Applies to: Facility First, Inc. and its officers, supervisors, managers and office personnel
Related policies: Website Terms and Conditions; Privacy Policy
1. Purpose of This Code
1.1 Facility First, Inc. (“Facility First”) manages facility maintenance and repair programs for multi-site businesses. The trade work in those programs is performed by independent, vetted local service providers (“Service Providers”). Clients rely on Facility First to manage requests, dispatch, approvals, verification and invoicing honestly and responsibly, and Facility First expects the Service Providers in its programs to act lawfully and safely at client locations. This Code of Ethics states the principles that guide how Facility First conducts its business.
1.2 This Code applies to Facility First’s officers, supervisors, managers, office personnel and leadership (together, “Facility First personnel”). Section 4 describes the standards Facility First expects of Service Providers. Security services in Facility First programs are delivered by McCray Global Protection Corp., a separate company, under its own policies, including its own Code of Ethics.
1.3 This Code is a statement of principles. It does not address every situation Facility First personnel may face. Facility First’s written policies, including any employee handbook, contain the detailed requirements that apply to Facility First personnel, and they control where they give more specific direction. A Service Provider’s written agreement with Facility First governs that Service Provider’s obligations.
1.4 This Code is not a contract. It does not create a contract of employment or a guarantee of employment, and it does not change the at-will nature of employment with Facility First. It does not create an employment, agency or contractual relationship with any Service Provider. It does not create rights for any client, employee, Service Provider or other person.
2. Integrity and Honest Dealing
2.1 Facility First personnel are expected to deal honestly and fairly with clients, colleagues, Service Providers, vendors, regulators and the public.
2.2 Service requests, work orders, approvals, verification records, invoices, timesheets and other business records must be accurate, complete and truthful, and must reflect what the author personally observed, did or confirmed. Facility First personnel may not approve, verify or invoice work that was not performed as recorded.
2.3 Facility First personnel may not misrepresent Facility First’s services, licenses, qualifications or capabilities, the qualifications of its Service Providers, or the scope, status or cost of any work, and may not present themselves or Facility First as holding a license, certification or insurance that they do not hold.
2.4 Facility First property, systems, accounts, equipment, and client keys, access codes and site credentials are to be used only for authorized business purposes.
3. Compliance with Laws and Licensing
3.1 Facility First expects its business to be conducted in compliance with applicable laws and regulations, including those governing contractor and trade licensing, employment, wages and hours, workplace and site safety, environmental protection and privacy.
3.2 Facility First personnel are expected to obtain and keep current the licenses, registrations and training their roles require, and to follow the rules of the regulators that oversee their work.
3.3 Facility First works with Service Providers that hold the licenses, registrations and insurance the work requires, and expects Service Providers to keep them current for as long as they perform work in Facility First programs.
4. Service Providers and Site Conduct
4.1 Service Providers are independent businesses. They are not employees or agents of Facility First, and they are responsible for their own personnel, work methods and compliance with applicable law.
4.2 Facility First selects and dispatches Service Providers based on qualifications, licensing, insurance, availability, performance and client requirements, and not on personal relationships, gifts or other improper considerations.
4.3 Facility First expects Service Providers and their personnel, while performing work in Facility First programs, to work safely and lawfully, to respect client sites, the people at them and their property, to keep client information confidential, to report accurately the work they performed, and to uphold the standards in Sections 2, 5, 6, 8 and 9.3 of this Code as they apply to their work.
4.4 Facility First personnel who visit client sites are expected to follow client site rules, to treat client personnel and members of the public with courtesy and respect, and to act within the scope of the work the client has authorized.
5. Respect and Equal Opportunity
5.1 Facility First prohibits discrimination and harassment based on any characteristic protected by law.
5.2 Facility First does not honor requests to assign, exclude or remove personnel or Service Provider personnel based on a characteristic protected by law.
5.3 Facility First personnel are expected to treat every person they deal with, including colleagues, clients, Service Providers and members of the public, without bias. Decisions about selecting, dispatching, rating or removing Service Providers must be based on qualifications, performance and business needs, not on a characteristic protected by law.
6. Confidentiality and Privacy
6.1 Facility First personnel are expected to protect confidential information belonging to Facility First, its clients and its Service Providers, including site and facility information, keys, access codes, alarm and security information, pricing, client and customer information, Service Provider information and personal information, and to use it only for authorized business purposes.
6.2 Facility First personnel may not record, photograph or share information about client sites, clients, customers, Service Providers or colleagues except as authorized by Facility First or required by law. Photographs and records collected to document or verify work are to be used only for that purpose.
6.3 Only personnel authorized by Facility First may speak to the media or make public statements on Facility First’s behalf. Facility First personnel may not post confidential client, site, pricing or Service Provider information on social media or other public forums.
7. Conflicts of Interest, Gifts and Gratuities
7.1 Facility First personnel are expected to avoid situations in which personal interests conflict, or appear to conflict, with the interests of Facility First or its clients, and to disclose potential conflicts to management. A financial, family or personal interest in a Service Provider or vendor is a potential conflict that must be disclosed.
7.2 Facility First personnel may not accept gifts, gratuities, discounts or favors from clients, customers, Service Providers or vendors that could influence, or appear to influence, their judgment, except as permitted by Facility First policy.
8. Anti-Corruption and Fair Competition
8.1 Facility First prohibits offering, paying, soliciting or accepting bribes, kickbacks or other improper payments, whether involving public officials or private parties, in connection with its business. This includes any payment or benefit offered or requested in exchange for work assignments, approvals, verification or payment of invoices.
8.2 Facility First competes on the quality of its services and does not seek business through improper means, including the misuse of another company’s confidential information.
9. Fair Treatment and Safety of Personnel
9.1 Facility First is committed to fair employment practices, including accurate timekeeping and the payment of wages in accordance with applicable law.
9.2 Facility First personnel are expected to follow safety rules, including at client sites, to report to work fit for duty and not impaired by alcohol, drugs or any other substance, and to report unsafe conditions and injuries promptly.
9.3 Facility First respects human rights in its operations. Facility First prohibits human trafficking, forced or compulsory labor and child labor, and expects the Service Providers and vendors it works with to uphold the same standards.
10. Reporting Concerns
10.1 Anyone, including Facility First personnel, clients, Service Providers, vendors and members of the public, may report a concern about a possible violation of law, this Code or Facility First policy by email to ethics@mccraygp.com.
10.2 Reports sent to ethics@mccraygp.com are received by a limited group designated by Facility First’s leadership. Facility First handles reports with discretion and shares information only as needed to review the concern, take appropriate action, comply with law or respond to legal process.
10.3 Facility First personnel may also raise concerns through the reporting procedures in Facility First’s written policies, including with a supervisor or a member of management.
10.4 Facility First reviews the concerns it receives and determines the appropriate follow-up. The nature and timing of any review depend on the circumstances.
10.5 A situation involving an immediate threat to life or safety should be reported first to 911 or local emergency services, and then to Facility First at (833) 832-6647. The ethics address is not monitored continuously and should not be used for emergencies or service requests.
10.6 Facility First personnel are expected to cooperate with internal reviews and to respond truthfully to lawful requests from regulators and law enforcement.
11. Non-Retaliation
11.1 Facility First prohibits retaliation against anyone who raises a concern in good faith or participates in a review or investigation. A concern is raised in good faith when the person reasonably believes the information is accurate, even if it later proves to be mistaken.
11.2 A report the person knows to be false is not made in good faith and may result in corrective action.
12. Protected Rights
12.1 Nothing in this Code limits any right protected by law, including the right to discuss wages, hours and other terms and conditions of employment, to file a charge or complaint with a government agency, to communicate with a government agency, or to take part in a government investigation or proceeding.
13. Accountability
13.1 Conduct that violates this Code or Facility First policy may result in corrective action, up to and including termination of employment, consistent with Facility First policy and applicable law. Nothing in this Section changes the at-will nature of employment with Facility First.
13.2 Conduct by a Service Provider that is inconsistent with the standards described in this Code may result in action under the Service Provider’s written agreement with Facility First, including removal from Facility First programs.
14. Changes to This Code
14.1 Facility First may update this Code from time to time. The updated Code will be posted on this page with a revised date.
15. Questions
15.1 Questions about this Code may be directed to ethics@mccraygp.com.
Facility First, Inc.
407 Lincoln Road
Miami Beach, FL 33139
United States