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Ethics &

Gryphon is committed to conducting our business with honesty, integrity, trustworthiness, and accountability.

Gryphon has established a Code of Ethics and Business Conduct Policy, which reflects the company’s uncompromising position regarding the standards by which its employees are expected to present themselves when representing Gryphon in any capacity.

Gryphon is dedicated to applying the highest ethical standards in its pursuit of excellence. The principles set forth in this Code are the standards of professional conduct that are the foundation of Gryphon’s identity. It is the responsibility of each Gryphon employee to know and abide by all requirements of the Code.

All employees, including company agents or representatives, are expected to demonstrate the highest ethical conduct in all our dealings with customers, fellow employees, suppliers, business partners and the community. Each employee is expected to assume personal responsibility for ensuring that his/her conduct is legal, honest, and ethical.

Those that manage or supervise other employees have additional responsibility under this Code.

These include:

  • Making sure the Code is provided to, explained, and understood by employees
  • Providing guidance to those they manage or supervise on how they can meet the Code’s requirements
  • Promoting the standards by setting a personal example
  • Ensuring employees receive training and guidance on ethical issues
  • Monitoring compliance with the Code by Employees they manage or supervise
  • Ensuring that trading partners are aware of and comply with the policies and standards

Our Code of Conduct is designed to assist us in meeting our obligations.

This Code of Ethics and Business Conduct applies to everyone who does business on behalf of Gryphon Technologies – employees, managers, officers, and subcontractors.

Legal Compliance: We have a responsibility to comply with all applicable laws in the countries where we do business. This includes anti-bribery and anti-corruption laws such as the U.S. Foreign Corrupt Practices Act (FCPA) and similar laws in other countries and territories that we operate in. All business decisions are based on fair, reliable, and accurate data with policies and culture in place to ensure we perform ethically and legally. These policies apply to all persons working for Gryphon. Gryphon ensures that when we assess and carefully choose our trading partners that they clearly understand our commitment to the highest level of ethics, integrity, and compliance with applicable laws, rules, and regulations.

We Don’t Retaliate: Gryphon encourages employees, subcontractors, suppliers, vendors, consultants, and customers to ask questions or raise concerns about ethical violations or compliance issues that may be contrary to our values, reflect potential misconduct, and/or violate laws and regulations. We investigate and address any concerns, as needed. Retaliation against employees, subcontractors, consultants, and customers who report concerns in good faith regarding the Company’s operations will not be tolerated.

Reporting: It is the responsibility of Gryphon’s personnel to immediately report any potential violation of Gryphon’s Anti-Bribery and Anti-Corruption policy to one of the following confidential sources

Toll-free Department of Defense Inspector General Hotline: 1-800-424-9098
To submit an online complaint with the Department of Defense, please visit their website
Toll-free Gryphon’s Human Resources Hotline: 202-617-3777
To submit a question or complaint to Gryphon, please email our Ethics Committee

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Equal Employment Opportunity

Gryphon is committed to employ, without discrimination, the most qualified persons of the greatest ability. Gryphon does not discriminate against any applicant or employee because of age, ancestry, color, creed or religion, genetic information, HIV status, marital status, medical condition, national origin, physical or mental disability, race, sex, sexual orientation, gender identity and expression, veteran status, family leave status, or any other protected group status as defined by applicable law (“protected employee status”). This policy applies to all terms, conditions, and privileges of employment including recruiting, hiring, training, placement, development, promotion, transfer, compensation, benefits, employee facilities, terminations, and retirement.

Gryphon has developed and maintains an Affirmative Action Plan that establishes specific practices, procedures, and goals in support of this policy. The Plan includes the following:

  • Gryphon will recruit, hire, train, and promote qualified persons in all job classifications without regard to protected employee status.
  • Gryphon will make promotion decisions in accordance with principles of Equal Employment Opportunity by imposing only valid job-related requirements for promotional opportunities.
  • Gryphon will administer all above noted personnel actions, as well as Company-sponsored training and education, education assistance, and social recreation programs, without regard to protected employee status.

It is the responsibility of each employee to treat every fellow employee or applicant for employment with respect and in a fair, nondiscriminatory manner. We seek to comply with all applicable federal, state and local laws related to discrimination.
Anyone who believes that an employment decision has been made that does not conform with management’s commitment to equal opportunity should promptly bring the matter to the attention of the Human Resources Department. The complaint will be thoroughly investigated. There will be no retaliation against anyone who files a complaint in good faith, even if the result of the investigation produces insufficient evidence to support the complaint.

Commitment to a harassment-free workplace

Gryphon is committed to providing and maintaining a productive work environment that is characterized by mutual respect and is free from any type of harassment or discrimination, including but not limited to, that of a sexual nature or otherwise intimidating behavior, threats or assaults. In keeping with this commitment, the Company has adopted a policy of zero-tolerance with regard to employee harassment.

Gryphon maintains a strict policy prohibiting harassment in the workplace, including sexual harassment, by any employee, and by third parties such as customers, clients, vendors or visitors. Harassment may include, but is not limited to, unwelcome or unsolicited speech or conduct based upon age, ancestry, color, creed or religion, HIV status, marital status, medical condition, national origin, citizenship status, genetic information, physical or mental disability, race, sex, sexual orientation, veteran status, family care leave status or any other protected status under federal, state or local law.

Prohibited harassment includes the following examples:

  • Verbal conduct such as threats, epithets, derogatory comments, or slurs
  • Visual conduct such as derogatory posters, photographs, cartoons, drawings, or gestures
  • Written communications, statements and images which may be offensive to individuals in a particular protected group such as gender, religious or racial ethnic stereotypes, or caricatures
  • Physical conduct such as assault, unwanted touching, or blocking normal movement

Furthermore, any form of retaliation against an individual who has made, or cooperated with investigation of, a harassment or discrimination complaint is unlawful and will not be tolerated.

Gryphon will not discharge or in any other manner discriminate against employees or applicants because they have inquired about, discussed, or disclosed their own pay or the pay of another employee or applicant. However, employees who have access to the compensation information of other employees or applicants as a part of their essential job functions cannot disclose the pay of other employees or applicants to individuals who do not otherwise have access to compensation information unless the disclosure is (a) in response to a formal complaint or charge, (b) in furtherance of an investigation, proceeding, hearing, or action, including an investigation conducted by the employer, or(c) consistent with the contractor’s legal duty to furnish information. 41 CFR 60-1.35(c)

Workplace accommodations: It is Gryphon’s policy to comply with the Americans with Disabilities Act (ADA) of 1990, its amendments, and state and local laws prohibiting discrimination against people with disabilities. Gryphon shall not discriminate against any qualified employee or applicant with regard to any terms or conditions of employment because of such individual’s disability or perceived disability so long as the employee can perform the essential functions of the job with or without a reasonable accommodation. Consistent with this policy of nondiscrimination, Gryphon will provide a reasonable accommodation to qualified individuals with a disability, as defined by the ADA and state and local laws, provided that such accommodation does not constitute an undue hardship to Gryphon. Employees with a disability who believe they need a reasonable accommodation to perform the essential functions of their job are encouraged to contact the Human Resources Department.


The Department of Homeland Security (DHS) and the Social Security Administration (SSA) have established an electronic system called E-Verify, which assists Gryphon in verifying the employment eligibility of all newly hired employees. Through E-Verify, Gryphon sends information about you to DHS and SSA to ensure that all newly hired employees are authorized to work in the United States and that information from your Form I-9 match government records.

For more details on your rights and responsibilities please visit E-Verify.

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