Code of Business Ethics

As a Janus employee, I will always uphold the Janus Way. I will:

  • Follow the laws, rules and regulations in the cities, states and countries in which Janus Global operates.
  • Act at all times with honesty and integrity, avoiding any real or perceived conflict of interest between my personal interests and my ethical and professional responsibilities.
  • Avoid even the appearance of impropriety.

Further, I will:

  • When in doubt about any issue or course of action, immediately seek guidance.
  • Work to ensure a safe, secure, and respectful workplace.
  • Never discriminate on the basis of race, color, sex, national origin, age, religion or disability.
  • Be vigilant to protect against Human Rights abuses, Harassment, and Workplace Violence.
  • Avoid inappropriate non-business relationships with government officials.
  • Not own any interests in any Janus supplier, customer or competitor.
  • Not engage in outside employment that might affect Janus business interests.
  • Exercise moderation and sound judgment when making gifts to customers.
  • When dealing with U.S. or foreign government officials strictly adhere to the Janus Code.
  • In any business dealings, never offer nor receive any gift (“kickback”) designed to influence or reward favorable treatment.
  • Not solicit nor receive a competitor’s proprietary information or source selection information during the course of a procurement.
  • Not engage in the recruitment or any steps of hiring government officials without the approval of the General Counsel.
  • Never use Janus property or assets for personal use unless authorization is obtained in advance.
  • Always safeguard, and refrain from personal use, the Company’s business sensitive information and intellectual property.
  • Protect Government property and documents in your charge.
  • Not engage in anti-competitive practices, and if involved in industry associations, be sensitive to anti-trust situations.
  • Do everything practical to ensure compliance with Janus contract requirements.
  • Accurately record and charge my time to the proper account and never falsify and Company record.
  • Not be guilty of nor tolerate the use of illegal drugs or the use of alcohol at Company offices and worksites.
  • Report all violations of Janus Code of Business Ethics and Conduct in accordance with the many options it provides.

November 2016

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