Executive-Level Oversight of Compliance
Sierra Nevada Global Logistics (SNVGL) designates executive-level individuals to oversee compliance. Our Chief Compliance Officer (CCO) ensures that our company adheres to all applicable laws, regulations, and internal policies.
The Chief Compliance Officer's responsibilities include:
1. Leadership and Oversight: Providing strategic leadership and oversight of our compliance and ethics program to ensure it is effective and continuously improving.
2. Policy Development: Developing, implementing, and maintaining comprehensive compliance policies and procedures that align with legal and regulatory requirements.
3. Training and Education: Ensuring that all employees receive regular training on compliance issues and understand their responsibilities under our compliance program.
4. Monitoring and Auditing: Overseeing regular audits and monitoring activities to detect and prevent non-compliance and unethical behavior.
5. Reporting and Communication: Establishing clear channels for reporting compliance concerns and ensuring issues are addressed promptly and effectively.
6. Advisory Role: Acting as an advisor to the executive team and the Board of Directors on compliance-related matters and emerging regulatory trends.
Our commitment to compliance and ethical conduct is integral to our operations, and the Chief Compliance Officer plays a crucial role in maintaining the integrity and transparency of our business practices.
Anti-Bribery and Gift Policies
Sierra Nevada Global Logistics (SNVGL) has stringent policies and procedures that prohibit bribery and regulate giving gifts, entertainment, and travel to government recipients. These measures ensure that our business practices are ethical, transparent, and compliant with all applicable laws and regulations.
Key elements of our policies include:
1. Anti-Bribery Policy: We have a zero-tolerance policy towards bribery. All employees and stakeholders are strictly prohibited from offering, giving, receiving, or soliciting anything of value to improperly influence the actions of government officials or any other individuals.
2. Gifts and Entertainment: Our policy clearly defines acceptable limits on gifts and entertainment. Any gifts or entertainment provided to government recipients must be modest, infrequent, and compliant with all relevant laws and regulations.
3. Travel Expenses: Reimbursement or payment of travel expenses for government officials is highly restricted and must be pre-approved by our compliance team. Such costs must be reasonable, necessary, and directly related to legitimate business purposes.
4. Training and Awareness: We regularly train all employees to ensure they understand and adhere to our anti-bribery and gift policies. This training includes practical guidance on handling situations involving gifts, entertainment, and travel for government recipients.
5. Monitoring and Enforcement: Compliance with these policies is monitored regularly. Any violations are taken seriously and may result in disciplinary action, including termination of employment.
By adhering to these policies, SNVGL ensures that our interactions with government officials are conducted with the highest level of integrity and in full compliance with legal requirements.
Accountability for Compliance
Sierra Nevada Global Logistics (SNVGL), our employees, and third-party representatives are held accountable for adhering to the organization’s policies. We have precise mechanisms in place to ensure compliance and to address instances of non-compliance through disciplinary or corrective action.
Critical aspects of our accountability measures include:
1. Clear Expectations: All employees and third-party representatives are informed of our policies and their responsibility to comply with them from the outset of their engagement with SNVGL.
2. Regular Training: We provide ongoing training to ensure everyone understands our policies, the importance of compliance, and the potential consequences of non-compliance.
3. Monitoring and Audits: We conduct regular monitoring and audits to detect deviations from our policies. This helps maintain high standards of ethical conduct and compliance.
4. Reporting Mechanisms: We have established secure and confidential channels for reporting suspected non-compliance or unethical behavior. These channels are accessible to both employees and third-party representatives.
5. Disciplinary Actions: In cases of non-compliance, appropriate disciplinary or corrective actions are taken. This may include retraining, formal warnings, suspension, employment termination, or business relationships with third-party representatives.
6. Consistent Enforcement: We ensure that our policies are enforced consistently and fairly across the organization, regardless of the position or relationship of the individual involved.
By holding everyone accountable for compliance, SNVGL reinforces its commitment to ethical business practices and the integrity of our operations.
Human Rights and Labor Standards Policy
Sierra Nevada Global Logistics (SNVGL) is committed to upholding the highest human rights and labor practices standards. This policy outlines the company's commitment to comply with international laws prohibiting forced labor, slavery, human trafficking, and illegal child labor.
Scope
This policy applies to all contractors, consultants, suppliers, and third parties acting on behalf of SNVGL.
Policy Statement
SNVGL strictly prohibits all forms of forced labor, slavery, human trafficking, and illegal child labor. The company is committed to ensuring that all business operations and supply chains are free from these unethical practices.
Definitions
Responsibilities
Reporting Violations
Employees, representatives, and third parties are encouraged to report any violations or suspected violations of this policy to their supervisor or the designated compliance officer. Reports can be made anonymously and without fear of retaliation.
Consequences of Violation
Violations of this policy will be taken seriously and may result in disciplinary action, including termination of employment or contract and potential legal action.
Due Diligence and Risk Assessment
SNVGL will conduct regular due diligence and risk assessments to identify, prevent, and mitigate risks of forced labor, slavery, human trafficking, and illegal child labor in its operations and supply chains.
Review and Amendments
This policy will be reviewed periodically and may be amended to ensure continued compliance with legal and ethical standards.
Anti-Corruption Risk Assessment Policy
Sierra Nevada Global Logistics (SNVGL) is committed to maintaining the highest standards of integrity and compliance with anti-corruption laws and regulations. This policy outlines the procedures for conducting periodic anti-corruption risk assessments to identify, assess, and prioritize key compliance risks and remediation needs.
Scope
This policy applies to all employees, contractors, consultants, suppliers, and third parties acting on behalf of SNVGL.
Policy Statement
SNVGL will conduct periodic anti-corruption risk assessments to identify, assess, and prioritize risks related to corruption and bribery. The goal is to implement effective risk mitigation and remediation strategies to ensure compliance with legal and ethical standards.
Risk Assessment Procedures
Responsibilities
Reporting and Documentation
Maintain comprehensive documentation of the risk assessment process, including the findings, action plans, and implementation status. Report critical risks and remediation efforts to senior management and the Board of Directors.
Review and Amendments
This policy will be reviewed periodically and may be amended to ensure continued effectiveness and compliance with legal and ethical standards.
Compliance and Anti-Corruption Training Policy
Purpose
Sierra Nevada Global Logistics (SNVGL) ensures that all relevant individuals are educated about compliance and anti-corruption standards. This policy outlines the requirements for periodic compliance training, including anti-corruption training.
Scope
This policy applies to the following individuals and groups:
Policy Statement
SNVGL requires all specified individuals and groups to participate in periodic compliance training, including anti-corruption training. The training ensures they understand and adhere to the company’s compliance standards and anti-corruption policies.
Training Requirements
Training Content
Training programs will cover:
Tracking and Documentation
SNVGL will maintain records of all training sessions, including participant attendance and completion dates. Training records will be reviewed periodically to ensure compliance with this policy.
Responsibilities
Review and Amendments
This policy will be reviewed periodically and updated to ensure its effectiveness and compliance with legal and regulatory standards.
Anti-Bribery and Anti-Corruption Certification Policy
Purpose
Sierra Nevada Global Logistics (SNVGL) is dedicated to maintaining the highest ethical standards and complying with all anti-bribery and anti-corruption laws and regulations. This policy certifies that SNVGL will not engage in any practices that violate these standards.
Policy Statement
SNVGL certifies that it will not, directly or indirectly, offer, pay, promise, or authorize the payment of any money, gift, benefit, or anything of value to a Government official (as defined below) for any of the following purposes:
(i) Government Official Definition:
(ii) Prohibited Purposes:
Certification Requirements
All employees, contractors, consultants, and third parties acting on behalf of SNVGL are required to certify their adherence to this policy and confirm that they will not engage in any prohibited activities as outlined above.
Responsibilities
Monitoring and Enforcement
SNVGL will implement appropriate measures to monitor compliance with this policy, including periodic audits and reviews. Any violations will be addressed promptly, with appropriate corrective actions taken.
Review and Amendments
This policy will be reviewed periodically and may be amended as necessary to ensure continued compliance with legal and ethical standards.
Policy Title: Prohibition on the Provision of Covered Telecommunications Equipment or Services to the Government
Policy Number: SNVGL-TEC-001
Effective Date: 14 December 2023
Policy Statement:
Sierra Nevada Global Logistics (SNVGL) is committed to ensuring the security and integrity of its operations and services. According to federal regulations and best practices, SNVGL will not provide the government with any covered telecommunications equipment or services.
Purpose:
This policy complies with Section 889 of the John S. McCain National Defense Authorization Act for Fiscal Year 2019 (NDAA FY19), which prohibits the use of certain companies' covered telecommunications equipment or services due to security concerns. This policy ensures that SNVGL does not provide, use, or contract for covered telecommunications equipment or services in federal government contracts.
Scope:
This policy applies to all employees, contractors, and partners of SNVGL involved in the procurement, provision, and management of telecommunications equipment and services.
Definitions:
Policy Requirements:
Responsibility:
The Compliance Officer is responsible for overseeing the implementation and enforcement of this policy. All department heads are responsible for ensuring their teams understand and adhere to this policy.
Non-Compliance:
Non-compliance with this policy may result in disciplinary action, up to and including termination of employment or contracts.
Approval:
This policy has been approved by the CEO and the Board of Directors of SNVGL.
Sierra Nevada Global Logistics (SNVGL) Anti-Inversion Policy
Policy Title: Affirmation of Domestic Corporate Status
Policy Number: SNVGL-ADC-001
Effective Date: 14 December 2023
Policy Statement:
Sierra Nevada Global Logistics (SNVGL) is committed to maintaining its status as a domestic corporation within the United States. SNVGL affirms it is not an inverted domestic corporation and adheres to all regulations and requirements to sustain this status.
Purpose:
This policy affirms SNVGL's commitment to remaining a domestic corporation as defined by U.S. federal regulations, ensuring compliance with relevant laws, and maintaining transparency with our stakeholders.
Scope:
This policy applies to all SNVGL operations, subsidiaries, and affiliates.
Definitions:
Policy Requirements:
Responsibility:
The Compliance Officer is responsible for overseeing the implementation and enforcement of this policy. The Board of Directors is responsible for reviewing and approving any changes to the corporate structure to ensure compliance with this policy.
Non-Compliance:
Non-compliance with this policy may result in disciplinary action, up to and including termination of employment or contracts.
Approval:
This policy has been approved by the CEO and the Board of Directors of SNVGL.
Policy Title: Equal Opportunity Compliance Reports
Policy Number: SNVGL-EOCR-001
Effective Date: 14 December 2024
Policy Statement:
Sierra Nevada Global Logistics (SNVGL) is committed to maintaining an inclusive, diverse, and equitable workplace. To support this commitment, SNVGL will regularly produce Equal Opportunity Compliance Reports that monitor and ensure adherence to all relevant Equal Opportunity laws and regulations.
Purpose:
This policy outlines the procedures for preparing, reviewing, and disseminating Equal Opportunity Compliance Reports. These reports will help SNVGL monitor compliance, identify areas for improvement, and demonstrate our commitment to equal opportunity in employment.
Scope:
This policy applies to all departments and employees within SNVGL.
Definitions:
Policy Requirements:
Responsibility:
The HR Department and the Compliance Officer are responsible for the preparation, review, and dissemination of the Equal Opportunity Compliance Reports. Senior management and department heads are responsible for implementing action plans and ensuring compliance within their teams.
Non-Compliance:
Non-compliance with this policy may result in disciplinary action, up to and including termination of employment or contracts.
Approval:
This policy has been approved by the CEO and the Board of Directors of SNVGL.
Policy Title: Affirmative Action Compliance
Policy Number: SNVGL-AAC-001
Effective Date: 14 December 2024
Policy Statement:
Sierra Nevada Global Logistics (SNVGL) is dedicated to promoting diversity and inclusion in the workplace. As part of this commitment, SNVGL will implement and maintain an Affirmative Action Program (AAP) to ensure compliance with all applicable affirmative action laws and regulations, and to foster equal employment opportunities for all individuals.
Purpose:
The purpose of this policy is to outline SNVGL's commitment to affirmative action and to establish procedures for developing, implementing, and maintaining an effective Affirmative Action Program.
Scope:
This policy applies to all employees, applicants for employment, and all departments within SNVGL.
Definitions:
Policy Requirements:
Responsibility:
The Compliance Officer and the Human Resources (HR) Department are responsible for the development, implementation, and maintenance of the AAP. Managers and supervisors are responsible for supporting affirmative action efforts within their teams.
Non-Compliance:
Non-compliance with this policy may result in disciplinary action, up to and including termination of employment or contracts.
Approval:
This policy has been approved by the CEO and the Board of Directors of SNVGL.
Policy Title: Buy American Certificate Compliance
Policy Number: SNVGL-BAC-001
Effective Date: [Insert Effective Date]
Policy Statement:
Sierra Nevada Global Logistics (SNVGL) is committed to supporting American manufacturing and ensuring compliance with the Buy American Act (BAA) and other related regulations. As part of this commitment, SNVGL will provide Buy American Certificates for applicable products and services to affirm our compliance with federal procurement requirements.
Purpose:
The purpose of this policy is to outline the procedures for issuing Buy American Certificates, ensuring that SNVGL meets the requirements of the Buy American Act and other relevant laws and regulations.
Scope:
This policy applies to all products and services offered by SNVGL that are subject to the Buy American Act.
Definitions:
Policy Requirements:
Responsibility:
The Compliance Officer and the Procurement Department are responsible for overseeing the implementation and enforcement of this policy. They are also responsible for issuing Buy American Certificates and ensuring that all products and services comply with the Buy American Act.
Non-Compliance:
Non-compliance with this policy may result in disciplinary action, up to and including termination of employment or contracts.
Approval:
This policy has been approved by the CEO and the Board of Directors of SNVGL.
Policy Title: Certification Regarding Responsibility Matters
Policy Number: SNVGL-CRM-001
Effective Date: 14 December 2024
Policy Statement:
Sierra Nevada Global Logistics (SNVGL) is dedicated to maintaining the highest standards of integrity, responsibility, and compliance in all business dealings. In alignment with Executive Order 12689, SNVGL requires certification regarding responsibility matters to ensure that all individuals and entities associated with the company adhere to ethical and legal standards.
Purpose:
The purpose of this policy is to outline the requirements for certification regarding responsibility matters, ensuring compliance with Executive Order 12689 and promoting responsible business practices within SNVGL.
Scope:
This policy applies to all employees, contractors, subcontractors, and suppliers associated with SNVGL.
Definitions:
Policy Requirements:
Responsibility:
The Compliance Officer is responsible for overseeing the implementation and enforcement of this policy. All department heads and managers are responsible for ensuring compliance within their teams.
Approval:
This policy has been approved by the CEO and the Board of Directors of SNVGL.
Effective Date: [Insert Date]
The purpose of this policy is to affirm Sierra Nevada Global Logistics' (SNVGL) commitment to environmental transparency and responsibility by publicly disclosing our greenhouse gas (GHG) emissions. This policy outlines the standards and procedures for conducting, reporting, and publicly sharing our GHG emissions inventory.
This policy applies to all operations of SNVGL and covers all GHG emissions generated by the company.
This policy will be reviewed annually and updated as necessary to reflect changes in regulations, best practices, and organizational values. Any amendments to this policy will be communicated to all employees, partners, and stakeholders.
Authorized by:
Evan Kirkwood
CEO
Sierra Nevada Global Logistics (SNVGL)
Sierra Nevada Global Logistics LLC - SDVOSB
1650 O Farrell Street, Reno, Nevada 89503, United States
Copyright © 2024 Sierra Nevada Global Logistics - All Rights Reserved.
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