Drug, Alcohol & Corruption
1.1 – This Drug, Alcohol and Smoking Policy (the “Policy”) has been approved by the Shareholders (the “Shareholders”) of Blacksync Inc. and is intended to assist all employees, officers, directors, agents and contractors (the “1P360S Representatives”) of Blacksync Inc. and each of its direct and indirect subsidiaries and branches (collectively, the “1P360S”) to maintain the highest standards of ethical conduct in company affairs. This Policy is intended to comply with US and State of Delaware law requirements. The Shareholders have determined that this Policy shall be always in compliance with the anti-corruption US laws.
1.2 – This Policy will supersede any other existing 1P360S policies relating to drugs, alcohol, and smoking use or abuse.
2. Drugs and alcohol in the workplace
2.1 – The 1P360S' Policy on drugs and alcohol in the workplace is designed to address the 1P360S’ concern for the health and well-being of its employees and to ensure that the 1P360S Representatives comply with the federal Drug-Free Workplace Act of 1988. Penalties for violations of this Policy, or violations of the laws regarding controlled substances or alcohol, range from warning to permanent separation from the 1P360S depending on the seriousness of the infraction and the degree to which violation of the Policy adversely affects the well-being of the 1P360S Representatives or the fulfillment of the 1P360S’ business mission.
3. Application of the Policy
3.1 – The Policy applies to all directors, officers, employees, consultants, and contractors of 1P360S. Compliance with this Policy constitutes terms of service for each director, conditions of employment for each officer and employee, and conditions of providing services to 1P360S for each consultant and contractor. Each such person agrees to be bound by the provisions of this Policy upon notification of the most recent copy being given to them or upon notification that an updated version has been placed on 1P360S’ website for review.
4.1 – 1P360S Representatives may not consume, manufacture, distribute, dispense, or be under the influence of controlled substances in the workplace, including in vehicles provided by 1P360S, at any worksite or location at which 1P360S duties are being performed by 1P360S Representatives, or as part of any other 1P360S activities. Common examples of controlled substances include but are not limited to cocaine, marijuana, and heroin.
1P360S will take disciplinary action against violators, consistent with 1P360S Policy, and federal, state, and local laws. Such disciplinary action may include satisfactory participation in a substance abuse treatment, counseling, or education program as a condition of reinstatement or continued employment, suspension, termination of employment, and referral for prosecution.
5. Reporting requirements
5.1 – The Drug-Free Workplace Act requires that employers who are engaged in activities funded by federal grants or contracts notify the relevant federal agency of convictions under the criminal drug laws for violations occurring in the workplace. To ensure 1P360S’ compliance with this federal law, 1P360S Representatives must report any criminal drug statute conviction for a violation occurring in the workplace to their immediate supervisor, department director, dean, vice president, or human resources officer within five days of the conviction. Within ten days of learning of such a conviction of any individual engaged in work under federal grants or contracts, 1P360S is required to notify the relevant federal agency. Upon notification of a conviction, supervisors should immediately contact their local human resources office.
6.1 – All 1P360S Representatives are prohibited from consuming alcohol or being under the influence of alcohol during work hours or in the workplace (except that it will not be a violation of this Policy for an employee to engage in the responsible consumption of alcohol at approved social functions held during work hours or in the workplace, provided that the use of alcohol has been permitted in these circumstances.) Under no circumstances may a 1P360S Representative consume or be under the influence of alcohol while operating 1P360SC vehicles or equipment. The consumption of alcohol will not constitute a mitigating circumstance when it contributes to the violation of 1P360S policies.
President, Vice Presidents, CEO, and heads of administrative units have the authority and responsibility to govern the use of alcohol in areas they control, and to require measures to ensure that at events where alcohol will be served only individuals of legal age will have access. Those hosting such events must take reasonable steps to ensure that the acquisition, distribution, and consumption of alcohol otherwise comply with applicable law and 1P360S Policy.
7.1 – Smoking is prohibited inside all 1P360S buildings or properties. All forms of tobacco use including cigarettes, cigars, e-cigarettes, and smokeless tobacco are prohibited inside all 1P360S buildings, offices, properties.
8.1 – The Compliance Officer and the Shareholders will review and evaluate this Policy on an annual basis to determine whether it is effective in ensuring compliance by 1P360S , its directors, officers, employees, consultants, or contractors with all relevant anti-corruption laws, rules, and regulations.
9.1 – By accepting this Policy, directors, officers, employees, family members, consultants and contractors of 1P360S accept ’ values and standards and are obliged to comply with them during the contractual relationship with 1P360S. Any violation of this Policy will thus be deemed as a severe breach of contract which entitles 1P360S to withdraw from the contract unless the directors, officers, employees, family members, consultants and contractors manage after being granted a reasonable period of grace to eliminate / resolve the circumstances / issues which led to non-compliance within such period. However, in case of deliberate or repeated non-compliance or in case 1P360S’ business and or reputation might be affected by the non- compliance of the directors, officers, employees, family members, consultants and contractors, 1P360S is entitled to withdraw from the contract with immediate effect (i.e. without necessity to allow for a period of grace before withdrawal).
10. Approval and amendment
10.1 – This Policy was approved and adopted by the Shareholders. 1P360S is committed to reviewing and updating its policies and procedures on a continuing basis. This Policy may be revised, changed, or amended at any time by the Shareholders, and amendment to the Policy will be disclosed promptly to directors, officers, employees, family members, consultants and contractors and will be disclosed publicly in accordance with applicable laws.
11. Publication of the Policy
11.1 –This Code will be posted on 1P360S' website. For any further information you may need, related to this document, we kindly invite you to write to the Compliance Team.