Page 11 - E3 Employee Handbook

2.3.4 Confidentiality
Discovered or suspected matters of misconduct may be reported anonymously or on a confidential basis.
Anonymous allegations will be reviewed to the extent possible, given the opportunity to confirm such allegations
from other reliable sources. In the case of allegations made on a confidential basis, every effort will be made to
keep the identity of the reporting party secret during an internal review. E3 makes every effort to maintain
confidentiality to the greatest extent possible; however, disclosure may be necessary in some cases to conduct an
effective internal review and to pursue further action, as prudent and necessary.
Allegations will not be discussed with anyone other than those who have a legitimate need to know. It is
important to protect the rights of the persons accused, to avoid damaging their reputation should they be found
innocent, and to protect the organization from potential liability.

2.3.5 Internal Reviews and External Reporting Procedures
Internal reviews of actual, potential, or the appearance of misconduct will be conducted via the E3 Ethics and
Compliance Officer in concert with an executive team, as identified on a per internal review basis, as needed. All
reports will be treated seriously.

Required reporting to the requisite agency Office of Inspector General and Government Contracting Officer,
pursuant to Federal Acquisition Regulations Clause 52.203-13, Contractor Code of Business Ethics and Conduct, will
be conducted by E3’s Chief Operating Officer or Chief Executive Officer or their express designee. This will be done
on a case-by-case basis in a timely manner when E3 has “credible evidence that a principal, employee, agent, or
subcontractor has committed a violation of Federal criminal law involving fraud, conflict of interest, bribery, or
gratuity violations found in Title 18 of the United States Code or a violation of the civil False Claims Act.”

2.3.6 External Investigation Procedures
Should an E3 employee be contacted by Government auditors or investigators, the E3 employee must take two (2)
steps: 1) notify the E3 Ethics and Compliance Officer immediately through email reports@lighthouse-services.com
(must include company name with report) and by phone and 2) respond truthfully and accurately to Government
auditors or investigators. It is the policy of E3 to fully cooperate with Government auditors and investigators by
providing timely and complete responses to requests for documents, access to information, and interviews.

2.3.7 Annual Certification Process
All E3 employees must sign an annual certification that they understand and are in compliance with the
requirements of E3’s Code of Business Ethics and Conduct. All managers are responsible for ensuring that their
staff receive, read, and understand the Code, complete annual training, and sign the required annual certification.
Detailed information regarding the annual certification process is included in the instructions when the
certification materials are distributed to E3 staff.

2.3.8 Summary
E3’s Employee Handbook provides the foundation of the Company’s expectations and responsibilities of its
employees with regards to our standards of professionalism and workplace operations. The Company holds its
employees accountable to this Code of Business Ethics and Conduct.

2.3.9 Personal Conflict of Interest
You should not engage in any activity, practice, or conduct which conflicts with, or appears to conflict with, the
interests of E3, its customers and clients, or suppliers. As in all of your job duties, when you are dealing with
customers, suppliers, contractors, competitors, or any person doing or seeking to do business with E3, you are to
act in the best interests of E3 regardless of personal preference and must not create an actual, potential, or the
perception of personal advantage or bias.

An actual or potential conflict of interest occurs when you are in a position to influence a decision that may result in
a personal gain for you or for a relative as a result of E3’s business dealings. For the purposes of this policy, a relative
is any person who is a close family member or who is an individual living in your household.

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.