The people of the Javits Center are committed to providing the highest level of services to our exhibitors and attendees, and to do so while maintaining an equally high standard of conduct. The following Code expresses our values and core beliefs; while we cannot address every situation that might arise, these are the principles that should govern our behavior. The Center’s has adopted and distributed a number of more detailed employee conduct policies, which elaborate on many of the principles set forth below. We encourage you to consult those policies for more detailed guidance in specific areas.

1. Our customers and the public are entitled to honest and professional services, to accurate information about those services, and to prompt and courteous responses to all requests.
2. We will avoid any conduct or financial activity that creates, or appears to create, a conflict of interest.
3. We will protect the property of the Center, refrain from using the Center’s facilities for an unauthorized purpose, and we will maintain the confidentiality of the Center’s, and our customers’, proprietary information.
4. We will not accept any thing of value from any person or company doing business with the Center nor will we use our connection with the Center to secure special privileges for ourselves or for others.
5. We will strictly obey all state restrictions on seeking or discussing employment opportunities with those who do business with the Center, and the state restrictions that govern our employment activities after we leave our employment with the Center.
6. We will enter into contracts and purchases exclusively on the basis of price, quality, service and ability to meet the Center’s needs.
7. We will treat co-workers and other colleagues with respect and fairness, maintain a safe and productive working environment, and not allow our personal beliefs to interfere with our professional responsibilities.
8. We are committed to maintaining and enhancing our own knowledge and skills, encouraging professional development, and helping co-workers and employees under our supervision to achieve their legitimate goals within the organization.

The purchasing manager or their designee is responsible for the disposal of all obsolete, surplus and scrap equipment.

Periodically, the Purchasing Manager will request from each department a list of unneeded equipment.  The most efficient means of disposing of a particular department’s surplus equipment is to transfer it to another department where needed; this avoids the expenditure of new equipment.  Items can also be effectively disposed of by using it as a trade-in on the purchase of new equipment.  If the foregoing has been exhausted, the Purchasing Manager should arrange to sell obsolete and surplus equipment at public sale or transfer the asset through the NYS Office of General Services.  Such sales are widely advertised in order to inform prospective buyers.  Donation of the equipment to a charitable organization is also a recommended option.

Equipment can be scrapped, however, before an item is declared scrap, the Purchasing Manager should determine if it can not be reconditioned or reused, sold or donated.  There are two forms that must be completed and authorized to complete this process.  They are the Property Disposal Authorization Form (PDA) and the Property Disposal Disposition Form (PDD).

The requesting department submits an approved PDA form to the Purchasing Manager listing the items to be disposed of.  The Purchasing Manager prepares a PDD form and arrange for the equipment to be destroyed.  This act is to be witnessed (signature) by a Javits Security Officer and the Fix Asset Accountant.  However, before an asset can be sold, traded or scrapped the Purchasing Manager must obtain the approval of the CCOC V.P. of Finance.

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“Wrongdoing”, includes but is not limited to any alleged:

• Corruption
• Fraud
• Criminal Activity
• Conflict of interest
• Accounting, Internal Control or Audit Irregularities
• Intentional Reporting of False or Misleading Information
• Any violation of the Javits Center’s Code of Conduct
• Any violation of any applicable law or regulation.

Any person having information about possible wrongdoing occurring at or affecting the Javits Center is encouraged to report those concerns to the Javits Center (“Report”).  The Javits Center has an Ethics Hotline administered by an independent third party (“Lighthouse by Syntrio”) where a Report can be made in either English (844-450-0005) or Spanish (800-216-1288).  Reports may also be filed through Lighthouse by Syntrio via the internet at https://report.syntrio.com/javitscenter or emailed to reports@lighthouse-services.com, including company name with report. The Ethics Hotline is accessible 24 hours a day and provides a secure way for individuals to report concerns.

In addition to the Ethics Hotline, Reports may be filed with:

• • The Center's Ethics Officer, by phone (212-216-2122)
  • Office of the Inspector General, by phone (800-367-4448) or through its website (https://ig.ny.gov/offices/inspectorgeneral)
  • The Authorities Budget Office, by phone (800-560-1770)

Reports may be filed anonymously. However, we strongly encourage individuals filing Reports to provide their name and contact information, to better enable the Center to properly investigate allegations contained in any Report. It is also important to include as much factual detail as possible, including names of individuals involved, dates and places of relevant events, as well as sources of potential supporting materials such as e-mails, invoices or other documentation. By providing sufficient detail the Center has a better ability to fully and accurately investigate Reports.

Employees should be aware that under the Public Authorities Accountability Act of 2005, the knowing failure by an employee to report corruption, fraud, criminal activity, conflicts of interest and abuse of office may result in dismissal or other appropriate sanction.

Reports filed with the Ethics Hotline will be logged, given a unique reference number and will be promptly investigated. Individuals filing Reports with the Ethics Hotline will be provided the unique reference number and may follow up for a status of their Report.

It is critical for individuals to know that they will not suffer any adverse consequences for making a Report pursuant to this the policy or cooperating in any investigation in connection with such Report. Consequently, no Javits Center representative shall retaliate against any individual for filing a good faith Report or cooperating in an investigation, whether through threat, coercion, or abuse of authority; and, no Javits Representative shall interfere with the right of any individual by any improper means aimed at deterring disclosure of potential wrongdoing. Any attempts at retaliation or interference are strictly prohibited. Any act of alleged retaliation should be reported immediately to the General Counsel at 212-216-2122.

If requested to do so, the Javits Center will endeavor to protect the identity of any individual making a Report or cooperating in any investigation. However, under certain circumstances the Center may be required to disclose a Reporter’s or cooperating witness’s identity.

Any individual filing a Report under this policy is expected to do so upon a good faith basis. Their suspicions or concerns need not, in fact, be true, but must have a reasonable basis. Any individual who knowingly files a Report which contains false allegations shall be subject to disciplinary action, up to and including termination.

This Corporate Governance Reporting Policy is not intended to limit, diminish or impair any other rights or remedies that an individual may have under the law with respect to disclosing potential wrongdoing free from retaliation or adverse personnel action.

• Specifically, this Corporate Governance Reporting Policy does not limit any rights or remedies that an individual may have under the laws of the State of New York, including but not limited to Civil Service Law § 75-b, Labor Law § 740, State Finance Law § 191 (commonly known as the “False Claims Act”), and Executive Law § 55(1).
• With respect to any rights or remedies that an individual may have pursuant to Civil Service Law § 75-b or Labor Law § 740, any employee who wishes to preserve such rights shall prior to disclosing information to a government body outside the Javits Center, have made a good faith effort to provide the Javits Center the information to be disclosed and shall provide the Javits Center or its designee a reasonable time to take appropriate action unless there is imminent and serious danger to public health or safety. (See Civil Service Law § 75-b[2][b]; Labor Law § 740[3]).