SimulTrans and its employees must, at all times, comply with all applicable laws and regulations.  SimulTrans will not condone the activities of employees who achieve results through violation of the law or unethical business dealings.  This includes any payments for illegal acts, indirect contributions, rebates, and bribery.  SimulTrans does not permit any activity that fails to stand the closest possible public scrutiny.   

All business conduct should be well above the minimum standards required by law.  Accordingly, employees must ensure that their actions cannot be interpreted as being, in any way, in contravention of the laws and regulations governing SimulTrans' operations. 

Employees uncertain about the application or interpretation of any legal requirements should refer the matter to their supervisor, who, if necessary, should seek appropriate legal advice. 

General Employee Conduct

SimulTrans expects its employees to conduct themselves in a businesslike manner.  Fighting, swearing, and similar unprofessional activities are prohibited while on the job.

Employees must not engage in sexual harassment, or conduct themselves in a way that could be construed as such, for example, by using inappropriate language, keeping or posting inappropriate materials in their work areas, or accessing inappropriate materials on their computers. 

Conflicts of Interest

SimulTrans expects that employees will perform their duties conscientiously, honestly, and in accordance with the best interests of SimulTrans.  Employees must not use their positions or the knowledge gained as a result of their positions for private or personal advantage.  Regardless of the circumstances, if employees sense that a course of action they have pursued, or are presently pursuing, or are contemplating pursuing may involve them in conflicts of interest with their employer, they should immediately communicate all the facts to their supervisors.

Outside Activities, Employment, and Directorships:  All employees share a serious responsibility for SimulTrans’ good public relations, especially at the community level.  Their readiness to help with religious, charitable, educational, and civic activities brings credit to SimulTrans and is encouraged.  Employees must, however, avoid acquiring any business interest or participating in any other activity outside SimulTrans that would, or would appear to: 

  • Create an excessive demand upon their time and attention, thus depriving SimulTrans of their best efforts on the job.
  • Create a conflict of interest - an obligation, interest, or distraction - that may interfere with the independent exercise of judgment in SimulTrans’ best interest.

Relationships With Clients and Suppliers

Employees should avoid investing in or acquiring a financial interest for their own accounts in any business organization that has a contractual relationship with SimulTrans, or that provides goods or services, or both, to SimulTrans if such investment or interest could influence or create the impression of influencing their decisions in the performance of their duties on behalf of SimulTrans.  

Gifts, Entertainment, and Favors

Employees must not accept entertainment, gifts, or personal favors that could, in any way, influence, or appear to influence, business decisions in favor of any person or organization with whom or with which SimulTrans has, or is likely to have, business dealings.  Similarly, employees must not accept any other preferential treatment under these circumstances because their positions with SimulTrans might be inclined to, or be perceived to, place them under obligation to return the preferential treatment. 

Kickbacks and Secret Commission

Regarding SimulTrans’ business activities, employees may not receive payment or compensation of any kind, except as authorized under SimulTrans’ business and payroll policies.  In particular, SimulTrans strictly prohibits the acceptance of kickbacks and secret commissions from suppliers or others.  Any breach of this rule will result in immediate termination and prosecution to the fullest extent of the law.

Organization Funds and Other Assets

Employees who have access to Organization funds in any form must follow the prescribed procedures for recording, handling, and protecting money as detailed in SimulTrans’s policies and procedures or other explanatory materials, or both.  SimulTrans imposes strict standards to prevent fraud and dishonesty.  If employees become aware of any evidence of fraud and dishonesty, they should immediately advise their supervisor or seek appropriate legal guidance so that SimulTrans can promptly investigate further.

When an employee’s position requires spending Organization funds or incurring any reimbursable personal expenses, that individual must use good judgment on SimulTrans’ behalf to ensure that good value is received for every expenditure. 

Organization funds and all other assets of SimulTrans are purposed for SimulTrans only and not for personal benefit.  Organizational assets, such as computers, may be used for personal purposes so long as that use does not interfere with use for SimulTrans purposes, degrade the value of the asset, or create additional work for other SimulTrans staff members.

Organization Records and Communications

Accurate and reliable records of many kinds are necessary to meet SimulTrans’ legal and financial obligations and to manage the affairs of SimulTrans.  SimulTrans’s books and records must reflect in an accurate and timely manner all business transactions.  The employees responsible for accounting and recordkeeping must fully disclose and record all assets and liabilities and must exercise diligence in enforcing these requirements. 

Employees must not make or engage in any false record or communication of any kind, whether internal or external, including but not limited to: 

  • False expense, attendance, production, financial, or similar reports and statements
  • False advertising, deceptive marketing practices, or other misleading representations 

Dealing With Outside People and Organizations

Employees must take care to separate their personal roles from their SimulTrans positions when communicating on matters not involving SimulTrans business. Employees must not use organization identification, stationery, supplies, and equipment for personal or political matters. 

When communicating publicly on matters that involve SimulTrans business, employees must not presume to speak for SimulTrans on any topic, unless they are certain that the views they express are those of SimulTrans, and it is SimulTrans’ desire that such views be publicly disseminated. 

When dealing with anyone outside SimulTrans, including public officials, employees must take care not to compromise the integrity or damage the reputation of either SimulTrans, or any outside individual, business, or government body. 

Prompt Communications

In all matters relevant to customers, suppliers, government authorities, the public and others in SimulTrans, all employees must make every effort to achieve complete, accurate, and timely communications - responding promptly and courteously to all proper requests for information and to all complaints.  

Privacy and Confidentiality

When handling financial and personal information about customers or others with whom SimulTrans has dealings, observe the following principles: 

  • Collect, use, and retain only the personal information necessary for SimulTrans’s business.
  • Whenever possible, obtain any relevant information directly from the person concerned. Use only reputable and reliable sources to supplement this information.
  • Retain information only for as long as necessary or as required by law. Protect the physical security of this information.
  • Limit internal access to personal information to those with a legitimate business reason for seeking that information.  Use only personal information for the purposes for which it was originally obtained.  Obtain the consent of the person concerned before externally disclosing any personal information, unless legal process or contractual obligation provides otherwise.