Page 10 - E3 Employee Handbook

discriminatory harassment, and trafficking in persons. To ensure the safety of our employees, texting while driving
1
is strongly discouraged.
The Code reaffirms the ethical standards which have long governed our Company's professional practice, and
which are an extension of E3’s core values. Each and every employee has an obligation to be familiar with the Code
and to immediately clarify with an appropriate authority any questions or concerns with regards to proper
business conduct to prevent and/or mitigate any misconduct.
Any E3 employee who becomes aware of any existing or potential violation of this Code is required to notify the E3
Ethics and Compliance Officer, who is also the E3 Human Resources Director, or requisite E3 Manager. Failure to
do so is itself a violation of this Code. As a standard business practice, retaliation for reporting will not be
permitted or tolerated in accordance with our Harassment-Free Workplace Policy, which provides for
whistleblower protection, as included in the E3 Employee Handbook.
It is the Company's policy to comply with all applicable federal and state laws, rules, and regulations. It is the
personal responsibility of each employee to adhere to standards and restrictions imposed by those laws, rules, and
regulations. The Company’s policies and procedures, as provided in Section 2, Standards and Expectations for the
Workplace, and Section 3, Employment and Operational Policies, of the Employee Handbook, as well as E3s
Timekeeping Policy and Travel Policy are incorporated in full by reference in this Code of Business Ethics and
Conduct.

2.3.2 Specific Areas of Compliance
Through E3’s new employee and annual training as well as Section 2 of the Employee Handbook, the Company has
defined conflicts of interest, gifts and gratuities, procurement integrity, and fraud. Additionally, E3’s Timekeeping
Policy has identified the timekeeping process and procedure and the Travel Policy has identified the travel process
and procedure. While the Code is not limited to the areas identified in this section, the aforementioned areas are
specifically identified due to their seriousness and the potential impact of any violation on any E3 employee up to
and including civil and criminal penalties and fines and/or imprisonment.

2.3.3 Reporting Responsibilities and Whistleblower Protection
It is the responsibility of every E3 employee to report, orally or in writing, actual, potential, or any appearance of
unethical or illegal activity immediately to the E3 Ethics and Compliance Officer or requisite E3 Manager.
Reporting to the E3 Ethics and Compliance Officer may be accomplished through our E3 Ethics and Compliance
Hotline at the following:
 Toll-Free Telephone:
o English speaking USA and Canada: 844-380-0005

 Website: www.lighthouse-services.com/e3federal

 E-mail: reports@lighthouse-services.com (must include company name with report)

No reporting party, who in good faith makes a report, will suffer harassment, retaliation, or other adverse
consequences. As provided in the Section 3.4, Harassment-Free Workplace Policy of the Employee Handbook, “It
is the policy of E3 that any harassment, including acts creating a hostile work environment or any other
discriminatory acts directed against our employees shall be subject to immediate disciplinary action, up to and
including termination of employment.” E3 expects its leaders to support employees who raise questions or
concerns or report misconduct. Additionally, no employee, service provider, or subcontractor will be adversely
affected because they refuse to carry out a directive which constitutes fraud or a violation of federal or state law.
Any allegation that proves to have been made maliciously or knowingly to be false will be viewed as a serious
disciplinary offense.

1 Source: Federal Acquisition Regulations Clauses 52.203-3, Gratuities; 52.203-7, Anti-Kickback Procedures; 52.203-
16, Preventing Personal Conflicts of Interest; 52.222-50, Trafficking in Persons; 52.223-18, Encouraging Contractor
Policies to Ban Text Messaging While Driving

Information in this document is proprietary to E3 and should not be discussed with third parties without consent.
Printed copies are uncontrolled and for reference only.