and Chief Operations Officer operate with an open-door policy, at any time should an employee feel their concern has not been taken seriously they should escalate the matter to the CEO and the COO.

Set Tone at the Top

Management has the added responsibility for demonstrating, through their actions, the importance of this Code. In any business, ethical behavior does not simply happen; it is the product of clear and direct communication of behavioral expectations, modeled from the top and demonstrated by example. Again, ultimately, our actions are what matters.

To make our Code work, supervisors must be responsible for promptly addressing ethical questions or concerns raised by employees and for taking the appropriate steps to deal with such issues. Supervisors should not consider employees’ ethics concerns as threats or challenges to their authority, but rather as another encouraged form of business communication. We want the ethics dialogue to become a natural part of daily work.

Uphold the Law

Our commitment to integrity begins with complying with laws, rules, and regulations where we do business. Further, each of us must understand the company policies, laws, rules, and regulations that apply to our specific roles. If we are unsure of whether a contemplated action is permitted by law or policy, we should seek the advice from the resource expert. We are responsible for preventing violations of law and for speaking up if we see possible violations.

Competition

We are dedicated to ethical, fair, and vigorous competition. We will conduct ourselves with the utmost professional demeanor providing services based on their merit, superior quality, functionality, and competitive pricing. We will make independent pricing and marketing decisions and will not improperly cooperate or coordinate our activities with our competitors. We will not offer or solicit improper payments or gratuities in connection with the purchase of SFC services, nor will we engage or assist in unlawful boycotts of customers.

Proprietary Information

It is important that we respect the property rights of others. We will not acquire or seek to acquire improper means of a competitor’s trade secrets or other proprietary or confidential information. We will not engage in unauthorized use, copying, distribution or alteration of software or other intellectual property.

Selective Disclosure

We will not selectively disclose (whether in one-on-one or small discussions, meetings, presentations, proposals or otherwise) any material nonpublic information with respect to SFC, its securities, business operations, plans, financial condition, results of operations or any development plan. We should be particularly vigilant when making presentations or proposals to customers to ensure that our presentations do not contain material nonpublic information.

Health and Safety

SFC is dedicated to maintaining a healthy environment. A safety manual has been designed to educate you on safety in the workplace. If you do not have a copy of this manual, please see the Human Resources Manager.

Avoid Conflicts of Interest

Conflicts of Interest

We must avoid any relationship or activity that might impair, or even appear to impair, our ability to make objective and fair decisions when performing our jobs. At times, we may be faced with situations where the business actions we take on behalf of SFC may conflict with our own personal or family interests. We owe a duty to SFC to advance its legitimate interests when the opportunity to do so arises. We must never use SFC property or information for personal gain or personally take for ourselves any opportunity that is discovered through our position with SFC.

Here are some other ways in which conflicts of interest could arise:

1.  Being employed (you or a close family member) by, or acting as a consultant to, a competitor or potential competitor, supplier, or contractor, regardless of the nature of the employment, while you are employed by SFC.

2.  Hiring or supervising family members or closely related persons.

3.  Owning or having a substantial interest in a competitor, supplier, or contractor.

4.  Having a personal interest, financial interest, or potential gain in any SFC transaction.

5.  Placing company business with a firm owned or controlled by a SFC employee or their family.

6.  Accepting gifts, discounts, favors, or services from a customer/potential customer, competitor, or supplier, unless equally available to all SFC employees.

Determining whether a conflict of interest exists is not always easy to do. Employees with a conflict-of-interest question should seek advice from management. Before engaging in any activity, transaction or relationship that might give rise to a conflict of interest, employees must seek review from their supervisor or the Human Resources Manager.

Gifts, Gratuities and Business Courtesies

We are committed to competing solely on the merit of our products and services. We should avoid any actions that create a perception that favorable treatment of outside entities by SFC was sought, received, or given in exchange for personal business courtesies. Business courtesies include gifts, gratuities, meals, refreshments, entertainment or other benefits from persons or companies with whom SFC does or may do business. We will neither give nor accept business courtesies that constitute, or could reasonably be perceived as constituting, unfair business inducements that would violate law, regulation or polices of SFC or customers or would cause embarrassment or reflect negatively on SFC’s reputation.

Accepting Business Courtesies

Most business courtesies offered to us in the course of our employment are offered because of our positions at SFC. We should not feel any entitlement to accept and keep a business courtesy. Although we may not use our position at SFC to obtain business courtesies, and we must never ask for them, we may accept unsolicited business courtesies that promote successful working relationships and good will with the firms that SFC maintains or may establish a business relationship with.

Employees who award contracts or who can influence the allocation of business, who create specifications that result in the placement of business or who participate in negotiation of contracts must be particularly careful to avoid actions that create the appearance of favoritism or that may adversely affect the company’s reputation for impartiality and fair dealing. The prudent course is to refuse a courtesy from a supplier when SFC engages in choosing or reconfirming a supplier or under circumstances that would create an impression that offering courtesies is the way to obtain SFC business.

Meals, Refreshments and Entertainment

We may accept occasional meals, refreshments, entertainment, and similar business courtesies that are shared with the person who has offered to pay for the meal or entertainment, provided that:

•  They are not inappropriately lavish or excessive.

•  The courtesies are not frequent and do not reflect a pattern of frequent acceptance of courtesies from the same person or entity.

•  The courtesy does not create the appearance of an attempt to influence business decisions, such as accepting courtesies or entertainment from a supplier whose contract is expiring in the near future.

•  The employee accepting the business courtesy would not feel uncomfortable discussing the courtesy with their supervisor or co-worker or having the courtesies known by the public.

Gifts

Employees may accept unsolicited gifts, other than money, which conform to the reasonable ethical practices of the marketplace, including:

•  Flowers, fruit baskets and other modest presents that commemorate a special occasion.

•  Gifts of nominal value, such as calendars, pens, mugs, caps, and t-shirts (or other novelty, advertising, or promotional items).

Generally, employees may not accept compensation, honoraria, or money of any amount from entities with whom SFC does or may do business. Tangible gifts (including tickets to a sporting or entertainment event) that have a market value greater than $100 may not be accepted unless approval is obtained from management.

Employees with questions about accepting business courtesies should talk to their supervisor or the HR Manager.

Offering Business Courtesies

Any employee who offers a business courtesy must assure that it cannot reasonably be interpreted as an attempt to gain an unfair business advantage or otherwise reflect negatively upon SFC. An employee may never use personal funds or resources to do something that cannot be done with SFC resources. Accounting for business courtesies must be done in accordance with approved company procedures.

Other than to our government customers, for whom special rules apply, we may provide nonmonetary gifts (i.e., company logo apparel or similar promotional items) to our customers. Further, management may approve other courtesies, including meals, refreshments, or entertainment of reasonable value, provided that:

•  The practice does not violate any law or regulation or the standards of conduct of the recipient’s organization.

•  The business courtesy is consistent with industry practice, is infrequent in nature and is not lavish.

•  The business courtesy is accurately reflected on the books and records of SFC.

Set Metrics and Report Results Accurately

Corporate Recordkeeping

We create, retain, and dispose of our company records as part of our normal course of business in compliance with all SFC policies and guidelines, as well as all regulatory and legal requirements.

All corporate records must be true, accurate and complete, and company data must be promptly and accurately entered in our books in accordance with SFC’s and other applicable accounting principles.

We must not improperly influence, manipulate, or mislead any unauthorized audit, nor interfere with any auditor engaged to perform an internal independent audit of SFC books, records, processes, or internal controls.

Promote Substance Over Form

At times, we are all faced with decisions we would rather not have to make and issues we would prefer to avoid. Sometimes, we hope that if we avoid confronting a problem, it will simply go away.

At SFC, we must have the courage to tackle the tough decisions and make difficult choices, secure in the knowledge that SFC is committed to doing the right thing. At times this will mean doing more than simply what the law requires. Merely because we can pursue a course of action does not mean we should do so.

Although SFC’s guiding principles cannot address every issue or provide answers to every dilemma, they can define the spirit in which we intend to do business and should guide us in our daily conduct.

Accountability

Each of us is responsible for knowing and adhering to the values and standards set forth in this Code and for raising questions if we are uncertain about company policy. If we are concerned whether the standards are being met or are aware of violations of the Code, we must contact the Human Resources Manager.

SFC takes seriously the standards set forth in the Code, and violations are cause for disciplinary action up to and including termination of employment.

Be Loyal

Confidential and Proprietary Information

Integral to SFC’s business success is our protection of confidential company information, as well as nonpublic information entrusted to us by employees, customers, and other business partners.

Confidential and proprietary information includes such things as pricing and financial data, customer names/addresses or nonpublic information about other companies, including current or potential supplier and vendors. We will not disclose confidential and nonpublic information without a valid business purpose and proper authorization.

Use of Company Resources

Company resources, including time, material, equipment, and information, are provided for company business use. Nonetheless, occasional personal use is permissible if it does not affect job performance or cause a disruption to the workplace.

Employees and those who represent SFC are trusted to behave responsibly and use good judgment to conserve company resources. Supervisors are responsible for the resources assigned to their departments and are empowered to resolve issues concerning their proper use.

Generally, we will not use company equipment such as computers, copiers, and fax machines in the conduct of an outside business or in support of any religious, political, or other outside daily activity, except for company-requested support to nonprofit organizations. We will not solicit contributions nor distribute non-work-related materials during work hours.

To protect the interests of the SFC network and our fellow employees, SFC reserves the right to monitor or review all data and information contained on an employee’s company-issued computer or electronic device, the use of the Internet or SFC’s intranet. We will not tolerate the use of company resources to create, access, store, print, solicit or send any materials that are harassing, threatening, abusive, sexually explicit, or otherwise offensive or inappropriate.

Questions about the proper use of company resources should be directed to your supervisor.

Media Inquiries

SFC is a high-profile company in our community, and from time to time, employees may be approached by reporters and other members of the media. In order to ensure that we speak with one voice and provide accurate information about the company, we should direct all media inquiries to the Chief Executive Officer (CEO). Should the CEO be unavailable all media inquiries must be directed jointly to the Director of Administration and the Human Resources Manager. No one outside of the individuals named may issue a press release or statement to the press.

Do the Right Thing

Several key questions can help identify situations that may be unethical, inappropriate, or illegal. Ask yourself:

•  Am I acting with integrity?

•  Does what I am doing comply with the SFC guiding principles, Code of Conduct, and company policies?

•  Have I been asked to misrepresent information or deviate from normal procedure?

•  Would I feel comfortable describing my decision at a staff meeting?

•  How would it look if it made the headlines?

•  Am I being loyal to my family, my company and myself?

•  What would I tell my child, sibling, close friend to do?

•  Is this the right thing to do?

SFC Supplier Code of Conduct

At Sierra Forestry Consulting LLC, we set high standards for our business and individual behavior as detailed in our Code of Ethics & Business Conduct Policy. We count on our suppliers to operate the same. This Supplier Code of Conduct details our expectations.

Regardless of a supplier’s size or geographical location, it is now more evident than ever that we are all part of a global community and must be responsible for the impacts our businesses make in our communities and on the environment. By acting ethically when conducting business, acting as stewards of our environment, and interacting respectfully with our communities.

We expect our suppliers, service providers, and business partners along with their subsidiaries, affiliates, sub-contractors, and suppliers, to make these same commitments based on The Ten Principles of the UN Global Compact. At a minimum, suppliers must meet fundamental responsibilities as follows:

Human Rights

Principle 1: Businesses should support and respect the protection of internationally proclaimed human rights; and

Principle 2: make sure that they are not complicit in human rights abuses.

Labor

Principle 3: Businesses should uphold the freedom of association and the effective recognition of the right to collective bargaining.

Principle 4: the elimination of all forms of forced and compulsory labor.

Principle 5: the effective abolition of child labor; and

Principle 6: the elimination of discrimination in respect of employment and occupation.

Environment

Principle 7: Businesses should support a precautionary approach to environmental challenges.

Principle 8: undertake initiatives to promote greater environmental responsibility; and

Principle 9: encourage the development and diffusion of environmentally friendly technologies.

Anti-Corruption

Principle 10: Businesses should work against corruption in all its forms, including extortion and bribery.

The Security of Company and Personal Data Suppliers shall handle and process data on behalf of SFC only for the purposes for which it was collected, received or otherwise made available, in accordance with the directions provided by SFC, and subject to technical and organizational security measures necessary to safeguard it against loss, alteration, unauthorized disclosure, access or other unlawful forms of processing. Other Laws Suppliers will comply with all applicable local, national, and international laws, regulations, treaties, and industry standards, including, without limitation, those pertaining to export and trade controls and the manufacture, pricing, sale and distribution and safety of the relevant products and/or services. In the event that the requirements of this Code of Conduct are stricter than applicable local, national, or international law, Supplier will comply with this Code of Conduct. However, if there is any conflict between the requirements of this Code of Conduct and the requirements of any applicable local, national, or international law, The supplier is to comply with the local, national, or international law.