1. Purpose and Relationship to Governing Documents
This Code of Conduct Policy ("Policy") is published by VA WORKS, LLC ("Consultant") and forms part of the Governing Policies referenced in the Master Service Agreement (MSA), the MSA Terms and Conditions (https://vaworks.com/MasterServiceAgreement), and any applicable Scope of Work Terms and Conditions (https://vaworks.com/SOWSelection). In the event of conflict, priority shall be determined in accordance with the MSA.
The purpose of this Policy is to outline the ethical and professional standards expected of all Consultant personnel when performing services on behalf of clients.
2. Scope
This Policy applies to all employees, independent contractors, and representatives of Consultant (collectively, "personnel") engaged in providing services to clients under any MSA or SOW.
3. Standards of Conduct
Consultant requires all personnel to:
- Conduct themselves with honesty, integrity, and professionalism at all times.
- Follow all applicable laws, regulations, and contractual obligations.
- Protect the confidentiality of client information.
- Avoid conflicts of interest or the appearance of impropriety.
- Use client systems, data, and resources only for authorized business purposes.
- Report suspected misconduct or policy violations promptly in accordance with the Ethics and Reporting Policy.
4. Respectful Workplace
Consultant personnel are expected to treat colleagues, clients, and third parties with dignity and respect. Harassment, discrimination, or abusive conduct of any kind is strictly prohibited.
5. Confidentiality and Data Security
Personnel must protect all Non-Public Personal Information (NPI) and other sensitive data accessed in the course of client services. Confidentiality obligations are further detailed in the MSA Terms and Conditions, the Safeguard Policy, and the Privacy Policy.
6. Compliance with Licensed Activities Restrictions
Consultant personnel shall not perform, nor be directed or permitted to perform, any activities requiring professional or occupational licensure (e.g., mortgage loan origination, real estate brokerage, legal services, financial advising, or inspections). Licensed activities must be performed exclusively by duly licensed individuals employed or contracted directly by the client.
7. Client Systems Disclaimer
Where personnel access Company-provided systems (including virtual desktops, licensed platforms, or third-party applications), Consultant does not own, manage, or control such environments. In accordance with the Data Security and Breach Disclaimer, the Company remains solely responsible for its own system protections, malware defenses, and insurance coverage.
8. Accountability and Enforcement
Violations of this Policy may result in disciplinary action, up to and including termination of employment or contract. Consultant also reserves the right to notify the client if a violation may materially affect client services.
9. Review Cycle
This Policy is reviewed annually by Consultant's leadership or sooner as required by legal, regulatory, or contractual changes.