Tsunami Tsolutions Personnel are required to be vigilant in ensuring that any business courtesy is reasonable, lawful, and fully justified under the circumstances, and does not suggest the appearance of impropriety. Company policies and procedures strictly prohibit offering any courtesy that could be misinterpreted as an attempt to gain an improper business advantage and include elevating thresholds of management approval. Before any courtesy is offered, personnel must determine that it is lawful and appropriate and would not result in an inappropriate action by the company or recipient.

Additionally, personnel must follow strict guidelines when determining if an offered courtesy can be accepted. Personnel are prohibited from soliciting courtesies or accepting any courtesies when a real or perceived attempt is being made to influence action by Tsunami Tsolutions.

Personnel are restricted in the gifts, favors and/or benefits they may accept or give to persons including current or prospective vendors, suppliers, and persons/entities doing or seeking to do business with Tsunami Tsolutions. 

Specifically:

• Personnel may not accept or give gifts, favors or benefits of more than nominal value (under $40.00) during a calendar year from or to any current or prospective vendor or supplier of Tsunami Tsolutions or from any person or entity doing or seeking to do business with Tsunami Tsolutions.
• Personnel may not accept or give any gifts, favors or benefits from or to any client of Tsunami Tsolutions, except as expressly authorized by Tsunami Tsolutions.
• Meals, group events, event tickets or other events involving current or prospective clients may also be considered as favors or benefits. Consideration must be given to the potential for such an event to be considered an attempt to inappropriately gain an improper business advantage.

Personnel must promptly disclose to Tsunami Tsolutions any activities, relationships or other circumstances that may give rise to a conflict of interest covered by this policy.  Such disclosures must be made as soon as practicable upon discovery of the conflict or potential conflict.  When unsure whether a conflict exists or may exist, personnel is expected to consult with the People & Culture Department or with the CEO or CFO for guidance.  Failure to disclose or consult concerning an actual or potential conflict of interest as required under this policy is subject to discipline up to and including termination of employment.

If, upon disclosure or discovery, Tsunami Tsolutions determines that an actual or potential conflict of interest exists, Tsunami Tsolutions will determine whether the conflict is manageable or unmanageable. 

Personnel must comply with all measures that Tsunami Tsolutions may require for the purposes of managing, reducing or eliminating the conflict.  Tsunami Tsolutions also may require personnel to provide follow-up disclosures or reports concerning the status of the conflict and/or the personnel’s compliance with conflict management measures.  Failure to comply with conflict management measures required by Tsunami Tsolutions is subject to discipline, up to and including termination of employment.  Nothing in this policy shall prevent Tsunami Tsolutions from taking any disciplinary action it deems appropriate under the circumstances, up to and including termination of employment.

Tsunami Tsolutions policies and procedures require that all hiring decisions be made fairly, ethically and in accordance with all relevant laws and regulations.

Personnel are expected to disclose a potential or actual conflict of interest as soon as they become aware of it. An actual or potential financial conflict of interest may exist when personnel:

• Makes, participates in or influences decisions to refer or award Tsunami Tsolutions business to a person or entity in which the personnel have a personal interest, an ownership interest (other than equity interests managed by a third-party mutual fund or equivalent), an employment or consulting role, or from which the personnel is receiving compensation or other benefits.
• Solicits or accepts honoraria or other benefits for making a presentation or appearance related to the personnel’s Tsunami Tsolutions employment, unless authorized in writing by Tsunami Tsolutions.
• Solicits or accepts employment, consulting/contract work or other benefits from actual or prospective Tsunami Tsolutions competitors, vendors, suppliers, or customers.
• Refers actual or prospective Tsunami Tsolutions vendors, suppliers, and/or customers to a service, service provider or product in return for value – or in which the personnel have a financial interest.

Tsunami Tsolutions maintains accurate and transparent books and records. All assets, liabilities and transactions must be promptly and accurately reflected, and Tsunami Tsolutions personnel are strictly prohibited from ever making a deliberately false or misleading entry in our books and records, no matter how small or immaterial. Tsunami Tsolutions financial management system is designed to assure, among other things, that company resources are effectively and efficiently managed and that reporting requirements are satisfied with integrity and reliability and in compliance with all relevant laws, regulations and generally accepted practices and principles. Specific to anti-corruption controls, all personnel are required to maintain accurate financial records and appropriately document and obtain approval of costs and expenses. Personnel may not approve expense reports for themselves or their peers. Use of company credit cards for non-business expenses is strictly prohibited. Personal credit cards may not be used for business expenses, except in very limited circumstances. Company policy prohibits falsification of accounting or other business records.

Tsunami Tsolutions pursues mergers, acquisitions, joint ventures, and equity investments when such transactions align with the Company’s strategic and operating objectives. All such transactions are accompanied by comprehensive due diligence to examine rigorously the books, records, corporate filings, operations, and compliance history of the candidates for the transactions.

Tsunami Tsolutions’ policy sets out detailed procedures for review and approval of teaming agreements and other non-sales agreements with companies, including appropriate levels of due diligence to ensure compliance with the U.S. Foreign Corrupt Practices Act and other applicable anti-corruption laws. Terms and conditions in those agreements must include warranties of compliance with all applicable anti-corruption laws.

Tsunami Tsolutions recognizes that good business practices include drawing on the expertise of outside consultants and professional service providers. To ensure those relationships comply with applicable laws, the company has detailed requirements for creating, maintaining, and renewing international consultant relationships. The company conducts appropriate and risk-based due diligence based on the international consultant’s statement of work, which may include geographic location, ownership, and other relevant information. The company renews that due diligence at appropriate intervals. International consultant agreements require strict compliance with applicable laws, including anti-corruption laws. Hiring, renewing, or expanding the scope of work of an international consultant requires multi-layer executive management approvals and review.

Appropriate due diligence is conducted for potential suppliers, such as screening governmental and industry listings for instances of sanctions and/or other compliance concerns. The terms and conditions in all supplier agreements require that suppliers provide assurance of compliance with all applicable anti-corruption laws, granting Tsunami Tsolutions contractual rights in the event of a breach, inclusive of termination rights. Additionally, company procedures prohibit personnel from soliciting gifts from suppliers or having any contact with suppliers that would give rise to even the appearance of impropriety and require all personnel to comply with anti-kickback laws and regulations.

Tsunami Tsolutions is committed to maintaining the safety and security of our systems and our customers’ information. We encourage earnest, responsible reporting of potential security vulnerabilities in any product, system, or asset made by or hosted to Tsunami Tsolutions.

To enable Tsunami Tsolutions to investigate and remedy the potential vulnerability, please report it as soon as possible after discovering it and provide a detailed summary of the vulnerability, including the following if known:

A description of the finding and how it was discovered

The product(s), system(s), or asset(s) affected

Your contact information. Personal data Tsunami Tsolutions receives in connection with your submission will be retained and protected in accordance with the company’s privacy policies and any applicable laws.

A Tsunami Tsolutions representative will acknowledge receipt as soon as possible, typically within 3 business days.

Submit any vulnerability information in full accordance with the following guidelines:

Do not engage in any activity that can potentially cause harm to Tsunami Tsolutions, our customers, our suppliers, or our personnel.

Do not engage in any activity that can potentially disrupt or degrade Tsunami Tsolutions’ (or its customers’) products, systems or assets.

Do not engage in any activity that violates

1. 1. federal or state laws or regulations or
   2. the laws or regulations of any country where,
      1. Tsunami Tsolutions’ (or its customers’) data, assets or systems reside,
      2. Tsunami Tsolutions data traffic is routed or
      3. the researcher is conducting research activity.

Do not engage in extortion, threats, or other tactics designed to elicit a response under duress. Tsunami Tsolutions will not respond to submissions made under threat of public disclosure, exposure of data, or withholding vulnerability information.

Do not store, share, compromise or destroy data on Tsunami Tsolutions’ (or its customers’) systems. If Personally Identifiable Information (PII), proprietary or sensitive data is encountered, you should immediately halt your activity and contact Tsunami Tsolutions .

Provide Tsunami Tsolutions reasonable time to fix any reported issue, before such information is shared with a third party or disclosed publicly.

Every Tsunami Tsolutions personnel receives annual ethics and compliance training. Anti-corruption compliance is shared through written communication, video-based training, live training, and targeted online and in-person training for high-risk personnel with messages encouraging personnel to identify issues, ask questions and raise concerns without the fear of retaliation, emphasizing the importance of training, and providing guidance on areas of particular concern to help all personnel understand key anti-corruption responsibilities and their personal role in guaranteeing compliance with anti-corruption laws.

If personnel should fail to comply with this Policy or Anti-Corruption laws, they will be subject to disciplinary action up to and including termination of employment or other relationship with Tsunami Tsolutions. Restitution could also be required, and Criminal or Civil action against individual personnel could be warranted.

If personnel are involved in or aware of a situation they believe may violate or lead to a violation of this Policy, they must ask for guidance from their manager or other personnel in a supervisory position.

Confidential and anonymous reporting methods are provided. Retaliation against reporting parties is strictly prohibited, and action is taken against violators of anti-retaliation policies. The company also makes its personnel aware of their federally protected whistleblower rights which are designed to protect personnel against retaliation for reporting potential wrongdoing by a U.S. contractor or subcontractor.

We consider activities conducted consistent with this policy to constitute authorized access under anti-hacking laws. To the extent your activities are inconsistent with certain Tsunami Tsolutions terms and conditions, we waive those restrictions for the limited purpose of permitting security research under this policy. Tsunami Tsolutions will not pursue civil action or initiate a complaint to law enforcement for accidental, good faith violations of this policy.