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Code of Conduct

ATTAC Consulting Group, LLC Code of Conduct and Ethics

Revised 01/09/2012

Introduction

ATTAC Consulting Group, LLC (ACG) is committed to ethically responsible behavior with its Clients, internal and external constituencies and to full compliance with all applicable statutory, regulatory and other legal requirements, specifically including federal and state program requirements. Conducting our business in a fair and ethical manner is a core value for ACG and its Principals. This Code of Conduct is intended to set forth the expectations of its Principals and management regarding ethical conduct and to ensure that all members of the ACG team avoid wrongdoing and abide by the highest standards of integrity.

Scope

This Code of Conduct is applicable to ACG, its subsidiaries and affiliates, and all Members, Principals, Officers, employees, contractors, subcontractors, vendors and business partners (collectively “Business Parters”). In addition, ACG’s Business Standards, Policies and Procedures outline further business and compliance requirements and expectations for all Business Partners.

Core Commitments

ACG is committed to, and expects and requires of each Business Partner to adhere to the following:

  • Conduct at all times in accordance with ethical principles that reflect the highest standard of corporate and individual behavior.

  • Avoidance of all conflicts of interest between responsibilities to ACG and personal affairs and interests including those of your immediate household.

  • Avoidance of conflicts with the best interests of ACG and of its clients.

  • Compliance with all applicable laws, regulations, policies and procedures in all business dealings on behalf of ACG and compliance with ACG’s published business standards and/or policies and procedures.

  • Full compliance with all Federal or state program laws, regulations and requirements.

  • Maintaining the confidentiality of information entrusted to them by ACG, its Clients or their business partners.

  • Fostering an environment in which all employees, contractors and affiliates of ACG are treated fairly.

  • Protecting ACG’s assets and assuring their efficient use.

Fair Dealing

Each Business Partner should endeavor to deal fairly with ACG’s clients, customers, service providers, suppliers, competitors and employees. No Principal, officer, employee, subcontractor, vendor or business partner should take unfair advantage of anyone through manipulation, concealment, abuse of confidential information, misrepresentation of material facts or any unfair dealing practice.

Additional Commitments

ACG is committed to, and expects and requires of each Principal, officer, employee, subcontractor, vendor and business partner to adhere to the following additional principals:

  • Obtain the necessary written approvals prior to any information being used for any purpose other than as allowed under our contracts and assure that personal information provided to us about individuals by Clients is maintained with the highest degree of confidentiality and in accordance with applicable regulations.

  • Not offer or accept any form of kickback, i.e., money, fee, commission, credit, gift, gratuity, thing of value or compensation for the purpose of improperly obtaining or rewarding favorable treatment including obtaining unwarranted waivers of deadlines and acceptance of non-conforming goods in connection with a prime contract or subcontract.

  • Commit any action with actual knowledge of falsity, reckless disregard for the truth or falsity, or deliberate ignorance of the truth or falsity or submit false or fraudulent claims for payment related to goods or services.

Individual Responsibilities for Assuring this Code of Conduct is Followed

Each ACG Principal, officer, employee, subcontractor, vendor and business partner is expected to:

  • Learn the details of this Code of Conduct, and ACG’s Business Standards and/or policies and procedures.

  • Seek assistance from Officers, Principals, Directors or other supervisors for anything that is not understood.

  • Promptly raise any concerns about one’s own conduct or the conduct of others that may appear to violate any ACG policy or federal or state law or regulation.

  • Promptly report suspected violations of law, regulation, policy or procedure, including suspected violations of federal or state program requirements or ACG Policies and Procedures, to a Principal or other individual designated by ACG.

  • Ensure that any concerns raised are adequately addressed.

  • Cooperate with any investigation of activity suspected of violating this code on behalf of ACG.

  • Disclose immediately to a Principal any debarment, exclusion, suspension, or other event that makes that person ineligible to participate in Medicare, Medicaid or other Federal or state programs.

Consequences of Non-Compliance

Failure to act with integrity, apply appropriate business ethics or comply with applicable laws and regulations can have a severe adverse impact on ACG and its business and that of its Clients. Nothing is more important to ACG’s success than the strength of its reputation, and nothing has a greater impact on ACG’s reputation than the individual conduct of our team members.

Penalties for Non-Compliance

Anyone to whom this Code or ACG’s policies apply who fails to comply with them shall be subject to disciplinary action up to and including termination of employment or contractual relationship. Such discipline may apply to direct violation of an ACG policy or requesting others to violate an ACG policy; failure to cooperate with an investigation or an audit; and retaliating against an employee for raising a compliance or liability concern.

Raising Compliance or Ethics Concerns

In order to ensure ethical conduct throughout all of ACG, employees, subcontractors, vendors and business partners are encouraged to raise concerns they might have about conduct that falls short of ACG’s commitments and compliance standards. There are a number of ways to raise concerns or to get answers to questions about ethical conduct in the work place:

  • Contact your immediate supervisor or the appropriate ACG project manager.

  • Contact an ACG Officer, Principal or Director.

Above all, concerns should be raised early to allow any problems to be resolved quickly.

Retaliation Prohibited

ACG prohibits any Principal, Officer, employee or subcontractor from retaliating or taking adverse action against anyone for raising or helping to resolve an ethics or compliance concern.

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301 E. Liberty Street, Suite 605
Ann Arbor, MI 48104
T. (734) 214-2990
E. inquiry@attacconsulting.com