Code of Business Conduct and Ethics


Belt and Road is committed to high ethical standards in all our activities and in compliance with applicable laws and regulations. Belt and Road's integrity is one of our most important assets and Belt and Road expects all employees to safeguard and protect that integrity. All Belt and Road employees must conduct business in an ethical and legal manner whether dealing with customers, vendors, distributors, or each other. In order to promote an ethical culture and a commitment to compliance with the law, this Code of Business Conduct and Ethics (the "Code") is designed to help employees understand their responsibilities to uphold the highest standards of business.

All Belt and Road officers, managers, employees, and any other contractor, consultant or person acting in the name of Belt and Road and its sister companies are expected to comply with our ethical obligations. The following standards of conduct will be enforced at all organizational levels. Any employee who violates, or fails to report a violation of these standards will be subject to disciplinary action, up to and including separation. Acts constituting criminal conduct may also subject the perpetrator to fines and imprisonment.

This Code supplements other Belt and Road policies and procedures, including the Belt and Road Employee Handbook and core competencies. This Code does not replace existing policies and procedures.


Belt and Road encourages its employees to provide information that may assist Belt and Road in investigating and correcting any ethical or legal violations that may occur. Belt and Road also has a strict non-retaliation policy. No form of retaliation will be tolerated for reports made in good-faith.

If Belt and Road employees are aware of a possible violation of this Code or principles, policies, or any other legal or regulatory requirements they must notify their supervisor (if the supervisor is not involved), Human Resources, or Corporate Management. This notification may be done in person, by phone, via email (to or via the Belt and Road website (contact us section). All reports are confidential and information will be shared on a need to know basis. Reports can also be made anonymously in compliance with local law. Belt and Road may have an obligation to investigate and, in some situations, report to appropriate governmental authorities whenever Belt and Road has reasonable grounds to believe that there has been a 1) violation of criminal law involving fraud, conflict of interest, bribery, or gratuity violations; 2) violation of the civil False Claims Act (31 U.S.C. 3729-3733); or 3) a violation of U.S. export control regulations.

Employees are protected by law under whistleblower protection provisions if they report gross mismanagement, gross waste, public safety issues, abuse of authority, or violation of law in the implementation or use of stimulus funds pursuant to section 1553 of the American Recovery and Reinvestment Act of 2009 (Pub.L. 111-5). Belt and Road may not discharge, demote, or otherwise discriminate against employees as reprisal for making such reports.

Belt and Road's Human Resources Organization has been designated with responsibility for overseeing and monitoring compliance with this Code. The Human Resources Department will make periodic reports to Belt and Road's Corporate Management for this purpose regarding the implementation and effectiveness of this Code.


During employment with Belt and Road, employees may have access to intellectual property and confidential information relating to Belt and Road, Belt and Road's employees, and its customers. All employees must protect Belt and Road and its customers' proprietary and confidential information from improper disclosure. Belt and Road employees must never accept confidential information from another person or company, or sign a confidentiality agreement in favor of someone else, without proper internal authorization.

All Belt and Road employees sign a "Trade Secrets, Proprietary Information, and Inventions Agreement" which, along with various laws, gives Belt and Road ownership of work developed by employees in the scope of their employment. Belt and Road employees are obligated to cooperate with Belt and Road to obtain intellectual property rights as may be necessary to protect Belt and Road's rights in the work product.

Belt and Road requires all software, data, images, or other third party-owned materials installed on its computer equipment and mobile devices to be properly licensed. To ensure the compliance of all employees with Belt and Road's copyright policy, all obligations imposed by the vendors of software, data, images, or other third party-owned materials and by law must be adhered to at all times.


Belt and Road is committed to maintaining accurate and timely financial records. Belt and Road's record keeping procedures are essential to ensure that all costs are properly charged and allocated. It is critical to Belt and Road, that all financial and non- financial data be accurate, complete and valid in all material respects.

Every employee is expected to complete their electronic time card promptly and accurately, in accordance with the time charging guidelines. Similarly all check requests, travel expenses and other costs must be accurately coded to the proper expense accounts.


Belt and Road is committed to providing a safe and productive work environment that is free from all forms of sexual or other illegal harassment, violence, or illegal discrimination. All employees and non-employees in a business relationship with Belt and Road must comply with this policy. Further, Belt and Road employees may not perform work while impaired due to drugs or alcohol, and must comply with the Belt and Road drug free workplace policy. Belt and Road is a weapons-free work site. Please refer to the Employee Responsibilities section of the Employee Handbook for additional details.

Belt and Road prohibits the use of forced or involuntary labor, including all forms of child labor, human trafficking, and slavery. The Company is committed to preventing these practices in its supply chain and it expects suppliers to do the same.


Belt and Road complies with Equal Employment Opportunity laws and does not discriminate on the basis of race, color, national origin, sex, age, disability, creed, religion, sexual orientation, or veteran status in treatment or employment. Belt and Road also makes reasonable accommodations for people with disabilities. Please reference the Equal Employment Opportunity Policy.


Belt and Road discourages employees from engaging in any activity that is, or may appear to be, a conflict of interest with the employee's duties at Belt and Road. Every employee is expected to avoid circumstances where personal or family interests actually or potentially conflict with the interests of Belt and Road. Employees must declare in writing to Human Resources any hires of relatives or close associates, in addition to any financial interests employee or employee's relatives or close associates have in any competitors, customers, or suppliers to Belt and Road. Employees elected or appointed to public office, or to external boards with organizations related to or affiliated with Belt and Road competitors, customers, suppliers, or partners must also disclose these positions to Human Resources.


All dealings with customers and potential customers must be legal, fair, and open. Belt and Road does not tolerate bribery or corruption. Belt and Road employees may never accept or solicit bribes, improper payments, gifts or gratuities from or to any Belt and Road customer or supplier. Belt and Road employees may not on behalf of Belt and Road give or solicit a gift, entertainment, meals, political contributions, charitable donations, or other gratuity of any kind, nor may they accept a gift, entertainment, meals, or other gratuity from a customer, supplier, vendor representative or business partner greater than $20.00 market value without Corporate Management approval. Belt and Road employees may not give a public official anything of value: 1) with the intent to influence any official act; 2) to influence the official to commit or aid in fraud; nor 3) to induce the official to act in violation of their official duties.


Whenever Belt and Road employees are called upon to make statements about competitors and their products or about Belt and Road products and services, they should do their utmost to make sure these statements are current and accurate.


Belt and Road believes in fair and open competition and requires strict adherence to all applicable Antitrust or Competition laws worldwide. All employees must, at all times, comply with Antitrust or Competition laws and Belt and Road's antitrust and competition policies, including any regional policies that apply to particular businesses. Employees are not to seek proprietary competitor information either directly, or from others, which may have resulted from a breach of confidentiality or lapse of integrity. Business relationships with Belt and Road's customers, suppliers, and competitors must comply with all applicable laws, including U.S. antitrust laws. Any questions regarding Antitrust Laws may be directed to the Contracts and Legal Services department for clarification.

As a general rule, agreements and/or arrangements among competitors regarding (among other things) prices, trading conditions, projected sales for any specific products or services, revenues and expenses, production schedules, inventories or sharing markets violate antitrust laws. The exchange of competitive or proprietary information must also be avoided. These guidelines also apply to informal contacts with competitors, including those at trade shows or meetings of professional organizations.


Belt and Road is committed to promoting business while complying with all applicable U.S. export control laws and regulations that guide the transfer, export, sale, or release of any product including hardware, software, data, or technology from the United States. Guidance on compliance with U.S. export control regulations is available in the Belt and Road Export Compliance Manual. Any additional questions regarding export control may be directed to the Contracts and Legal Services department for clarification.