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Corporate Administration

Statement of Business Ethics

Our goals and commitments are based on the unifying principles of character, loyalty, trust, integrity, honesty, love and accountability.

Letter from the Chairman

To: All ServoCon ALPHA Employees and Representatives:

We make this Statement to clarify the guidelines for conducting business at ServoCon and ALPHA.

From the beginning, we have adopted basic unifying principles. They are character, loyalty, trust, integrity, honesty, love and accountability. Our goal is to promote individual “excellence.”

We expect all ServoCon ALPHA employees and representatives to use good judgment with common sense in applying these guidelines.

When demanding challenges arise, we expect our employees and representatives to bring the facts to management who will work with them toward the solution.

ServoCon ALPHA has had an excellent reputation for integrity consistent with producing superior products and services.

As we apply these principles in our relationships we will preserve our good name. In this era, a reputation with character and ability makes us extraordinary and gives us a competitive advantage.


Richard A. Coffman
Chief Executive Officer

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Commitment to Our Associates

We recognize that our commitment is to a variety of organizations. ServoCon ALPHA’s associates include employees, customers, stockholders, suppliers, and communities in which we operate, at home and abroad.

We have the following commitments to each of our associates:

To our employees: We are committed to providing an equal employment opportunity in a safe working environment with fair pay and benefits and an opportunity for self-improvement and advancement. We are committed to creating an atmosphere that encourages employees to treat one another fairly and with dignity and respect. We are genuine in relationships with our employees.

To our customers: We will continue to maintain superior quality products at competitive and fair prices, backed by dependable service and support. We are committed to “excellence” in our relationships with our customers practicing a willingness to serve.

To our suppliers: We are committed to maintain open and fair business dealings, to select sources of supply on the basis of quality, price, services offered, and policies that are similar to our “excellence” standards.

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Worldwide Business

This Statement contains principles that apply to all business, in the U.S. and abroad. We address issues that apply to our Government business, but we believe that these principles apply to our business everywhere. We realize that some business is located in countries that have additional requirements to those included here. The representatives over these areas shall be made aware and shall consult appropriate administrators to prevent violation of all local applicable laws, rules, and regulations.

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Corporate Administration Guidelines

ServoCon ALPHA has adopted these Guidelines that describe how Directors will exercise judgment to act in the best interests of ServoCon ALPHA. The Board oversees performance and ensures that long-term interests of stockholders are served. The Board shall perform duties and responsibilities according to the laws of the State of Virginia.

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Financial Integrity

The integrity of our business is reflected in our financial practices. We subscribe to completeness, timeliness, accuracy, and honesty in our financial operations. Employees contribute to the integrity of our financial reports, with accurate entries and reporting of our financial status. We have processes, policies, and procedures to ensure that employees share the responsibility of maintaining ServoCon ALPHA’s financial stability.

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Conflicts of Interest

The proper operation of business requires that employees, and representatives are commissioned to act on behalf of ServoCon ALPHA. Employees shall avoid investments or activities that are detrimental to that commission. Most “conflicts of interest” are easily identified. Conflicts of interest occur when an employee takes on work from a competitor, customer, or supplier. The best policy is to avoid any business arrangement with our customers, suppliers, or competitors outside of ServoCon ALPHA’s business.

We realize the potential for conflicts of interest which may be difficult to evaluate and resolve. Under such circumstances, the matter should be brought to the attention of management so that we can resolve all questionable matters quickly.

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Accountable Use of Assets

We expect employees to be accountable and ensure the proper use of the company's and customer's property, electronic systems, information resources, materials, facilities, and equipment. Employees must use and maintain our assets with extreme care and guard against waste, abuse, and misuse. Employees shall not remove assets from the company’s premises without management's permission.

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Protection of Data

Employees have access to confidential information and are trusted to safeguard it. The confidential information includes pricing, marketing, proposal, and information related to how we provide services or make products. Our drawings and data marked “Proprietary,” or “Confidential,” are to be carefully protected. Handling, marking, and disclosure, of similar data provided to us by customers, vendors, or teammates also requires strict adherence to these guidelines.

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Acquisition Integrity

Employees will not accept or offer “kickbacks” of any kind including any money, fee, commission, credit, gift, gratuity, or compensation of any kind, for the purpose of improperly obtaining or rewarding favorable treatment in either the selling or procurement activities of the Companies.

Acquisition integrity applies to employees and affiliates who participate personally in the acquisition process. We are required to ensure that all those who, on our behalf, are not compromised by giving or receiving anything of value or by previous employment or affiliation. Our position in this regard is aligned with U.S. Federal Acquisition Regulations.

Employees shall not accept or offer either entertainment or gifts that could disrupt the objectivity in conducting business. Public disclosed transactions should never be compromising to anyone involved. Furthermore, “business courtesies” shall not be offered to employees of the U.S. Departments of Defense or Energy, NASA, or to a U.S. Government employee.

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International Anti-Bribery Act

The International Anti-Bribery Act covers these areas:

Unlawful Payments: The Act makes it unlawful for the Companies or any employee or representative of the Companies to make an offer, payment, or promise of payment of anything of value for corrupt purposes.

Accounting Standards: The Companies are required to keep books, records, and accounts that accurately and fairly reflect all transactions.

The Act goes into detail on each of these items on the U.S. Department of Justice website:

Employees with questions about any section of the Act shall bring them to the attention of management.

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Anti-Trust Regulation

ServoCon ALPHA management expects employees and representatives to comply with U.S. and foreign anti-trust laws. Violations may result in penalties to the individuals, as well as to the Companies. Agreements or understandings that limit or restrict competition may be unlawful. These could be agreements affecting prices, terms or conditions of sale, production, distribution, territories, or customers. Therefore, contracts, agreements, or understandings with suppliers and customers involving exclusive business, sales, or other restrictive agreements should only be done with the approval of management.

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Promotional: Commercial and Political

If an employee engages in any promotional activity interpreted as endorsing a commercial group, private venture, product, or political organization, it must be done on the employee’s own time, not as a representative of ServoCon ALPHA. The employee shall avoid even the appearance of participating as a representative of ServoCon ALPHA.

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Behavioral Integrity

We have adopted a number of other policies that establish our vision. Employees and representatives shall conform to these guidelines. They reinforce mutual trust, confidence, and integrity. Our vision for “excellence” has been posted in the front office lobby on a bronze plaque as a cornerstone since the foundation of the Companies.

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Implementation of Unifying Principles

Our commitment to ethical business conduct requires the cooperation of every employee and representative. We hold ourselves to the highest standards realizing that the Company’s best interests are our own. We strive to avoid any deviation from these standards. To help us handle difficult situations, we have established the following procedures:

We have a strong commitment to an “open-door” policy. This means that employees are encouraged to take advantage of the availability of any manager or supervisor for consultation on ethical issues as they arise. All managers will keep open communication with employees regarding ethics.

Confidential Ethics Reporting:
In cases where employees suspect a violation of our policy that has not been adequately addressed by supervision, they are advised to call a manager. Specific managers have been designated as our Ethics Support Team for these situations.

Accounting and Auditing Complaints:
In any case where an employee believes that financial statements are materially misstated as a result of intentional acts or material weaknesses in our systems of control, and such suspicions have not been satisfactorily addressed, they are advised to contact a manager. Communications are held in confidence with assurance that matters shall be investigated. Retaliation against anyone who has reported an ethics concern is not allowed and will be grounds for dismissal.

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