Code of Ethics and Standards of Conduct
IGI's fundamental ethical principles are:
Each of us is responsible for the propriety and consequences of our actions.
Each of us must conduct all aspects of IGI business in an ethical and legal manner, and obey the laws observed in all locations in which IGI does business or seeks to do business.
Our conduct on behalf of IGI with customers, suppliers, the public, and one another, must reflect our high standards of honesty, integrity and fairness.
Adherence by each of us to this Code and to the Standards of Conduct set forth on the following pages is essential to the continued vitality of IGI. Compliance with, and effective enforcement of the Code and Standards is one of your key responsibilities and will be addressed as an element in the regular evaluation of each employee.
Failure to comply with the Code or Standards will result in appropriate disciplinary action, which may include termination of employment, reimbursement to IGI for any resulting losses or damages, and possible civil or criminal prosecution. Principles of fairness will apply, and you will be provided an opportunity to explain your actions. The IGI Board of Directors must approve any waiver of any employee’s compliance with the Code of Ethics or Standards of Conduct, and such waiver shall be promptly disclosed to IGI stockholders.
Standards of Conduct
Conflict of Interest
You must be careful to avoid situations that may involve a conflict of interest or appear questionable to others. In general, there are two major areas of concern:
Participating in activities that conflict or appear to conflict with IGI responsibilities, and
Giving or receiving anything that may influence the recipient or cause another person to believe that the recipient may be influenced–this includes offering or accepting bribes, kickbacks, illegal payments, or gratuities.
You must avoid any actions that may appear to involve a conflict of interest with IGI activities. These include any business, financial or other relationships with suppliers, customers or competitors by you, your immediate family or your associates outside of IGI. Questionable activities include serving on the Board of Directors of a competing or supplier company, significant ownership in a competing or supplier company, or consulting with or working for a competing or supplier company, each without the written approval of IGI management.
IGI employees must observe the following IGI ethical standards, as well as applicable laws and regulations, when providing or accepting meals, entertainment or gifts to or from people in business situations.
Commercial Business—It is permissible for IGI or IGI employees to pay for meals, refreshments, and other ordinary or necessary expenses relating to company business with commercial entities. However, employees should use good judgment, observe all civil and criminal laws, and follow guidelines that apply to recipients.
Government Business–In certain countries, rules of conduct with respect to government officials are extremely strict and well defined in law, government regulations and IGI policy. It is the responsibility of IGI employees to seek out these rules of conduct, understand their application in the specific business setting and comply with them.
In many countries, including the United States, IGI and IGI employees must not provide meals, entertainment, gifts or anything else valued above a statutory dollar threshold (in the United States, federal officials may not receive items valued above $25 per occasion) to government employees; nor may any IGI employee or representative discuss employment opportunities with government employees without the prior approval of the Office of IGI's General Counsel. In all countries, IGI employees must not make any attempt to influence any government employee or member of a governmental body with regard to the award of a government contract for which a specific solicitation has been issued, other than through the standard preparation, submission, and discussion of IGI cost and technical proposals in conformance with procurement regulations.
Other Business—IGI employees with direct procurement-related responsibilities, regardless of the business sector in which they work, must not accept any meals, transportation, refreshments, entertainment, gifts (other than token marketing items) or anything else of value from suppliers or their personnel or representatives. Other IGI employees may accept modest meals, transportation, refreshments, entertainment or gifts but must not accept anything that might be considered excessive or intended to influence the employee.
Business Opportunities
You must not:
Take advantage of any opportunity for personal gain that is discovered through the use of IGI property, information or position; or
Compete with IGI
Protection of IGI and Customer Property
You have an obligation to protect all IGI and customer data, property and funds under your control against loss, theft, unsanctioned access and misuse. This includes the proprietary information belonging to IGI and/or its customers. You must keep this information confidential and not make any of it available to unauthorized personnel.
Security procedures have been established to protect government classified information and many types of unclassified technical information. By law, IGI employees who handle such data are required to know these procedures and strictly adhere to them at all times.
You must use IGI and customer funds, property and data only for their proper and intended purposes. No use of such property or data may be made after termination of your employment with IGI. It is also imperative that you make every effort to prevent the misuse of these assets by any other person, whether within or outside the company. Improper use includes selling, loaning or giving away IGI or customer property and/or modifying, destroying or disclosing customer or IGI data. Use of customer or company property for personal or non-business purposes, other than as specifically permitted under IGI's Policy on Electronic Communication Media, is considered to be improper conduct and is in violation of this Code of Ethics and Standards of Conduct.
Neither you nor any IGI representative may solicit, obtain or utilize Source Selection information relating to a government procurement. Similarly, neither you nor any IGI representative may solicit, receive, or utilize any other company's proprietary material other than as formally authorized by that company.
Providing a Proper and Professional Work Environment
You must use fairness, honesty, and comply with the law in all business relationships with IGI stockholders, customers, suppliers, teammates, partners, end users, consultants, employees, and applicants, as well as with local, state, national and international communities and governments.
You must not take unfair advantage of anyone, within or outside the company, through manipulation, concealment, and abuse of privileged information, misrepresentation of material facts or any other unfair dealing practice.
IGI employees must observe open, fair and equitable Human Resources management practices, including but not limited to those regarding recruitment, selection, job assignment, transfer, promotion/demotion, layoff, return from layoff, discipline including termination), training and education, tuition reimbursement, social and recreational programs, compensation and benefits.
Supervisors and managers must understand and abide by the laws and regulations that limit the work that can be done by former government civilian employees and military personnel now working at IGI. Former government employees or members of the armed forces must also be aware of and adhere to these laws and regulations.
You must neither engage in nor permit harassment of IGI employees for any reason by other employees, vendors, clients or anyone else with whom IGI employees come into contact during the course of their IGI business activities.
IGI employees are prohibited from possessing, using, distributing, manufacturing, purchasing, dispensing or selling controlled substances. Because these actions are counterproductive to our business interests and may be illegal, they will not be tolerated on IGI premises either during scheduled work periods or at any time while conducting company business. Alcohol abuse by IGI employees is an equally serious problem and will not be tolerated by the company, either on IGI premises during their scheduled work period or at any time while conducting Company business.
Application Accuracy and Full Disclosure
Misrepresentation or falsification of information pertaining to your previous employment, educational background, criminal record or financial history are grounds for actions up to and including termination of employment.
Communicating With IGI
The IGI policies and government rules and regulations referred to in these Standards are available through local management and are further detailed in this Employee Manual. If you are unsuccessful in getting the information needed from local sources, you should contact the Human Resources department.
If IGI management has reason to believe that a violation of this Code of Ethics and Standards of Conduct, or any other company policy, has occurred or is likely to occur, it is their obligation to contact a representative of the IGI Board of Directors.