Company Values

Leadership Commitment

Risk Assessment

Code of Conduct

Inquiry & Reporting

Awareness Training/Program Assessment & Evaluation


Company Values

At Zoey Consulting Services, Inc., we are a capable, strong small
business with intelligent employees dedicated to delivering the best
product possible. We place a special emphasis on core aspects of our
employees. We expect everyone involved with Zoey to be honest and
transparent in all their dealings. We value integrity and respect:
respect for both our customers and our fellow colleagues. We trust
everyone in our company to behave in an ethical manner that fosters good will. Our leadership emphasizes openness, creativity, excellence,
accountability, and cooperation. The company itself wants to be the
best it can be -- and that starts with every single employee. With these core values, honesty, integrity, respect, and trust, Zoey Consulting Services, Inc. strives to provide the best workplace experience and the highest quality security products employees and customers can ask for.

At Zoey, we pride ourselves on honest business practices, safety,
reliability, satisfaction, and security. We never compromise our
business and we never compromise our clients. Our clients' information
and our work is bar none. The satisfaction of both employee and customer matter deeply. We will provide top-notch security solutions in a timely, efficient manner. To do so, we offer an open door contact policy to keep everyone communicating. We also place an emphasis on education to maintain our employees' top-notch abilities. And finally, we steadfastly maintain good business practices with our clients, competitors, and collaborators by working together to ensure client satisfaction. Through these business practices, we will provide our customers with solutions that fit their needs.

As with all companies, our core values come from the personalities of
our staff. At our core, our founders believe in education, intelligence, honesty, accountability, and friendliness. Just as it is our job to always improve, to always do our best, and to always provide great service, we also strive to make our team comfortable and a happy place to work. We encourage a life beyond the company and all have families and perform volunteer work with esteemed organizations.

Zoey Consulting Services, Inc. (ZCS) researches, designs and implements
solutions to some of the problematic communications issues within
the Intelligence Community. We provide state-of-the-art results to
current problems and make a difference to National Security here and
around the world. We place TS/SCI w/Poly cleared professionals in
exciting career opportunities.

Zoey is a small business in the heart of Howard County. With an average
of over 20 years of experience each, our employees provide technical
analysis and software -- all at a great savings to our customers. Our
company specializes in research to production software that makes a
difference today. Zoey employees create customized solutions and bring
them to life!



Edward Hackett President

Leadership Commitment

Zoey's leaders are thoroughly committed to upholding our ethical
standards. We understand that our decisions and attitudes directly
influence the rest of the company. We take pride in leading our
employees by example; we embrace and embody our promise to uphold
ethical business practices.

In so doing, Zoey also believes in creating a culture of communication.
At any time, employees may contact their superior directly if they
believe they have found a problem. Management will immediately
investigate the issue and take appropriate action. There is no penalty
for bringing problems to light.

The ethics department may be reached at
<>. For emergencies, please call 410-772-5370. You may email anonymously by creating a site-email (gmail, hotmail, etc.)

Risk Assessment

Zoey Consulting Services, Inc. has identified several areas of
medium-to-high risk potential.

These include:
Business Courtesies/Gratuities Company Assets: accepting gifts,
presents, hospitalizes, or favors for which fair value is not paid by
the recipient. This includes tangible or intangible benefits.

Conflicts of Interest: involved in multiple interests, one of which
could possibly corrupt another Government Contracting issues Procurement Integrity/TINA Proprietary Information Safety Rules/OSHA

Time charging:
The customer publishes expected conduct and specifies details of billing in it's contracts and Zoey Consulting Services, Inc will work to ensure all it's employees understand what is expected of them and those standards are met.

Non-harassment Non-Discrimination/EEO/Affirmative Action

Commitment to Non-Discrimination
In accordance with applicable, federal, state, and local laws, Zoey Consulting Services, Inc. prohibits discrimination in employment based on an individual's protected status, including race/ethnicity, color, national origin, ancestry, religion, creed, age, gender, gender identity/expression, sexual orientation, marital status, parental status, including pregnancy, childbirth, or related conditions, disability, military service, veteran status, genetic information, or any other protected status. Any such discrimination will not be tolerated. The company is committed to taking all reasonable steps to prevent discrimination from occurring. Federal and state laws define discrimination as treating an employee differently based on the employee's membership in one of the protected categories listed above.

Commitment to No Harassment
Freedom from discrimination includes freedom from any form of harassment based on a person's protected status, including race/ethnicity, color, national origin, ancestry, religion, creed, age, gender, gender identity/expression, sexual orientation, marital status, parental status, including pregnancy, childbirth, or related conditions, disability, military service, veteran status, genetic information, or any other protected status. Such conduct is prohibited whether committed by managerial or non-managerial employees, contractors, vendors or customers. Even if such actions do not rise to the level of legally actionable conduct, they nonetheless are prohibited in our workplace. Examples of prohibited conduct include, but are not limited to:

Verbal conduct (for example, racial or sexual epithets, foul language, unwanted sexual flirtations, comments about a person's body, ethnic jokes, derogatory statements or slurs);
Physical conduct (for example, bullying, improper touching or assault);
Visual or written harassment (for example, racially or sexually explicit or derogatory posters, cartoons, graffiti, drawings, e-mails, instant messages, social media content, or obscene gestures);
Offering or implying to offer employment benefits in exchange for sexual favors; or
Reprisals for a refusal to respond to sexual advances—no supervisor or manager shall threaten or insinuate, either explicitly or implicitly, that an employee's submission to or rejection of sexual advances will in any way influence any personnel decision involving that employee.

Prohibition against Retaliation
Zoey Consulting Services, Inc. prohibits retaliation against any employee by another employee or by the company for reporting, filing, testifying, assisting or participating in any manner in any investigation, proceeding or hearing conducted by the company or a federal or state enforcement agency.

Zoey Consulting Services, Inc.'s Complaint and Reporting Procedure
The company will not tolerate any form of illegal harassment, discrimination and/or retaliation in the workplace, and will hold employees who violate this policy accountable. The company's complaint and reporting procedure provides for a prompt, thorough and objective investigation of any discrimination, harassment or retaliation claim. Following an investigation, any employee who is found to have engaged in prohibited discrimination or other conduct that violates company policy will be subject to appropriate disciplinary action, up to and including termination of employment. Appropriate action also will be taken to deter any future harassment, discrimination, and/or retaliation. If any employee believes he/she has been discriminated against, harassed or retaliated against, or is aware of discrimination, harassment or retaliation against others, the employee should provide a written or verbal report to his or her Human Resources representative, EEO administrator or his/her supervisor as soon as possible. All incidents that are reported will be investigated. The company will seek to protect the privacy and confidentiality of all parties involved to the extent possible, consistent with a thorough investigation and its legal obligations.

Additional Enforcement Information
Federal Equal Employment Opportunity Commission (EEOC) and similar state agencies investigate complaints of discrimination, harassment and retaliation in the workplace. Employees may file a complaint with any of these agencies. In addition, employees may file such complaints with the company under its Dispute Resolution Procedure as set forth in Corporate Procedures H103, Dispute Resolution Process, and H103A, Employee Mediation/Binding Arbitration Program.

Reaffirmation of Equal Employment Opportunity and Affirmative Action for Women, Minorities, Disabled and Veterans
Below are the ways in which the company promotes programs that help to ensure the success of Zoey Consulting Services, Inc.'s Equal Employment Opportunity and

Affirmative Action (EEO/AA) policy:

As an Equal Employment Opportunity/Affirmative Action employer, Zoey Consulting Services, Inc. provides equal employment opportunity to all employees and applicants without regard to an individual's protected status, including race/ethnicity, color, national origin, ancestry, religion, creed, age, gender, gender identity/expression, sexual orientation, marital status, parental status, including pregnancy, childbirth, or related conditions, disability, military service, veteran status, genetic information, or any other protected status.
As a federal government contractor, Zoey Consulting Services, Inc. is required to develop written Affirmative Action Plans (AAPs) annually that address the employment and career advancement of qualified women, minorities, veterans and individuals with disabilities.
A list of EEO administrators is below. Employees may contact their respective if they are interested in viewing the available portions of these plans to schedule an appointment during regular business hours. Vice President of Corporate Responsibility Sandra Evers-Manly is responsible for the overall direction of our EEO/AA compliance programs. Sylvester Mendoza, director of Diversity and Inclusion and EEO, manages these programs. Questions regarding our Diversity and Inclusion program, EEO/AA policy or AAPs may be directed to Edward Hackett.

Company confidential information
Information labeled as Company Proprietary are to be held within the company and not released by all employees. When an agreement is reached with Teaming Companies and the appropriate Teaming Agreements signed some company documents labeled proprietary can be shared with those companies.

Hiring former government employees
Zoey Consulting Services, Inc will not initiate contact federal employees with the intent of recruiting. When contacted by current federal employees Zoey Consulting Services, Inc will adhere to all federal laws regarding contacts and procedures.

Political contributions and activities
Zoey Consulting Services, Inc will never donate money to any political campaign and will never seek political favor for any purpose.

Zoey Consulting Services, Inc is committed to the security of all information and knowledge accrued in it's work. We will met with all security demands made upon us by our customer and will work to safeguard our entrusted information.

Compliance Program

Because Zoey so firmly believes in running an ethical business, we have
designed a set of compliance rules to mitigate these risks.

Employees must behave in a fair and impartial manner toward all business dealings. Therefore, the recipient must decide whether or not it is appropriate to accept all courtesies (defined above). The recipient must also promptly report their action and the courtesy to Dawn Stewart.

Employees may never ask for a courtesy and they may never accept one
that is a bribe or given to influence Zoey Consulting Services.

Employees may give courtesies, but they must adhere to the same rules
and guidelines as receiving.

Employees may accept courtesies when:

- it promotes a healthy, positive working relationship and goodwill

- the gift is reasonable and modest (flowers, fruit baskets, moderate
holiday gifts)

- it is not illegal or prohibited

- it does not create an actual or perceived conflict of interest

- it does not exceed a nominal value of $50 in a calendar year.

All employees will avoid conflicts of interest of any kind. These
include personal and professional dealings. If one seems to arise, the
employee will report the issue immediately to Dawn Stewart, Theresa
Villone, and Edward Hackett. Please cc.

Government Contracting issues Procurement Integrity/TINA Proprietary
Zoey Consulting Services, Inc customers expect not only product excellence but also the highest standards in our business practices. Our government customers, for example, expect complete and accurate pricing information in contract negotiations. In fact, the law called the Truth in Negotiations Act, known by its acronym TINA, requires government contractors to submit cost or pricing data and to certify that such data is current, accurate and complete on the date of final agreement on price, commonly referred to as the "handshake."

Compliance with TINA is an essential part of doing business with the U.S. Government. Zoey Consulting Services, Inc is fully committed to meeting its requirements, whether as a prime contractor, a team member or a subcontractor. It is the responsibility of every employee who participates in the proposal, bid preparation and contract negotiation processes to be aware of the requirements of TINA and to follow them precisely.

Cost or pricing information or data includes all facts that prudent buyers and sellers would reasonably expect to affect price negotiations significantly. Cost or pricing data are factual, not judgmental, and are verifiable.

Factual information or data includes such things as cost breakdowns on materials, subcontracted items, standard commercial items, direct labor hours and dollars and indirect expenses. It can also include:

Vendor quotations
Nonrecurring costs
Information on changes in production methods and in production or purchasing volume
Data supporting projections of business prospects and objectives and related operations costs
Unit cost trends such as those associated with labor efficiency
Make or buy decisions
Estimated resources to attain business goals
Information on management decisions that could have significant bearing on costs
Historical data upon which estimates are based.
If there is a question as to whether or not information should be disclosed, provide the information to the company's lead negotiator to make a determination. If the lead negotiator is unsure, it is best for the company to make the disclosure.

Employers will adhere to OSHA ( rules
and regulations for safe work environments.

All employees will help maintain a safe work environment by adhering to
OSHA rules and regulations.

Zoey members will keep honest books and honest billing practices for all
clients. Any discharging will be immediately rectified.

All members of Zoey will comply with federal rules regarding
non-harassment, non-discrimination, EEO, and affirmative action. Any
incident will be reported with no risk of retaliation.

Confidential information, regarding Zoey or any of our clients, will be
kept in strict confidence. There will be no sharing of information
beyond Zoey about our clients. Privacy is highly valued.

Our competitors will be treated respectfully and fairly by all Zoey
employees. Zoey will not obtain new clients from our competitors in any
underhanded manner or through any unfair business practices.

All communication made electronically must be kept entirely in
confidence and done securely.

Zoey adheres to the Foreign Corrupt Practices Act in full.

If an employee is required to report his or her status to the
government, either because he or she is still employed or because he or
she is a former employee, the employee must do so in a timely manner.

Zoey as a corporation is not allowed to donate to any political
campaigns. Private employees may, but neither Zoey funds nor time may
not be used.

All products delivered by Zoey will be of the highest standard and
created to the best of our ability.

Zoey's security is maintained by Dawn Stewart.

Company assets will be used only for purposes pertaining to Zoey.

Any employee requiring SSI or other government clearance will be
submitted to the proper background checks.

When in doubt, ask yourself: is this honest? do I feel badly about it?
Zoey trusts the integrity of its employees, but if you aren't sure,
don't take the step.

Code of Conduct

Zoey respects and trusts its entire staff to behave in a way guided by
their own values and ethics. Therefore, while we have listed many
potential problem areas for Zoey and its employees, our code of conduct
is very simple: easy-to-follow rules backed by the basic trust and
camaraderie of Zoey's leadership.

Create and deliver a product that is safe, secure, and of high quality

Treat other people and businesses the way you and Zoey would like to be
treated: fairly and respectfully

Respect the free market and respect if business does or does not come
our way

Deal honestly with the government, our competitors, and our clients

Keep honest books and records

Never mishandle information you acquire from Zoey

Make all necessary reports to any agencies you are required to make

Maintain business loyalty to Zoey Corporations, Inc.

Inquiry & Reporting

All inquiries and reports should be forwarded to *Dawn Stewart* at <>without risk of
retaliation. Zoey's management team will then investigate the report
fully. Whenever possible, the team will keep the whistle blower's
identity confidential.

Awareness Training, Program Assessment, & Evaluation

Every week at the employee's lunch meeting with Dawn Stewart, he or she
will review our policies and our ethical commitment. Every month, we
will ask for a small review of Zoey's commitment to our ethics policy
and a review of the policy itself.

Communication Plan & Awareness

At Zoey, our leadership is available to you. You may reach us at: 410-772-5370
Dawn Stewart
Theresa Villone
Edward Hackett