How we do business with customers, suppliers and government buyers.
Adopted October 29, 2026
Honest dealingWe tell the truth in quotes, listings and invoices.
Fair competitionWe set our own prices and never rig a bid.
Government complianceWe verify country of origin before we certify.
Speak up safelyNo one is penalized for raising a concern in good faith.
Purpose and scope
Aqua Terra Backyard (8 Van Buren Ave, Centereach, NY 11720) sells pool, spa and outdoor living products, and also supplies parts to government contractors. This policy sets the standards we follow in every business dealing. It applies to owners, employees, contractors and anyone acting on the company's behalf.
Code of conduct
We deal honestly and fairly with customers, suppliers, competitors and government buyers. In practice, that means:
We tell the truth in quotes, certifications, listings and invoices, and we correct mistakes as soon as we find them.
We keep accurate business records and never alter or backdate them.
We avoid conflicts of interest and disclose any personal interest in a transaction.
We treat people with respect and do not tolerate harassment or discrimination.
No one is penalized for reporting a concern in good faith.
We follow every law and regulation that applies to our business.
Federal procurement laws
When we quote or sell to government contractors, we follow the rules attached to the contract. We do not certify anything we have not verified.
Berry Amendment and Buy American Act: We confirm where a product is made before certifying domestic origin, using the manufacturer's documentation or written confirmation from our supplier.
Trade Agreements Act (TAA): We offer only products made in the United States or a TAA designated country when a quote requires it.
Country of origin: We record the country of origin for every product we quote to a government buyer and keep the supporting documents.
FAR and DFARS flowdowns: We read the flowdown clauses in each request for quote and purchase order, and we do not accept an order we cannot comply with.
Bid integrity, antitrust and anti-bribery
We set our own prices independently and compete fairly.
We never discuss prices, bids or whether to bid with a competitor, and we never ask another company to bid or not bid.
We do not share a quoted price with anyone outside the company before the contract is awarded, unless the law requires it.
Under the Procurement Integrity Act, we do not ask for or use non-public bid or source selection information.
Under the Foreign Corrupt Practices Act and U.S. bribery laws, we never offer or accept bribes, kickbacks or gifts meant to influence a business decision, and we follow federal limits on gifts to government employees.
Export controls and prohibited equipment
ITAR and EAR: We check whether each product is subject to the International Traffic in Arms Regulations or the Export Administration Regulations before it ships outside the United States, and we do not export without the required classification or license.
Prohibited telecom and surveillance equipment (FAR 52.204-25): We do not offer or deliver equipment or services from Huawei, ZTE, Hytera, Hikvision, Dahua or their affiliates to government customers, and we confirm that products we quote do not contain their components.
Vendor screening, records and personnel
Vendors and subcontractors: Before we buy for a government order, we confirm the supplier's identity, check that the product matches the part number requested, and obtain written confirmation of country of origin. We flow required contract terms down to them.
Records: We keep quotes, certifications, supplier confirmations, purchase orders and invoices for at least five years.
Personnel: Today the company is just its two owners. If we hire employees or use contractors, we will run identity and background checks appropriate to the role before giving anyone access to customer data, payments or government orders.
Training: Everyone who handles government orders reviews this policy when they start and once a year.
Human rights, workplace safety and the environment
We support the human rights of everyone in our supply chain and run a safe business.
Human rights: We do not use forced, bonded or child labor, and we do not take part in or tolerate human trafficking or modern slavery. We will not knowingly buy from a supplier that does.
Equal opportunity: We make employment decisions without regard to race, color, religion, sex, national origin, age, veteran status, sexual orientation, gender identity, disability or any other protected status.
Safe workplace: We keep our workplace safe and free from the illegal use, possession or sale of controlled substances, and we follow environmental, health and safety laws, including the rules for storing and shipping regulated products.
Environment: We handle products and packaging responsibly and work to minimize waste.
Global trade, money and product integrity
Anti-boycott: We do not take part in any foreign economic boycott or restrictive trade practice that U.S. law prohibits.
Anti-money laundering: We follow anti-money laundering laws and do not do business with anyone, or in any transaction, that would involve us in money laundering.
Counterfeit parts: We buy from manufacturers and established distributors. If we learn a product may be counterfeit or non-conforming, we stop the sale, notify the customer and the manufacturer, and keep it out of any delivery. We never knowingly sell counterfeit, used or altered goods as new.
Conflict minerals: We resell finished goods and do not manufacture products. When a customer asks about gold, tantalum, tin or tungsten in a product, we pass the question to the manufacturer and share the answer.
Information, data and artificial intelligence
Confidential information: We use customer, supplier and government information only for the purpose it was given for, and we follow data privacy laws.
Information security: We protect our business systems with strong unique passwords and two-factor sign-in, and we promptly tell affected customers and partners if we learn of unauthorized access to their data.
Intellectual property: We respect patents, copyrights and trademarks.
Inside information: We never use non-public information learned in business as the basis for trading securities.
Artificial intelligence: We use AI tools only to assist our people. A person reviews anything before it goes to a customer or government buyer, and if we ever develop or use AI on a customer's behalf, we follow the U.S. Department of Defense Ethical Artificial Intelligence Principles.
Reporting concerns
Anyone who sees a possible violation of this policy should tell Eric Borden, CEO, at 631-678-6506 or eric@aquaterrabackyard.com. Reports are handled promptly, and no one is retaliated against for raising a concern in good faith.
We review this policy once a year and correct any gap we find.
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