Business Ethics and Compliance

SMX® promotes an organizational culture that encourages ethical conduct and a commitment to compliance with the law through its ongoing business ethics awareness and compliance program. This program includes reasonable steps to periodically communicate our standards and procedures by conducting effective training programs and otherwise disseminating appropriate information regarding employee roles and responsibilities. Our internal control system establishes standards and procedures to facilitate timely discovery of improper conduct in connection with Government contracts, and ensures corrective measures are promptly instituted and carried out. This includes the assignment of responsibility at the senior level to ensure effectiveness of the program and internal control system, the implementation of vetting of new principals, periodic reviews of company business practices, procedures, policies, and internal controls for monitoring and auditing to detect criminal conduct, periodic evaluation of the effectiveness of the program and internal control system, and periodic assessment of the risk of criminal conduct. SMX maintains an internal hotline for anonymous reporting that encourages employees to report suspected instances of improper conduct. Or program provides for disciplinary action for improper conduct or for failing to take reasonable steps to prevent or detect improper conduct.

SMX shall also ensure the timely written disclosure of any credible evidence that a principal, employee, agent, or subcontractor of the Contractor has committed a violation of Federal criminal law involving fraud, conflict of interest, bribery, or gratuity violations found in Title 18 U.S.C. or a violation of the civil False Claims Act (31 U.S.C. 3729-3733) in connection with the award, performance, or closeout of any Government contract for a period of at least 3 years following final payment on the contract. Such disclosure will be to the agency OIG and Contracting Officer. If the violation relates to an order against a Government-wide acquisition contract, a multi-agency contract, a multiple-award schedule contract such as the Federal Supply Schedule, or any other procurement instrument intended for use by multiple agencies, SMX shall notify the OIG of the ordering agency and the IG of the agency responsible for the basic contract, and the respective agencies’ contracting officers. SMX shall always fully cooperate with any Government agencies responsible for audits, investigations, or corrective actions.

SMX ensures that all subcontracts that have a value in excess of $5,000,000 and a performance period of more than 120 days include a requirement for the subcontractor to have a Business Ethics and Compliance program.

Export Compliance

As a leading U.S. exporter of controlled products and technologies to the U.S. Department of Defense, other national defense establishments, and various domestic and international customers, SMX is committed to conducting business in full compliance with all U.S. and other national laws and regulations to include the International Trade in Arms Regulations (ITAR), 22 CFR sections 120–130, and the Arms Export Control Act (AECA), Export Administration Regulations EAR, 15 CFR sections 730–774. In addition, SMX ensures that no product or information is provided to any prohibited country (including release of such technical information or software to nationals, wherever they may be located, of any prohibited country) as specified in applicable export, embargo, and sanctions regulations.

Human Trafficking

SMX, LLC fully complies with Federal Acquisition Regulation (FAR) 52.222-50, “Combating Trafficking in Persons”. SMX engages in the verification of product supply chains to evaluate and address risks of human trafficking and slavery, conducts audits of suppliers to evaluate supplier compliance with company standards for trafficking and slavery in supply chains, requires direct suppliers to certify that materials incorporated into the product comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business, and maintains internal accountability standards and procedures for employees failing to meet company standards regarding slavery and trafficking. SMX provides supply chain management training on human trafficking and slavery, and mitigating risks within the supply chains of products.

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