CODE OF BUSINESS CONDUCT AND ETHICS

Corporate Commitment to Integrity, Accountability, Professional Excellence, and Responsible Business Practices

Effective Date: Upon corporate approval
Policy Owner: Office of the President
Applies To: Officers, employees, contractors, consultants, representatives, and other individuals acting on behalf of Problem-To-Solution, Inc.

1. Purpose and Commitment

At Problem-To-Solution, Inc. (PTS), integrity is foundational to how we conduct business, build relationships, and deliver value.

Our commitment is to provide ethical, innovative, and results-driven solutions that help organizations strengthen their people, processes, technologies, and operations.

As a provider of management consulting, professional training, and talent solutions, we recognize that our clients place significant trust in our expertise, judgment, confidentiality, and professional conduct.

We are committed to earning and maintaining that trust through responsible business practices, transparency, accountability, and compliance with applicable laws and contractual obligations.

This Code of Business Conduct and Ethics establishes the standards expected of everyone representing PTS.

Our guiding principle is straightforward:

We solve problems responsibly, deliver solutions ethically, and never compromise integrity for business advantage.

2. Scope and Applicability

This Code applies to all individuals conducting business on behalf of PTS, including:

  • Corporate officers and directors

  • Full-time and part-time employees

  • Independent contractors and consultants

  • Temporary and contingent personnel

  • Authorized representatives and business development personnel

  • Subcontractors and business partners, where incorporated into their contractual obligations

All covered individuals are expected to understand and comply with this Code, applicable laws, client requirements, professional standards, and contractual obligations.

Where a client policy or applicable law imposes a stricter requirement, the stricter applicable standard shall govern.

3. Our Core Ethical Principles

3.1 Integrity

We conduct business honestly, communicate accurately, and uphold our commitments.

We do not engage in deception, falsification, deliberate misrepresentation, or conduct intended to mislead clients, suppliers, regulators, employees, or the public.

3.2 Accountability

We accept responsibility for our decisions, professional performance, and contractual obligations.

When problems arise, we address them promptly, document relevant facts, and pursue appropriate solutions.

3.3 Excellence

We strive to deliver high-quality services grounded in professional competence, sound judgment, and recognized industry standards.

We pursue continuous improvement and invest in developing the capabilities of our workforce and clients.

3.4 Respect

We treat individuals with dignity, professionalism, fairness, and consideration.

We encourage constructive collaboration and maintain a workplace free from unlawful harassment, discrimination, intimidation, and retaliation.

3.5 Transparency

We provide truthful information regarding our qualifications, certifications, services, pricing, performance, and business relationships.

We communicate material issues that may affect contractual performance or client expectations.

3.6 Responsible Stewardship

We protect confidential information, client resources, public funds, intellectual property, and other assets entrusted to us.

4. Compliance With Laws and Regulations

PTS conducts business in accordance with applicable federal, state, and local laws, regulations, and contractual requirements.

This includes requirements relevant to:

  • Government procurement and contracting

  • Employment, labor, and wage practices

  • Equal employment opportunity

  • Anti-corruption and anti-bribery

  • Confidentiality and data protection

  • Intellectual property and copyright

  • Business licensing and corporate registration

  • Taxation and financial reporting

  • Professional training and credentialing

  • Supplier diversity and socioeconomic certification programs

No officer, employee, contractor, or representative may knowingly authorize, request, or participate in unlawful conduct on behalf of PTS.

When legal or contractual requirements are unclear, personnel must seek guidance before proceeding.

5. Government Contracting and Public Sector Integrity

PTS recognizes that government contracting requires heightened standards of transparency, accountability, and responsible use of public resources.

When supporting federal, state, or local government clients, PTS will:

  1. Comply with applicable procurement statutes, regulations, policies, and contract terms.

  2. Respect the authority of designated government procurement and contracting officials.

  3. Avoid unauthorized commitments, improperly directed work, and transactions outside approved contractual scope.

  4. Submit accurate invoices, timesheets, cost information, and supporting documentation.

  5. Maintain records sufficient to demonstrate work performed and compliance with contract requirements.

  6. Disclose actual or potential conflicts of interest as required.

  7. Refrain from attempting to improperly influence procurement decisions.

  8. Never offer improper gifts, payments, favors, or other benefits to obtain government business.

  9. Respect mandatory contract requirements, competitive procurement rules, and authorized exception procedures.

  10. Cooperate truthfully with authorized audits, reviews, and compliance inquiries.

PTS will not knowingly misclassify services, divide procurement requirements to evade competition, backdate approvals, or submit unsupported claims for payment.

Any disagreement involving contract performance, payment, or procurement requirements shall be addressed through appropriate administrative, contractual, or legal channels.

6. Anti-Bribery, Corruption, and Improper Influence

PTS maintains a zero-tolerance policy toward bribery, kickbacks, fraud, and improper influence.

Company representatives shall not offer, provide, solicit, or accept anything of value for the purpose of improperly influencing a business decision.

Business courtesies, meals, gifts, travel, and entertainment must comply with applicable laws, client policies, contractual requirements, and company authorization procedures.

Government officials and employees may be subject to additional restrictions.

No business opportunity justifies violating these standards.

7. Conflicts of Interest

All individuals representing PTS must avoid situations in which personal, financial, or outside interests improperly interfere with their professional responsibilities.

Potential conflicts include:

  • Undisclosed financial interests in suppliers, clients, or competitors

  • Improper personal benefits arising from business decisions

  • Outside employment that compromises client obligations

  • Undisclosed relationships affecting procurement or hiring decisions

  • Unauthorized use of confidential information for personal advantage

  • Favoritism or preferential treatment inconsistent with applicable policies

Actual or potential conflicts must be disclosed promptly to the President or designated compliance representative.

Disclosure does not automatically prohibit an activity, but it allows the company to assess and manage the risk appropriately.

8. Fair Competition and Ethical Business Development

PTS competes on the strength of its capabilities, qualifications, pricing, service quality, and professional performance.

We will not engage in bid rigging, price fixing, collusion, improper market allocation, or unlawful competitive practices.

Marketing materials, proposals, capability statements, and client presentations must accurately represent the company's experience and services.

We will not knowingly misrepresent:

  • Past performance or client relationships

  • Professional qualifications or certifications

  • Training-provider authorizations

  • Supplier diversity certifications

  • Contract awards or purchasing authority

  • Staffing capacity or available resources

  • Client outcomes and performance metrics

The company will respect contractual restrictions and lawful business relationships involving clients, prime contractors, subcontractors, and other suppliers.

9. Supplier Diversity and Certification Integrity

PTS values supplier diversity and fair access to business opportunities.

The company will maintain accurate records supporting any certifications, registrations, or socioeconomic designations it holds.

All representations regarding ownership, control, management, principal office location, employee residency, business size, and eligibility must be truthful and supported by current information.

PTS will promptly review changes that may affect certification eligibility or reporting obligations.

Certifications shall never be used to facilitate misrepresentation, improper pass-through arrangements, or other prohibited procurement practices.

10. Professional Consulting Standards

PTS consultants are expected to exercise independent professional judgment and provide recommendations grounded in facts, analysis, and appropriate professional expertise.

Consultants must:

  • Understand the client's objectives and authorized scope.

  • Communicate assumptions, risks, dependencies, and limitations.

  • Distinguish verified information from estimates and professional opinions.

  • Maintain appropriate documentation of material decisions and deliverables.

  • Escalate significant risks through approved channels.

  • Respect client governance and decision-making authority.

  • Avoid presenting recommendations as approved policies or legal determinations without authorization.

  • Deliver work consistent with agreed quality and acceptance standards.

PTS will not knowingly conceal material project issues, manipulate performance data, or misrepresent the status of deliverables.

11. Professional Training and Certification Ethics

As a PMI Authorized Training Partner and provider of professional education, PTS is committed to maintaining the integrity of its instructional services.

Training personnel are expected to:

  1. Represent course objectives, eligibility requirements, and certification pathways accurately.

  2. Respect the intellectual property and licensing requirements of training and certification organizations.

  3. Deliver instruction using properly authorized materials and qualified instructors.

  4. Maintain accurate attendance, completion, and instructional-hour records.

  5. Avoid unauthorized disclosure or reproduction of protected examination content.

  6. Communicate assessment and certification policies fairly.

  7. Avoid guaranteeing examination outcomes or certifications.

  8. Protect student information and educational records.

  9. Maintain a professional learning environment free from discrimination and harassment.

PTS will ensure that descriptions of its training-provider relationships do not imply endorsements, partnerships, or authorities beyond those actually granted.

12. Staffing, Recruitment, and Talent Management

PTS is committed to fair, ethical, and responsible workforce practices.

Our staffing and talent services shall reflect the following standards:

  • Candidates are evaluated based on relevant qualifications and legitimate business requirements.

  • Employment and assignment terms are communicated accurately.

  • Credentials, qualifications, work authorization, and experience are verified as appropriate.

  • Candidate information is handled confidentially.

  • Compensation and employment practices comply with applicable law.

  • No individual is knowingly misrepresented to a client.

  • Required employment documentation is maintained appropriately.

  • Client-specific onboarding, security, and conduct requirements are respected.

PTS prohibits forced labor, human trafficking, unlawful discrimination, and exploitative recruitment practices.

13. Confidentiality and Information Security

PTS recognizes that confidential information is among the most valuable assets entrusted to the company.

Personnel must protect confidential and proprietary information belonging to PTS, clients, employees, business partners, and other authorized parties.

Confidential information may include:

  • Government and corporate financial records

  • Client systems and operational data

  • Employee and contractor information

  • Training materials and proprietary documentation

  • Contracts, pricing, proposals, and business strategies

  • Access credentials and security-related information

  • Personally identifiable information

  • Nonpublic project and procurement information

Access must be limited to individuals with a legitimate business need.

Company personnel shall not disclose, transmit, reproduce, or use confidential information without authorization.

Suspected data breaches, unauthorized access, or loss of sensitive information must be reported promptly.

These obligations continue after the conclusion of an assignment or business relationship, subject to applicable law and contractual terms.

14. Responsible Use of Technology and Artificial Intelligence

PTS supports responsible innovation and the appropriate use of emerging technologies, including artificial intelligence.

Employees and contractors using AI-enabled systems must:

  1. Comply with client policies, data restrictions, and approved technology requirements.

  2. Avoid entering confidential, restricted, or personal information into unauthorized systems.

  3. Validate material AI-generated facts, recommendations, calculations, and deliverables before professional use.

  4. Maintain appropriate human oversight and accountability.

  5. Respect intellectual property, privacy, and security obligations.

  6. Avoid fabricating evidence, citations, records, approvals, or professional credentials.

  7. Disclose AI use when required by contract, law, policy, or client instruction.

AI-generated output shall not substitute for required professional approvals, legal advice, contractual authority, or independent verification.

15. Financial Integrity, Billing, and Recordkeeping

PTS will maintain accurate financial records and supporting documentation in accordance with applicable accounting, tax, and contractual requirements.

Personnel shall not:

  • Submit false or unsupported timesheets.

  • Bill multiple parties for the same work improperly.

  • Invoice for unperformed services.

  • Misstate labor categories, expenses, or billable hours.

  • Misrepresent contractual rates or payment entitlements.

  • Falsify accounting records or supporting documentation.

  • Destroy records to obstruct a lawful review or investigation.

Disputed payments, contract modifications, and additional work must be handled through applicable contractual and approval procedures.

Company records must be retained according to relevant legal, contractual, and organizational requirements.

16. Respectful Workplace and Equal Opportunity

PTS is committed to maintaining a respectful, inclusive, and professional workplace.

The company prohibits unlawful discrimination, harassment, and retaliation.

Employment and contracting decisions shall be based on legitimate business criteria and applicable legal requirements.

Everyone representing PTS is expected to communicate professionally, resolve disagreements respectfully, and avoid abusive, threatening, or intimidating conduct.

Reasonable accommodation requests will be addressed in accordance with applicable law.

17. Health, Safety, and Professional Responsibility

PTS is committed to providing safe working conditions and respecting client workplace safety requirements.

Personnel must comply with applicable health, safety, facility access, emergency response, and security procedures.

Unsafe conditions, threats, or incidents must be reported promptly.

No employee or contractor should knowingly undertake work requiring qualifications, authorization, or safety protections they do not possess.

18. Client Relationships and Service Excellence

PTS seeks to establish long-term client relationships founded on trust, responsiveness, and measurable value.

Our personnel are expected to:

  • Communicate honestly and professionally.

  • Respect client priorities and organizational structures.

  • Document important decisions and commitments.

  • Address service concerns constructively.

  • Deliver agreed services within authorized scope.

  • Maintain appropriate professional boundaries.

  • Protect the client's reputation and confidential information.

Client relationships shall never be used to justify improper contracting, unauthorized access, or departures from established ethical standards.

19. Reporting Ethical Concerns

PTS encourages the timely reporting of suspected misconduct, policy violations, unethical behavior, fraud, security incidents, and other compliance concerns.

Concerns may be reported to the President or another designated corporate representative.

Business Ethics Contact:
Problem-To-Solution, Inc.
Email: info@problemtosolution.com
Website: www.problemtosolution.com

Reports should contain sufficient information to allow a reasonable review.

PTS will handle reports discreetly to the extent reasonably possible and consistent with its obligations to investigate and respond.

Where an allegation concerns the individual ordinarily responsible for receiving reports, the company will seek an appropriate independent review mechanism.

20. Non-Retaliation

PTS prohibits retaliation against anyone who, in good faith:

  • Reports suspected misconduct

  • Raises compliance or ethical concerns

  • Requests guidance about applicable requirements

  • Participates in an authorized investigation

  • Refuses to participate in unlawful or unethical conduct

Knowingly making a false accusation or intentionally obstructing a legitimate investigation may itself constitute a policy violation.

Good-faith reports remain protected even when an investigation does not substantiate the concern.

21. Investigations and Corrective Action

Reported concerns will be evaluated fairly and appropriately.

PTS may conduct internal reviews or retain independent professionals when necessary.

Individuals are expected to cooperate truthfully with authorized investigations and preserve relevant information.

Violations of this Code may result in corrective measures, including additional training, reassignment, disciplinary action, termination of employment or contractual relationships, or referral to appropriate authorities when warranted.

Corrective measures will be determined based on the circumstances and applicable law.

22. Leadership Responsibilities

Corporate leadership is responsible for establishing an ethical organizational culture and demonstrating compliance through conduct and decision-making.

Leadership shall:

  • Communicate ethical expectations.

  • Provide appropriate compliance guidance.

  • Support good-faith reporting.

  • Address conflicts of interest.

  • Promote responsible contracting and financial management.

  • Maintain reasonable oversight of contractors and business partners.

  • Periodically review company policies and relevant risks.

Leadership must hold itself accountable to the same ethical standards expected of all personnel.

23. Policy Administration and Review

This Code shall be reviewed periodically and updated as necessary to reflect organizational changes, applicable laws, contractual requirements, and recognized professional standards.

The President is responsible for overseeing implementation and maintaining the corporate record of approved revisions.

Any exception to an internal company policy must be lawful, documented, and approved by an authorized corporate officer. No internal exception may override applicable law or binding contractual obligations.

24. Acknowledgment of Responsibility

By representing or conducting business on behalf of Problem-To-Solution, Inc., covered individuals are expected to understand and adhere to the standards established in this Code.

Where required by company policy or contract, individuals shall provide a written acknowledgment confirming receipt and understanding.

Our Commitment

At Problem-To-Solution, Inc., business success is measured not only by the solutions we deliver, but also by the integrity with which we deliver them.

We believe that ethical leadership, professional accountability, respect for people, and responsible innovation are essential to building lasting relationships and achieving meaningful results.

Train with integrity. Consult with accountability. Deliver talent with excellence.