Third Parties' Code of Conduct
Lux Art Consulting
Our third party vendors, subcontractors, suppliers, joint venture partners, agents and advocates (Lux Art Consulting Third Party Partners) play a significant role in building and maintaining Lux’s world-class brand and reputation. We expect Lux Art Consulting (Lux) Third Party Partners to act in accordance with Lux’s principles set forth in this Lux Third Parties’ Code of Business Conduct (Code of Business Conduct). This Code of Business Conduct applies to all Lux Third Party Partners who have not adopted a mandatory code of ethics
or conduct generally consistent with this Code of Business Conduct. Lux Third Party Partners that have a generally consistent code of ethics or conduct commit, by entering into an agreement with Lux, that they will comply with their code while working with and representing Lux. Each Third Party Partner must confirm that all
employees assigned to work with or to represent Lux have reviewed this Code of Business Conduct or their generally consistent code of ethics or conduct and that they will provide any lower tier subcontractors and subconsultants with access to this code or their code and require their compliance with that document.
Lux expects our Lux Third Party Partners
to comply with the following principles:
We expect Lux Third Party Partners to be honest and truthful in their dealings with us as we will be with them. We also expect our partners to scrupulously avoid undue influences and to comply with the requirements associated with their professional licenses and registrations.
ACT WITH INTEGRITY
We expect Lux Third Party Partners to comply with all laws that apply to the work being performed, wherever that work is. Sometimes, more than one set of laws will apply to a given opportunity or project; in those instances, our partners are expected to comply with all applicable regulations from all jurisdictions and to ensure that any third parties with whom they are working do as well.
FOLLOW THE LAW AT ALL TIMES AND IN ALL PLACES
Lux Third Party Partners shall not:
Promise, offer, or pay bribes for any reason;
Use the confidential information of others to gain improper advantage;
Propose or enter into any agreement with any competitor to fix prices,
margins, or terms and conditions or to divide up any markets or customers; or
Make any false representations in connection with any Lux pursuit, proposal, or transaction including, but not limited to, misrepresentations of fact or the use of false or inaccurate records.
Lobby or retain lobbyists or agents to specifically advocate with government employees with respect to an Lux pursuit or project without the prior written permission of your Lux designated representative.
COMPETE FAIRLY AND HONESTLY
Lux Third Party Partners shall provide equal opportunity and fair treatment for all without regard to ancestry, race, color, sex, sexual orientation, genetic information, religion, national origin, age, creed, veteran status, citizenship status, marital status, public assistance disability status, Vietnam Era Veteran status, recently separated, special disabled and other protected veterans or any other status protected by law. Additionally,
our partners shall not retaliate against any individual who makes a good faith allegation of wrong doing. Discrimination, harassment and retaliation will not be tolerated. Lux Third Party Partners shall not use, either directly or indirectly, forced labor, unlawful child labor or labor from individuals who have been human trafficked.
EMBRACE DIVERSE BACKGROUNDS AND PERSPECTIVES AND TREAT PEOPLE WITH DIGNITY AND RESPECT
Lux Third Party Partners are accountable for making certain that their employees both understand the hazards to which their work may expose them and know how to prevent harm to themselves, to others and to their surroundings from such exposure. Lux Third Party Partners shall take all necessary measure to provide a safe working environment for their employees consistent with applicable law. Lux Third Party Partners are expected to take all reasonable precautions to protect the environment and to make choices that are resource sensitive.
PROTECT HEALTH, SAFETY AND THE ENVIRONMENT
Lux Third Party Partners must avoid any situation or relationship that may involve an inappropriate conflict or the appearance of a conflict with the interests of Lux or its other partners or clients. Lux Third Party Partners shall not offer or provide excessive gifts, hospitality or entertainment to any Lux employee or any family member of Lux employees or Lux’s other partners or clients. Any identified actual, potential, or apparent conflicts should be reported to Lux’s Conflict of Interest Manager at Admin@LuxArtConsulting.com.
AVOID CONFLICTS OF INTEREST
Lux Third Party Partners must use Lux’s and its clients’ confidential information, trade secrets, copyrights and other proprietary or personal information only in a manner that is permitted by law and under their contracts with Lux. Lux Third Party Partners must not misuse, misappropriate, or infringe upon the trade information, trademarks, or copyrighted works of others, and must not misuse trade secrets or proprietary or confidential information of other third parties working with Lux for their own purposes or disclose such information to unauthorized third parties. Lux Third Party Partners must notify Lux when they learn of or suspect any unauthorized use of Lux confidential information. Lux Third Party Partners must at all times protect
and minimize the use and disclosure of personal data.
PROTECT CONFIDENTIAL INFORMATION AND INTELLECTUAL PROPERTY
Lux Third Party Partners shall comply with all Government contracting rules applicable to the contract including any applicable timekeeping requirements, assigning fully qualified individuals to all projects, and only invoicing for expenses that are permitted and allowable under these contracts. Adherence to these requirements is subject to Lux and Government oversight and audit.
COMPLY WITH GOVERNMENT CONTRACTING RULES
Lux Third Party Partners shall keep all financial books and records related to Lux projects accurately, completely and in accordance with their internal policies. Adherence to these requirements is subject to oversight and audit by Lux and the ultimate client.
KEEP ACCURATE FINANCIAL BOOKS AND RECORDS
Lux Third Party Partners must strictly comply with all export and import restrictions applicable to Lux contract activities and with sanctions applicable to the contract activities and as required by applicable laws. Business partners also need to be mindful of restrictions on doing business with certain countries, companies and individuals.
COMPLY WITH TRADE REGULATIONS
Lux Third Party Partners must not offer, give, promise or authorize any bribe, gift, loan, fee, reward or other advantage to any government official or employee, any customer, any Lux employee or any other person to obtain any business advantage or improperly influence any action or decision. Lux business partners must comply with all applicable anti-corruption laws and regulations, including the U.S. Foreign Corrupt Practices Act and the UK Bribery Act.
DO NOT ACCEPT OR MAKE UNLAWFUL OR INAPPROPRIATE PAYMENTS OR GIFTS
Lux may audit compliance with this Code of Conduct or appoint a third party to conduct an audit. Any violations will be reported to the Lux Third Party Partner’s management for their attention and, if appropriate, corrective action. Lux Third Party Partners shall cooperate or cause the cooperation of their employees and any second-tier third parties with respect to any Lux investigations into a potential violation of this Code of Conduct. Noncompliance with this Code of Conduct will negatively impact Lux’s ability to conduct business with your firm in the future.
Lux Third Party Partners and their employees and other stakeholders may report suspected violations of this Code of Conduct to Lux’s Conflict of Interest Manager at Admin@LuxArtConsulting.com.
MONITORING AND COMPLIANCE
Please direct questions on this Code of Conduct or on ethical or compliance issues that arise to