Code of Business Ethics and Conduct

This code applies to Viceroy NM directors, officers, employees, agents, and subcontractors when acting for the company. The Chief Executive Officer is the accountable ethics owner. Managers are responsible for making this code available to people working on company and government-contract matters and for escalating suspected violations.

Our standards

• Act honestly, keep accurate records, and never conceal, falsify, backdate, or mischaracterize a transaction, delivery, invoice, certification, test, time record, or contract communication.
• Comply with applicable laws, contract clauses, procurement-integrity restrictions, export controls, sanctions, anti-kickback rules, and requirements governing gifts, gratuities, bribery, conflicts of interest, and confidential information.
• Disclose actual or potential conflicts promptly and do not participate in a decision until the conflict is reviewed.
• Protect government, customer, supplier, employee, and company information. Use only the approved channel and system for the data classification involved.
• Compete fairly. Do not seek source-selection information, competitor bid information, or other nonpublic procurement information through improper means.
• Use company and government resources only for authorized purposes and preserve records subject to contract, audit, investigation, or legal-hold requirements.

Ask or report

Raise a question or report suspected misconduct confidentially by emailing govops@viceroynm.com with “Confidential ethics report” in the subject, or by mailing a sealed envelope marked “Confidential — Chief Executive Officer” to Viceroy, LLC d/b/a Viceroy NM, 8100 Wyoming Blvd NE, Ste M4-301, Albuquerque, NM 87113, United States. Reports may omit the reporter's name, although anonymity can limit follow-up. Do not send classified information, CUI, source-selection information, export-controlled technical data, credentials, or evidence requiring a protected channel through ordinary email or the public website; request an approved channel first.

No retaliation

Viceroy NM prohibits retaliation against a person who raises a concern in good faith, seeks guidance, participates in an investigation, or makes a protected disclosure. Knowingly false reports or interference with an investigation may result in corrective action, but an unsubstantiated good-faith concern is not misconduct.

Review and response

Reports are routed to an owner without the reported conflict, assessed promptly, preserved as appropriate, and investigated proportionately. Confirmed violations may result in corrective or disciplinary action, contract or customer notice, recovery of funds, process changes, or referral to an authority. Confidentiality is protected to the extent reasonably possible and consistent with a fair investigation and legal obligations.

Government-contract disclosure

When the company has credible evidence connected with the award, performance, or closeout of a covered Government contract or subcontract, Viceroy NM follows the applicable written-disclosure requirements, including disclosure to the responsible agency Office of Inspector General with a copy to the Contracting Officer where required. See the official FAR 52.203-13 Contractor Code of Business Ethics and Conduct. This public summary does not replace a contract clause, agency-specific procedure, protected disclosure right, or advice from counsel.

Questions

Questions about this code may be sent to govops@viceroynm.com.