Legal & Ethical Policies

At Launch, we are committed to maintaining the highest ethical standards. This Code of Conduct and Ethics Policy sets clear expectations for professional behavior and decision-making across all levels of the organization.

Key Principles

• Compliance with Laws and Regulations: Contractors must adhere to all applicable local, state, federal, and international laws and regulations.
• Integrity and Honesty: Contractors are expected to act with integrity, be truthful in all interactions, and avoid any form of dishonesty.
• Conflicts of Interest: Contractors must avoid situations where personal or business interests conflict with the interests of the Company and even our clients businesses. Sometimes a Contractor and the Company may even share clients, offer similar services to one another, or promote similar business services in the same circles. As such, please disclose such relationships or situations promptly so a determination can be made about the best course of action to ensure no harm comes to any parties involved.
• Respect and Professionalism: Contractors are expected to treat colleagues, clients, and partners with respect and professionalism.

Violations of this policy may result in termination of contract or legal remedies may need to be taken.

Prohibited Conduct Policy

At Launch Industries, we are committed to maintaining a professional and respectful environment that supports the success of our contractors, clients, and business operations. While contractors maintain independence in how they perform their work, certain behaviors are not permitted as they may jeopardize safety, security, or the company’s ability to fulfill its contractual obligations.

The following actions are examples of prohibited conduct that may result in the termination of a contractor agreement, as outlined in the terms of the contract. This list is illustrative, not exhaustive:

1. **Falsification of Records**
   • Submitting inaccurate or false time records, invoices, or reports, including reporting time on personal projects as billable or recording hours not worked.
2. **Theft or Misuse of Property**
   • Unauthorized use, theft, or damage of company, client, or contractor property, including equipment, documents, passwords, or other resources.
3. **Confidentiality Violations**
   • Disclosing or misusing confidential or proprietary information without authorization, in violation of the Confidentiality and Data Protection Policy.
4. **Substance Use**
   • Performing contract work under the influence of alcohol or illegal drugs, or possessing, consuming, or distributing illegal substances while engaged in contract-related activities.
5. **Unprofessional Behavior and Business Disparagement**
   • Engaging in harassment, abusive language, or other unprofessional conduct that materially harms the Company’s business reputation, client relationships, or contractual integrity.
6. **Unauthorized Use of Resources**
   • Using company equipment, materials, or facilities for unauthorized purposes unrelated to the contractor’s scope of work.
7. **Safety and Security Violations**
   • Failing to comply with safety protocols or engaging in dangerous behavior that puts others at risk on a job site.
8. **Illegal Activities**
   • Engaging in criminal conduct, including downloading unauthorized or pirated content on company or client networks, or violating applicable laws while performing contract-related work.
9. **Conflict of Interest**
   • Failing to disclose conflicts of interest that may interfere with the integrity of the contractor’s work for Launch or its clients.
10. **Non-Compliance with Policies**
    • Violating any policies outlined in this handbook, including but not limited to confidentiality, data protection, and cybersecurity guidelines.

Consequences of Prohibited Conduct

Violations of this policy may result in the immediate termination of the contractor agreement, in accordance with the terms outlined in the contract. Launch reserves the right to take further legal action if necessary to protect the company’s interests, clients, and stakeholders.

This policy ensures that Launch maintains a professional and secure environment while supporting the independence of contractors. Contractors are encouraged to contact the company owner or Contract Administration with any questions or concerns regarding this policy.

Confidentiality and Data Protection Policy

At Launch, safeguarding confidential and proprietary information and complying with data protection laws are top priorities. This policy outlines contractors' responsibilities to protect company, customer, and contractor information.

Definition of Confidential Information

Confidential information includes:

• Business strategies, financial data, and marketing plans.
• Customer lists, contracts, and communications.
• Trade secrets, proprietary technology, and intellectual property.
• Contractor and customer personal data protected by laws such as GDPR or CCPA.

Contractor Responsibilities

• Do not disclose confidential or proprietary information to unauthorized parties.
• Securely store and protect confidential information in physical and digital forms.
• Handle personal data in compliance with applicable laws (e.g., GDPR, CCPA).
• Immediately report any data breaches or suspected breaches to the company owner.

Prohibited Actions

• Sharing confidential information outside authorized business purposes.
• Using proprietary information for personal gain or to benefit competitors.
• Failing to follow legal requirements for protecting personal data.

Termination of Contract

Upon leaving the company, contractors must:

• Return all confidential materials, including digital files, documents, and devices.
• Cease any use of confidential or proprietary information.
• Return any Company property in Contractor’s possession

Breach of Confidentiality

Violations of this policy will result in disciplinary action, up to and including termination, and may lead to legal consequences.

Conflict of Interest Policy

Launch expects contractors to act in the company’s best interests and avoid situations where personal interests conflict with professional responsibilities.

What Constitutes a Conflict of Interest

• Financial or personal relationships that could influence business decisions.
• Accepting gifts, services, or favors from vendors, clients, or competitors that may create a sense of obligation.
• Note that we do not prohibit Contractors from providing similar services to other businesses that are provided to Launch and its clients; on the contrary, we assume you offer similar services to others. However, any such relationships, especially those that directly compete with Launch or its Clients, should be disclosed for evaluation on a case-by-case basis.

Disclosure Requirements

Contractors must disclose any potential or actual conflicts of interest to the company owner. Launch will work to resolve conflicts in a manner that protects the integrity of the business and its clients.

Political Activity and Lobbying Policy

The company maintains a neutral and professional workplace and prohibits contractors from engaging in political activities or lobbying on behalf of the company.

Key Guidelines:

1. Contractors may not use company time, resources, or their position to participate in or promote political campaigns, lobbying efforts, or causes.
2. Personal political activities must remain separate from the company, and contractors must not represent their personal views as those of the company.
3. Social media posts and public statements must not imply company endorsement of any political party, candidate, or cause.
4. Any conflicts of interest arising from political activities must be disclosed to HR.

This policy ensures a respectful and inclusive workplace. Violations may result in disciplinary action, up to and including termination. For questions, please contact HR.

Social Media and Technology Use Policy

Launch encourages contractors to use technology responsibly and professionally. This policy provides guidelines for the appropriate use of company-provided technology and social media platforms.

Technology Use Guidelines

• Company-provided software tools must only be used to perform the work you are contracting with Launch to perform.
• Passwords must be securely stored/encrypted and never shared.

Social Media Guidelines

• Contractors must not disclose confidential information or represent Launch without prior approval.
• Personal social media activity should not harm the company’s reputation or relationships with clients.

Violations of this policy may result in termination of contract.

Intellectual Property and Ownership Policy

Launch retains ownership of all intellectual property (IP) created by Contractors who are paid for such services. This includes inventions, designs, and creative works produced using company or client resources, and may include written materials, software, processes, designs, and marketing assets developed for Launch and its clients.

Contractor Obligations

• Contractors must not use Launch’s IP for personal gain or share it with unauthorized parties.
• Upon termination, contractors must return all Company materials and cease using Company IP.

Failure to comply with this policy may result in legal action.

Drug- and Alcohol-Free Workplace Policy

Launch maintains a drug- and alcohol-free work environment to ensure safety, productivity, and professionalism. Although Contractors are not employed by Company, Contractors are expected to adhere to our drug and alcohol-free workplace when visiting Company and Client job sites. As an exception, moderate alcohol consumption may be permitted at company-sponsored events with prior approval.

Violations of this policy may lead to disciplinary action, up to and including termination.

Compliance with Laws Policy

Launch complies with all applicable local, state, federal, and international laws. Contractors are expected to adhere to these laws and regulations in all aspects of their work.

Contractor Responsibilities

• Be familiar with and follow laws relevant to their role.
• Report any suspected illegal activity or non-compliance to the company owner.

Violations of this policy will be addressed promptly and may result in disciplinary action, including termination.

Anti-Bribery and Anti-Corruption Policy

As a contractor for City and State governments, Launch is committed to maintaining the highest standards of integrity and compliance with applicable anti-corruption and procurement laws. This Anti-Bribery and Anti-Corruption Policy ensures that all contractors and third parties acting on behalf of Launch understand their obligation to avoid bribery and corruption in all business dealings.

Prohibited Conduct

Contractors and third parties acting on behalf of Launch are strictly prohibited from:

• Offering, promising, giving, or authorizing bribes, kickbacks, or improper payments to government officials, vendors, or other contractors to gain an unfair business advantage.
• Soliciting or accepting bribes, kickbacks, or improper payments in connection with their work at Launch.
• Failing to report any known or suspected incidents of bribery or corruption.

City and State Contracting Compliance

As contractors for City and State governments, Launch strictly adheres to all relevant laws, regulations, and ethical standards governing public procurement and government contracting. This includes:

• State and Local Anti-Corruption Laws: Launch complies with all applicable laws prohibiting bribery, corruption, and unethical conduct in dealings with City and State officials or agencies.
• Procurement Guidelines: Contractors involved in bidding, procurement, or contracting must comply with all applicable City and State procurement policies, ensuring transparency and fairness.
• Accurate Reporting: Contractors must ensure that all financial transactions, records, and submissions related to City and State contracts are accurate and comply with reporting requirements.

Reporting Violations / Whistleblower Policy

Contractors are required to report any suspected violations of this policy to the company owner immediately. Reports will be handled with confidentiality, and retaliation against whistleblowers is strictly prohibited. Additionally, our policy prohibits discrimination against anyone who reports company violations.

Violations of this policy may result in termination of contract. In cases involving illegal activity, violations may also be reported to the appropriate City or State authorities.

Relatives and Personal Relationships in the Workplace

Launch Industries is committed to maintaining a professional, fair, and equitable business environment for all independent partners. This policy ensures that personal relationships, including those involving relatives, do not create a conflict of interest or the appearance of impropriety within the contractual relationship.

Policy Guidelines

1. **Contracting with Relatives and Close Business Partners**
   • Contract decisions involving the engagement of a contractor's relative or close business partner must be based solely on merit and the suitability of the individual/entity to meet the Statement of Work (SOW) requirements.
   • Any decision to contract with a relative must be reviewed by the Company Owner or senior leadership to ensure no perceived preferential treatment is given in the contracting process.
2. **Conflicts of Interest in Contract Administration**
   • No contractor or their relative/partner may work in a role that gives them direct authority or influence over the contract negotiation, scope of work (SOW) approval, invoicing, or payment approval for the other individual/entity's contract with Launch Industries.
   • This guideline is in place to protect the financial integrity of the contractual relationship and ensure compliance with all applicable anti-corruption and procurement laws.
3. **Disclosure of Relationships**
   • Any familial or close personal relationship that may create a potential or actual conflict of interest impacting the contracting process (e.g., contract negotiation, payment review, or compliance) must be promptly disclosed to the company owner for evaluation.
   • Launch Industries will take necessary steps, such as implementing alternative invoicing approval chains, to resolve conflicts and protect the integrity of the business partnership.

Gossip and Disparagement Policy

To maintain a professional partnership and ensure business continuity, the following behaviors are considered a violation of this policy and may result in contract termination:

1. **Malicious Falsehood or Defamation**
   • Knowingly making or distributing false, malicious, or derogatory statements (written, spoken, or electronic) about Launch Industries, its clients, partners, or other contractors that are likely to harm the Company’s business reputation or professional relationships.
2. **Breach of Confidentiality via Discussion**
   • Sharing confidential, proprietary, or private business information with unauthorized parties under the guise of informal discussion or "gossip," in violation of the Confidentiality and Data Protection Policy.
3. **Interference with Contractual Duties**
   • Engaging in discussions or behavior intended to undermine the professional standing or contractual performance of another contractor, or that disrupts the efficient operation of Launch Industries or its projects.

Violations of this policy will be addressed promptly and may result in the immediate termination of the contractor agreement.