RMCO's Code of Ethics and Conduct

Uphold the law

The bare minimum that is required of us is to follow and uphold the letter and spirit of the law. I’m sure you’re aware of the laws that pertain to most Connecticut businesses, such as the Occupational Safety and Health Administration (OSHA) directives and the Connecticut State and Federal Labor laws. The nature of our business subjects us to the FAR and its defense supplement (DFARS), which contain some additional restrictions.

The main focus of the FAR is contract pricing. The government does not want to overpay for stuff. Its second focus is on various programs aimed at helping small businesses, and protecting the people who actually do the work. Most of it is common sense: don’t commit fraud, don’t engage in bribery. Some of it may not be immediately obvious. For example, did you know that telling people from other companies the amount we bid on a contract (won or lost) could be considered price collusion? Were you aware that accepting gifts from our subcontractors could be considered a kickback? As our company continues to grow, we will find ourselves subject to many more of these regulations, as well as more scrutiny.

DFARS can be summed up as buying materials only from countries on a white list. The purpose of DFARS is to prevent the US defense industry from the vulnerabilities of being overly dependent on foreign sources of supply, and while it can be a hassle it has a side-effect from which we benefit: protectionism. We don’t have to compete with cheap labor from third world countries, in return we agree to jump through the hoops they set up for us. So while DFARS compliance may seem like just a pain, it’s actually to your benefit.

Maintain a safe & healthy working environment

 Even more important than the law is your life, right? We’ve never had any deaths on premises (and we’d like to keep it that way!) but we have had a few accidents, including some fairly severe ones. It might be helpful if you would all keep in mind the fact that the machines we work with could be accurately described as giant killer robots.

Perhaps more insidious are the diseases associated with the machining industry at large, namely cancers and respiratory ailments. Aerosolized machine coolant is associated with an increased risk of lung ailments like asthma and pneumonia, especially when the coolant is contaminated with bacteria. Inhaling particulate metals like aluminum and beryllium increases the risks of various cancers, especially lung, stomach and esophageal cancers. While it is next to impossible to prevent all exposure to these materials, every effort should be made to minimize your exposure as well as those around you. Masks and gloves are available and their use is recommended, as are common sense practices like keeping a clean work station and regularly scheduled coolant changes. Complete information on all of the chemicals you might come in contact with at Richard Manufacturing is available in the form of Material Safety and Data Sheets (MSDS), which are kept in the file room.

We are now required by OSHA to keep track of and annually report on occupational injuries and illnesses, and we’ve formed an official Safety Committee to do so. There are various informational booklets and posters in the lunch room for your information, but if you can’t find the answer you’re looking for then you are encouraged to contact a member of the Safety Committee with your concerns. If you see someone doing something that you think isn’t safe, you are obligated to confront or report them. Don’t think of it as tattling, think of it as possibly saving their life. You can do so anonymously, just drop an envelope addressed to the safety committee into the suggestions box by the time clock.

Treat people with respect

Everyone deserves to be treated with dignity and respect everywhere they go, that’s just human decency. This applies doubly so to your coworkers. People need a positive environment to reach their full potential, we can’t afford to let anyone’s talents go to waste. When you distract someone, you’re actually robbing the company of their mental bandwidth. You may think it’s funny, but you can’t know for sure ahead of time that they will agree. Which is all besides the fact that the law requires us to be an equal opportunity employer, and to have an affirmative action plan in place. Therefore, there can be no tolerance for harassment or discrimination of anyone in any form. Incidents you observe must be reported, or you could be implicated as an accessory.

Accurate record keeping

We place a high value on our records for several reasons. We’re required to keep some records on file for our customers, specifically our inspection records and process certifications. We use our labor time records to increase the competitiveness of our bids, to win us more contracts and grow our company. Our job travellers are used as a form of communication, as jobs make their way between different departments within the shop. They’re also used to improve our manufacturing method, each traveller has a “suggestions” box at the end so anyone can add their opinion for consideration next time around. As manufacturing methods and technologies evolve, we have to evolve with them and be constantly assessing ourselves for efficiency and quality and accurate record keeping enables us to do so.

Proper use of company and customer assets, protection of proprietary information

During the course of your normal work day, it is likely that you will come in contact with information properties belonging to our customers. Whether physical or digital, these assets are not our property and must be treated with respect. Unauthorized distribution of Sikorsky property such as blueprints is grounds for legal action, not just from Sikorsky but also from the federal government under the International Traffic in Arms Regulations (ITAR). Because we do defense work you must be extremely diligent about only sharing this information with U.S. persons who are authorized and require the information to complete work for us.

Company resources, including time, material, equipment and information, are provided for company business use. Occasional personal use is permissible, as long as it does not affect job performance or cause a disruption to the workplace.

Report any concerns.

Hopefully all of this stuff was pretty much common sense to everyone. If you have any pressing concerns related to the things discussed above, please contact a supervisor. Non-urgent concerns or ideas are welcomed in the suggestion box.

And, since we've decided to post this on our website in the interest of transparency, feel free to email or comment below.