{"id":932,"date":"2021-10-07T22:48:13","date_gmt":"2021-10-07T22:48:13","guid":{"rendered":"https:\/\/www.strlco.com\/?page_id=932"},"modified":"2023-04-24T16:04:01","modified_gmt":"2023-04-24T20:04:01","slug":"ethics-compliance-program","status":"publish","type":"page","link":"https:\/\/www.strlco.com\/investor-relations\/corporate-governance\/ethics-compliance-program\/","title":{"rendered":"Ethics & Compliance Program"},"content":{"rendered":"

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Ethics and Compliance Program Structure<\/h2>\n

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<\/div>[vc_column_text]Sterling’s ethics and compliance program involves leadership and oversight. Sterling\u2019s 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\u2019s 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.[\/vc_column_text][\/vc_column][\/vc_row][\/vc_section][vc_section full_width=”stretch_row”][vc_row type=”full_width_section” top_padding=”0″ bottom_padding=”0″][vc_column bg_image=”1922″ column_center=”true” text_color=”light” width=”1\/2″][vc_empty_space height=”400px”][\/vc_column][vc_column el_class=”half-column-bg” bg_image=”2669″ column_center=”true” width=”1\/2″][\/vc_column][\/vc_row][\/vc_section][vc_section][vc_row top_padding=”100″ bottom_padding=”100″][vc_column width=”1\/1″][vc_column_text]<\/p>\n

Overview of Ethics and Compliance<\/h2>\n

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<\/div>[vc_column_text]A reputation of integrity is one of the most valuable assets a company can possess. Sterling\u2019s reputation has been built over many years and is dependent on the integrity and sense of responsibility demonstrated by our employees.\u00a0 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.<\/p>\n

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\u2019s Board adopted the Code of Business Conduct<\/a> (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.<\/p>\n

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.<\/p>\n

We continue to promote and encourage a ‘See Something \u2013 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.<\/p>\n

Sterling has several other polices that support honesty and integrity in addition to the Code of Business Conduct<\/a>. 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<\/a>, which applies to contractors and agents of Sterling. Sterling business unit Employee Handbooks serve as another resource for employees.<\/p>\n

Sterling is committed to fostering dialogue between management and employees through multiple channels.<\/p>\n

Supervisors are expected to maintain an environment that promotes open communication.\u00a0 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.<\/p>\n

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.<\/p>\n

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 \u2014 Say Something”<\/strong> initiatives.<\/p>\n

The goal of this initiative is to \u2014<\/strong><\/p>\n