Code of Conduct & Ethics Policy

Effective Date: October 1, 2025

Introduction

Westminster Consulting Group LLC (“WCG”) is committed to conducting business with the highest standards of integrity, ethics, and professionalism. This Code of Conduct & Ethics Policy establishes the principles and expectations that guide our operations, relationships, and decision-making.

All employees, contractors, consultants, and representatives of WCG are expected to read, understand, and comply with this Code. Adherence to these standards is essential to maintaining trust with our government partners, community stakeholders, and the public we serve.

Our Core Values

Integrity: We conduct all business honestly, transparently, and in compliance with applicable laws and regulations.

Accountability: We take responsibility for our actions and deliver on our commitments to partners and communities.

Excellence: We strive for the highest quality in every project and interaction.

Respect: We treat all individuals with dignity, fairness, and professionalism.

Service: We are dedicated to creating positive, lasting impact in the communities we serve.

1. Compliance with Laws and Regulations

WCG is committed to full compliance with all applicable federal, state, and local laws, regulations, and ordinances. This includes but is not limited to:

Government contracting regulations
Labor and employment laws
Environmental regulations
Housing and zoning laws
Anti-discrimination laws
Tax laws
Health and safety requirements

All team members must:

Understand and comply with laws relevant to their work
Seek guidance when uncertain about legal requirements
Report any suspected violations immediately

Violations of law will not be tolerated and may result in disciplinary action, up to and including termination.

2. Ethical Business Practices

Honesty and Transparency

We conduct business with honesty and transparency in all dealings. We provide accurate, complete, and timely information to government partners, stakeholders, and regulatory authorities.

Fair Dealing

We compete fairly and ethically. We do not engage in deceptive, misleading, or unfair business practices.

Accurate Records

We maintain accurate and complete business records, including financial statements, project documentation, time records, and communications. Falsification of records is strictly prohibited.

Confidential Information

We protect confidential and proprietary information belonging to WCG, our clients, and partners. Information should only be shared on a need-to-know basis and in accordance with legal requirements.

3. Conflicts of Interest

A conflict of interest occurs when personal interests interfere, or appear to interfere, with the interests of WCG or our clients.

Disclosure Requirement

All team members must promptly disclose any actual or potential conflicts of interest to management. This includes:

Financial interests in organizations that do business with WCG or our clients
Outside employment or business activities that may conflict with WCG duties
Personal relationships that may create conflicts in business decisions
Gifts or benefits that may influence business judgment

Prohibited Activities

Team members may not:

Use their position for personal gain
Accept gifts, favors, or entertainment that could influence business decisions
Compete with WCG or divert business opportunities for personal benefit
Use confidential company information for personal advantage

Government Contracting

Due to the nature of our work with government entities, team members must be especially vigilant about conflicts of interest and comply with all applicable government ethics rules.

4. Gifts, Hospitality, and Entertainment

General Rule

Team members may not offer or accept gifts, meals, entertainment, or other benefits that could improperly influence business decisions or create the appearance of impropriety.

Government Officials

Special restrictions apply to interactions with government employees and officials:

Prohibited: Offering anything of value to government officials to influence decisions
Team members must comply with all applicable gift and ethics rules of government clients
When in doubt, decline or consult management before accepting or offering anything

Modest Business Courtesies

Modest, occasional business meals or promotional items of nominal value may be acceptable if they:

Are customary in the industry
Do not create obligation or appearance of impropriety
Comply with client policies and applicable laws
Are properly documented

5. Anti-Bribery and Anti-Corruption

WCG strictly prohibits bribery, kickbacks, and corrupt practices of any kind.

Prohibited conduct includes:

Offering, promising, or providing anything of value to improperly influence decisions
Accepting bribes, kickbacks, or improper payments
Making facilitation payments (even where legal)
Using intermediaries to engage in prohibited conduct

This policy applies to:

Interactions with government officials at all levels
Commercial business relationships
Subcontractors and vendors
All domestic and international activities

6. Equal Opportunity and Non-Discrimination

WCG is committed to providing equal employment opportunities and maintaining a workplace free from discrimination and harassment.

Non-Discrimination

We do not discriminate based on:

Race, color, or ethnicity
National origin or ancestry
Gender, sex, or gender identity
Sexual orientation
Religion or creed
Age
Disability or veteran status
Genetic information
Any other protected characteristic under applicable law

Harassment-Free Environment

WCG prohibits harassment of any kind, including sexual harassment, bullying, intimidation, or other offensive conduct. All team members deserve to work in a respectful, professional environment.

Reporting

Anyone who experiences or witnesses discrimination or harassment should report it immediately through the channels outlined in Section 11.

7. Health, Safety, and Environment

WCG is committed to providing a safe, healthy work environment and conducting operations in an environmentally responsible manner.

Team members must:

Follow all health and safety policies and procedures
Report unsafe conditions or practices immediately
Comply with environmental laws and regulations
Support sustainable practices in project planning and execution

Prohibited conduct:

Working under the influence of drugs or alcohol
Workplace violence or threats of violence
Bringing weapons to work (unless legally authorized and permitted by policy)

8. Protection of Company Assets

Team members are responsible for protecting WCG’s physical and intellectual assets, including:

Equipment, vehicles, and property
Confidential information and trade secrets
Intellectual property and proprietary data
Computer systems and data
Financial resources

Company assets should only be used for legitimate business purposes.

9. Political Activities and Contributions

Personal Political Activities

Team members may engage in personal political activities on their own time, using their own resources. However:

Do not represent personal political views as those of WCG
Do not use company resources, time, or facilities for political activities
Do not pressure others to support particular political positions

Corporate Political Activities

WCG does not make political contributions unless permitted by law and approved by senior management. All political activities must comply with applicable campaign finance and lobbying laws.

Government Relations

Communications with government officials on behalf of WCG must be truthful, accurate, and comply with lobbying disclosure requirements.

10. Social Media and Public Communications

Professional Conduct

Team members who communicate publicly about work-related matters must:

Be professional, respectful, and accurate
Protect confidential and proprietary information
Make clear when expressing personal opinions (not company positions)
Comply with all applicable laws and regulations

Authorization

Only authorized spokespersons may speak on behalf of WCG to media, at public events, or in official capacities.

11. Reporting Violations and Non-Retaliation

Duty to Report

All team members have a responsibility to report suspected violations of this Code, company policies, or applicable laws.

How to Report

Reports can be made to:

Direct supervisor or manager
Human Resources (if applicable)
Senior management
Email: info@westminstercg.com

Anonymous reports are accepted when permitted by law.

Non-Retaliation

WCG strictly prohibits retaliation against anyone who:

Reports suspected violations in good faith
Participates in investigations
Refuses to engage in unlawful or unethical conduct

Retaliation is itself a serious violation and will result in disciplinary action.

Good Faith Reporting

Reports should be made in good faith based on reasonable belief. Knowingly false or malicious reports will not be tolerated.

12. Investigations and Discipline

Investigation Process

WCG will promptly and thoroughly investigate all reported violations. Investigations will be conducted professionally, confidentially to the extent possible, and impartially.

Cooperation

All team members are expected to cooperate fully with investigations.

Disciplinary Action

Violations of this Code may result in disciplinary action, up to and including:

Written warnings
Suspension
Termination of employment or contracts
Legal action
Reporting to appropriate authorities

The specific action taken will depend on the nature and severity of the violation.

13. Acknowledgment and Certification

All team members must acknowledge receipt of this Code of Conduct & Ethics Policy and certify their commitment to comply with its provisions.

By working with or for WCG, you acknowledge that:

You have received and read this Code
You understand your obligations under this Code
You agree to comply with all provisions
You will report suspected violations
You understand that violations may result in disciplinary action

14. Waivers and Amendments

Any waiver of this Code must be approved in writing by senior management. WCG reserves the right to amend, modify, or revise this Code at any time. Updates will be communicated to all team members.

15. Questions and Guidance

If you have questions about this Code or need guidance on ethical issues, please contact:

Westminster Consulting Group LLC

Email: info@westminstercg.com

Mailing Address:
70 East Sunrise Hwy, Suite 500
Valley Stream, New York 11581

Conclusion

This Code of Conduct & Ethics Policy reflects WCG’s commitment to integrity, transparency, and excellence. By adhering to these principles, we build trust with our partners, strengthen our communities, and ensure sustainable success.

Every team member plays a vital role in upholding these standards. Together, we build stronger communities—ethically and responsibly.

Westminster Consulting Group LLC
Integrity in Action. Excellence in Service.