Policies

TDI-Brooks has created a Comprehensive Training Program with the goal of training, supporting and engaging our employees in a continual improvement process.

We act fairly and ethically wherever we conduct business, whether domestic or internationally. Our code of ethics and integrity capture our belief and intent in making the right decisions that impact our clients, our personnel, our suppliers, and the communities where we live and work. We have a core set of values to guide us every day, and we do the right thing, even when it’s difficult, not convenient, or not popular or observed by others.

An important part of our culture is recognizing that doing business with integrity is a shared responsibility. Every person engaged in our business efforts, whether as an employee, consultant, agent, contractor or in any other capacity, has a responsibility to act with the highest level of integrity and sound judgement regarding any form of corruption or bribery that would be in conflict with our core values.

We believe that what we do is important — and how we do it is even more so. We work hard to earn and maintain the respect of our partners, investors, and clients around the globe. As we strive to continually deliver strong business value, we want to ensure that we achieve those results in the proper and forward-looking way. We take a zero-tolerance approach to corruption in all its forms and do not accept corruption or bribery in our business or by those with whom we do business.

We prohibit soliciting, making, or accepting facilitation payments or “kickbacks” of any kind to government officials, foreign agencies, political parties, or party officials. We are committed to complying with all applicable laws in our operations, including, but not limited to, the U.S. Foreign Corrupt Practices Act (FCPA). The FCPA is a U.S. law that prohibits bribes to government officials (including political candidates and political parties) in order to influence their acts or decisions to our favor. The FCPA also prohibits payments to intermediaries or agents when the payments may be used to direct improper payments to foreign officials. “Kickbacks” and bribes do not involve only cash. They can also involve gifts, products, trips, or anything else of value. Many other countries around the world have similar laws that we must also strictly follow. The FCPA also prohibits payments to intermediaries or agents when the payments may be used to direct improper payments to foreign officials.

Further, we intend not to just act in accordance with those legal requirements, but to conduct all our industrial business in accordance with the honesty and integrity intended and reflected by our core values. We are expected to report any suspected illegal or unethical business activity. No employee, agent, contractor, vendor, or other affiliated party may directly or indirectly, offer, guarantee, pay, gift, grant or authorize any financial or other advantage to any other person or organization, with the intent to secure an improper advantage for us. Likewise, no employee, agent, contractor or vendor may accept payment or gifts from a third party if they know or suspect that it is offered or provided with an expectation that a business advantage will be provided in return.

Data Integrity: It is our policy to conduct all business with integrity and in an ethical manner. It is essential that every employee understand and adhere to these ethical standards in order to preserve the basis integrity of all work products. Data integrity concerns the ability to define and defend that the entire survey, data acquisition, and analytical process has been “unimpaired” and performed following appropriate practices and procedures. The ability to defend the integrity of the data is by complete documentation of actions and activities, which includes such items as: (1) maintaining chain of custody and security of the samples; (2) clear documentation of the activities performed in the preparation and analysis of the samples and in the final data reduction, review, and reporting; and (3) by maintaining complete and clear files of these records.

Violation of this Ethics, Integrity, and Anti-Corruption policy may result in disciplinary action up to and including termination. Disciplinary action may include, but is not limited to, formal reprimand, demotion, reassignment, or termination of employment, depending on the circumstances and gravity of the case.