Sterling’s ethics and compliance program involves leadership and oversight. Sterling’s Board is committed to maintaining an effective ethics compliance program. The Board has delegated oversight to the Audit Committee and has delegated executive oversight to Sterling’s Chief Compliance Officer. A Compliance Report is presented to the Audit Committee at least quarterly to provide updates on processes to ensure compliance with the program.
Overview of Ethics and Compliance
A reputation of integrity is one of the most valuable assets a company can possess. Sterling’s reputation has been built over many years and is dependent on the integrity and sense of responsibility demonstrated by our employees. Sterling is committed to high ethical, moral, professional, and legal standards and is dedicated to operating its business consistent with these high standards of business conduct and ethics.
Our company-wide commitment to ethical business practices is a result of strong ethical leadership coupled with individual ethical standards of each of our employees. Sterling’s Board adopted the Code of Business Conduct (the “Code”), which applies to all directors, officers and employees, and all business partners, including owners, joint venture partners, suppliers, subcontractors, and all other parties acting as representatives or agents of Sterling and its subsidiaries. The Code sets forth the expected standard of conduct and provides guidance for our legal and ethical responsibilities when acting as a representative of Sterling. Every Sterling employee receives training on the Code and is required to certify that they have received, have read, and understand the expectations of the Code.
The core of our ethics and compliance framework is built around preventive communications, education and training at all levels of the organization. Our education and training programs enable employees to identify and deal with ethical problems, which are implicit in their everyday choices and actions.
We continue to promote and encourage a ‘See Something – Say Something’ culture through increased visibility of the Chief Compliance Officer within our business units. We continue to conduct substantive trainings and strengthen our processes to ensure that all allegations of employee misconduct are reported up through appropriate channels, and are consistently investigated and remediated.
Sterling has several other polices that support honesty and integrity in addition to the Code of Business Conduct. These polices include, but are not limited to, the Insider Trading Policy, Conflicts of Interest Policy, Anti-Fraud Policy, and a Supplier Code of Conduct, which applies to contractors and agents of Sterling. Sterling business unit Employee Handbooks serve as another resource for employees.
Sterling is committed to fostering dialogue between management and employees through multiple channels.
Supervisors are expected to maintain an environment that promotes open communication. In addition, Sterling hosts an independent compliance EthicsLine for employees and external parties to report concerns about ethical or questionable conduct they may not be comfortable discussing with their management or a member of human resources.
In addition to the Code, and other policies, Sterling provides several channels for employee communications and training, including the LRN (formerly Legal Research Network) interactive training portal; periodic Ethics & Compliance reminders, New Hire Orientation, as well as virtual and instructor-led training.
As part of Sterling’s on-going commitment to developing a strong culture of ethics and integrity, Sterling promotes a culture of speaking up through our “See Something — Say Something” initiatives.
The goal of this initiative is to —
- Protect both Sterling and our employees from risks by ensuring that we are aligned with both external and internal policies & regulations.
- Promote a culture that encourages Sterling employees to take responsibility for always doing the right thing.
- Help employees grow our business in a compliant way.
Sterling has implemented a multi-faceted management methodology for cybersecurity to best protect company data. This approach includes: people, policies, processes and technology. In addition to protective systems and measures, we believe that ongoing employee awareness and training play a critical role in data security.
- People — The best cybersecurity strategies start with people. At Sterling we are working to create a culture of cybersecurity awareness.
- Policies/Processes — Structure is key, our policies guide our processes and technology.
- Technology — Sterling has focused on the right technologies in the right places for the largest mitigation of cybersecurity risk.
During 2020, Sterling obtained a cybersecurity assessment from an independent third party. In addition, system vulnerability tests were also conducted on sterling’s systems by an independent third party. The tests were conducted without incident and the cybersecurity assessment results were typical based on cybersecurity framework standards.
Sterling’s Commitment To An Ethical Culture
- Sterling is committed to upholding the highest ethical standards and complying with applicable laws and regulations, its Code of Business Conduct and Company policies or requirements.
- We have selected Lighthouse-Services to provide us with an anonymous and confidential method to hear your concerns or report misconduct. The Ethics Line is open not only to Sterling employees but to any party with knowledge of an ethics or compliance issue, including customers, vendors and other third parties.
- The Ethics Line is a phone and Internet resource established to help us do the right thing. You have our promise that your comments will be heard.
- We also prohibit unlawful retaliation. Sterling prohibits retaliation against anyone for raising a legal or ethical concern in good faith or for cooperating with an investigation.
Frequently Asked Questions
- We recognize that you may have questions about the Sterling’s Ethics Line and what will happen when you call. Please read through our FAQ prior to filing a report.
Frequently Asked Questions
Lighthouse-Services is an independent third party that provides secure, confidential telephone and web-based systems for use by individuals who wish to report a concern or submit an inquiry relating to business conduct. Sterling is one of many companies that contracts with Lighthouse-Services for this service in the belief that potential reporters will be more comfortable reporting a concern if they know they will be reporting to a professional, third-party. The EthicsLine is available 24 hours per day, 7 days per week, 365 days per year. In addition, Lighthouse-Services offers translation services that allow telephone and web reports to be made in many languages.
When filing a report, or just seeking advice, you will be asked to provide the most detailed information possible about the incident, or question. You may choose to remain anonymous when submitting your question or report; however, doing so may limit a full investigation of the matter. When submitting your question or report, you will be given a unique report number and asked to create a personal identification number, or PIN. You will need this information to access the follow up on a report you reported, or to add additional information. We ask you to follow-up on your inquiry or report within five to ten business days. Continued follow-up on a matter is particularly important for anonymous reports, where we have no other means to communicate with a reporter.
Concerns about an immediate threat of physical harm or damage to property should not be reported to the EthicsLine. However, if you require emergency assistance, please contact your local emergency services, or hang up and call 911.
Sterling urges you to use the EthicsLine whenever you have a question or concern that cannot be readily addressed within your work group or through your supervisor. First consider whether you are comfortable raising your concern directly, such as to your supervisor or manager, your manager’s supervisor or your local HR Representative. Individuals within the Company have indicated that, while sometimes challenging, directly addressing issues and or concerns with those involved can be very effective. If you are uncomfortable reporting your concern, if you do not know whom to contact, if you believe your concern has not been satisfactorily addressed, or if you wish to remain anonymous, please proceed with the filing of a report through the EthicsLine.
If you choose to identify yourself in reporting your concern, Sterling will make every reasonable effort to hold your name in confidence during the investigation. Many investigations can be more quickly and effectively completed when the reporter is identified because it allows Sterling’s investigators to follow up directly with the reporter. Please note that if you are reporting about a personal concern involving your work schedule, benefits, pay or other employment-related matters, we may not be able to resolve it if you do not identify yourself. Please take this into account when filing your report.
If you no longer have your unique report number or PIN, you will no longer be able to access your report and you will be required to file a new report. The use of the report number and PIN is integral to maintaining a high level of confidentiality. You can mention in your new report that this matter relates to another report you previously filed.
Sterling strictly prohibits any form of retaliation against any person who reports a concern. Complaints made in good faith will not expose you to any adverse action regardless of whether the concerns you report prove to be valid or result in any corrective action. If you believe you have faced retaliation of any kind, please report it to the EthicsLine so that Sterling can investigate.
Yes! Reporting a concern can minimize the potential negative impact on the Company, and most importantly, help to alleviate a difficulty you might be facing. When necessary, Sterling will intercede in perceived ethical or business conduct issues. Also, offering input may help identify issues that can improve corporate culture and the Company’s overall performance. If you observe or suspect a violation of any Company workplace policy or of the law, as an employee, you have the obligation to speak up! Please do not assume that someone else is going to raise the concern. Unless you speak up, Sterling may not have the opportunity to investigate and address the situation.