IMSG’s business depends upon our reputation for integrity, trust, and confidence and our commitment to the highest ethical standards and values in the way we conduct our business. IMSG is also equally committed to complying with all applicable laws and regulations, both domestic and foreign, in jurisdictions where we operate. Therefore, it is the personal responsibility of each IMSG employee to read, understand, and comply with our IMSG standards of ethics and business conduct and to diligently comply with appropriate regulatory guidance. Employees must promptly direct any questions regarding specific policies to their immediate Program Manager or other management official.
All IMSG employees will be required to certify their understanding of our IMSG standards of ethics and business conduct on an annual basis. Failure to certify understanding of or failure to comply with this business standard shall be grounds for disciplinary action, up to and including termination of employment.
IMSG’s purpose is to ensure there are no instances of corrupt payments to foreign officials for the purpose of obtaining or keeping business. IMSG policy ensures that all concerned personnel are aware of, and acknowledge, their responsibilities regarding the Foreign Corrupt Practices Act (FCPA). As such, IMSG has published an FCPA Compliance Plan that outlines the specific procedures that company personnel must follow and details the responsibilities of all concerned employees.
Employees, or any relevant third party, detecting potential acts of non-compliance with the FCPA are required to report these potential violations to the Compliance Officer, or alternate, as soon as possible.