Business Partner Code
of Conduct

Safeguard and Support Human Rights

We require our Business Partners to share our commitment to uphold the human rights of all team members.

This means we expect our Business Partners to:

• ensure all employment is freely chosen and prohibit all forms of modern slavery and human trafficking;
• prohibit the use of child labor or labor by anyone under the minimum legal age for employment where the work is performed;
• comply with all applicable laws in the countries in which they operate, including those related to wages, benefits and working hours;
• respect the right of team members to form and join trade unions of their own choosing, to bargain collectively and to engage in peaceful assembly, as well as respect the right of team members to refrain from such activities; and
• refrain from violating the human rights of others.

Our commitment to prohibit modern slavery and human trafficking means Business Partners must never:

• destroy, conceal, or confiscate identity or immigration documents (e.g., passports, visas, drivers' licenses, etc.);
• use recruiters that do not comply with local labor laws of the country in which the recruiting takes place;
• use misleading or fraudulent tactics in recruiting;
• charge team member recruitment (or similar) fees or provide inadequate housing based on local standards, laws and directives;
• fail to provide employment contracts and other documentation in the team member's native language;
• fail to provide return transportation upon the end of employment for team members brought to the country for the purpose of working; or
• fail to investigate and protect team members suspected of being trafficking victims.

Operate with Integrity and Respect

Our Business Partners should operate with respect and dignity, encourage diversity, promote equal opportunity for all, and foster an inclusive and ethical culture.

This means we expect our Business Partners to:

• value the differences that make people unique;
• be inclusive, support others and remain open and receptive to different ideas and opinions;
• provide a work environment that is free from discrimination and all forms of harassment or other abusive conduct; and
• provide equal employment opportunities to team members and applicants, without regard to race, ethnicity, religion, color, sex, national origin, age, military veteran status, sexual orientation, gender identity, marital status, or mental or physical disability, so long as the essential functions of the job can be competently performed with or without reasonable accommodation.

Maintain a Safe and Healthy Workplace

Business Partners should protect the health, safety, and welfare of their team members, visitors, and others who may be affected by their activities.

This means we expect our Business Partners to:

• maintain safe, healthy, and humane working conditions at all locations, including provision of personal protective equipment;
• provide training and information to team members, employees and staff as to the hazards present on the job site and ways team members can protect and safeguard themselves;
• comply with all applicable environmental, health and safety laws, regulations, and directives;
• comply with flow-down/contractual requirements, document and provide documentation of health and safety performance and regulatory performance actions when asked; and
• maintain a workplace free from the illegal use, possession, sale, or distribution of controlled substances.

Prohibit Bribery and Corruption

Our Business Partners must comply with the U.S. Foreign Corrupt Practices Act and other applicable anti-corruption laws, directives and/or regulations that govern operations in the countries in which they do business, regardless of local customs.

This means we expect our Business Partners to:

• refrain from offering or making any payments of money or anything of value (including kickbacks, favors, gifts, gratuities, entertainment, travel, political contributions, charitable donations or other business courtesies) to Customers, government officials, political parties, candidates for public office, charities, or other business-related parties that could be considered to improperly influence a business decision;
• prohibit the payment of facilitation payments intended to expedite or secure performance of a routine governmental action like obtaining a visa or customs clearance, except in situations where there is an imminent threat to personal health or safety (i.e., where the individual's life, limb, or liberty are in danger); and
• conduct appropriate due diligence and monitoring activities to prevent and detect corruption in all business arrangements, including partnerships, joint ventures, offset agreements, and the engagement of third parties, including consultants.

Engage in Fair and Responsible Competition and Source Selection

Business Partners must compete on the merits of their products and services rather than by any illegal or unethical business practice.

This means we expect our Business Partners to:

• comply with competition and antitrust laws;
• never make agreements with competitors to fix prices, rig bids, allocate Customers or markets, or exchange any pricing information;
• never use the exchange of business gifts and hospitality to gain an unfair competitive advantage;
• never offer anything of value to Versar's team members to obtain favorable treatment in an existing relationship or to entice the team member to enter into such a relationship; and
• utilize and leverage competition in the marketplace to the maximum extent possible.

Comply with Global Trade Requirements

Imports and Exports

Our Business Partners must comply with the laws, directives and regulations that govern international trade, including those that govern the import and export of parts, components, and technical data such as the U.S. International Traffic in Arms Regulation and the Export Administration Regulations.

Anti-Boycott

Our Business Partners must comply with U.S. Anti-Boycott laws and regulations.

Anti-Money Laundering

Business Partners must also comply with anti-money laundering laws and regulations.

Security

When applicable, Business Partners should implement practices and procedures to ensure the security of their supply chains.

Maintain Accurate Books and Records

We expect Business Partners to be honest and transparent and to create and maintain complete and accurate records for all transactions and business processes related to our mutual business, including those for timekeeping and invoicing purposes. All records, regardless of format, made or received in furtherance of a business transaction must fully and accurately represent the transaction or event being documented. Business Partners must not alter any record to conceal or misrepresent the underlying transaction represented by such record. Records should be retained based on the applicable records retention requirements set forth in the applicable contract or under applicable law or regulation.

Avoid Conflicts of Interest

Conflicts of interest can arise when personal interests interfere or appear to interfere with a person's ability to make objective business decisions or perform their duties without bias. This applies to a conflict between the interests of our company and the personal interests of those working on our behalf, or their close relatives, friends, or associates.

This means we expect our Business Partners to:

• be fully transparent with respect to all relationships that Business Partner may have with any of our team members;
• avoid all situations that create a conflict of interest, or the appearance of one, in their dealings with our company;
• avoid offering our team members any gift or hospitality that is frequent, lavish, or extravagant, or otherwise does not comply with the law, our policies or Code of Conduct; and
• provide notification to all affected parties when an actual or potential conflict of interest arises so that it can be properly resolved.

Ensure Product and Service Quality

Business Partners must take due care to ensure their work product meets our company's quality standards.

This means we expect our Business Partners to have effective processes in place to:

• identify defects and implement corrective actions, and facilitate the delivery of products and services whose quality meets or exceeds the contract requirements;
• minimize the risk of introducing counterfeit parts and materials into deliverable products; and
• detect counterfeit parts and materials, provide notification to recipients of counterfeit product(s) when warranted, and exclude them from the delivered product.

Follow the Rules for Contracting with the Government

Business Partners must comply with the specific rules that apply to contracting with the U.S. Government.

This means we expect Business Partners who work with us in support of a U.S. Government contract to:

• follow the U.S. Government's rules for competing fairly;
• honor restrictions applying to U.S. Government employees, including those related to gifts, hospitality and offers of employment;
• deliver products and services that conform to specifications, laws, and regulations;
• adhere to government accounting and pricing requirements;
• ensure the accuracy of data submitted;
• comply with all other applicable U.S. Government requirements; and
• promptly report any suspected violations of this Business Partner Code, law, or regulations.

Commit to Innovation and Excellence

We are committed to applying innovation and excellence as fundamental organizational operating principles and in project execution. We expect our Business Partners to apply these same principles in the conduct of their respective businesses.

Safeguard Assets and Information

We rely on our Business Partners to protect the company assets that we have entrusted to them, against unauthorized access, loss, damage, theft, and misuse, and to only use them in a manner that is permitted under our contract. This includes physical assets and our company's confidential and proprietary information, trade secrets, copyrights, and trademarks, and any other company data accessible to the Business Partner.

This means we expect our Business Partners to:

• properly handle sensitive information, including confidential, proprietary, and personal information, using it only for the business purpose for which it was provided unless given prior authorization from the information owner;
• comply with all applicable data privacy/data protection laws and regulations;
• respect and comply with all the laws governing intellectual property rights assertions, including protection against disclosure, patents, copyrights, and trademarks;
• never use material, non-public information ("insider information") as the basis for trading or for enabling others to trade in the securities of our company or those of any other company;
• maintain information security programs designed to mitigate cybersecurity risks and adequately protect their information systems from unauthorized access, destruction, use, modification and disclosure; and
• promptly inform us of any unauthorized use of the Business Partner's information systems or potential unauthorized access or compromise of such systems or data.

Promote Environment and Sustainability

We are committed to protecting the environment and operate, practice and apply principles of environmental sustainability to promote resource protection and support conservation to help address environmental challenges.

This means we expect our Business Partners to:

• operate in a manner that actively manages risk, minimizes waste, and protects the environment;
• apply a systematic approach to the management of risks/hazards and opportunities associated with the environment, including potential risk from regulatory non-compliance, reputational loss, and opportunities for business growth through operational and product stewardship; and
• make decisions that promote positive environmental impact.