Ethics in Telecom Sector Essay Sample

10 October 2017

To All Employees of IEC Telecom Company and its Subordinates. The IEC Telecom Company Code of Business Conduct. which is explained and summarized in this brochure. is a usher for every Company Director. officer. employee and agent in using legal and ethical patterns to their mundane work. The Code describes non merely our criterions of unity but besides some of the specific rules and countries of the jurisprudence that are most likely to impact us. There is no quality more of import than unity. This applies to a concern merely as it does to an person. Integrity is a nucleus value in our Code of Business Conduct. Certain state of affairss may originate which are non covered in our Code of Business Conduct. If you have any inquiries refering the legality or properness of an action. or the significance of the Code. you should reach the Company’s Law Department. Conformity with the jurisprudence and honestness and unity in our traffics with others are non to be sacrificed in the name of net incomes. Management does non and will non excuse any such action. Our success will be attained through conformity with the jurisprudence. traffics attesting equity and unity and a committedness to quality. We expect your heart-whole support of these Company values and rules.

Erwan P. Emilian Chief Executive Officer IEC Telecom Company

General Policy Regarding Laws and Business Conduct
The Code of Business Conduct of IEC Telecom Company ( the “Company” ) consists of the policies associating to the ethical and legal criterions of behavior to be followed by Directors. employees and agents of the Company in the behavior of its concern. The Code of Business Conduct applies to all Company Directors. employees and agents and all Company activities throughout the universe. except where specifically indicated. It is the policy of the Company to follow with applicable jurisprudence. Some Company policies are based on the demands of applicable jurisprudence and others are merely good moralss and concern sense. The Company is organized under Gallic jurisprudence and its securities are publically traded. This means that the Company is chiefly governed by Gallic jurisprudence. and that Gallic jurisprudence applies to some of the Company’s concern outside France.

The Company does concern in many states around the universe and. as a good concern citizen. we must detect the applicable Torahs of the states in which the Company does concern. Sometimes there is a struggle between Gallic jurisprudence and the jurisprudence of one of the other states in which the Company operates. In these state of affairss the Company will decide the struggle with the advice and advocate of the Law Department. It is the personal duty of each Company Director. employee and agent to detect the criterions of behavior and other demands of the Code of Business Conduct whether or non these criterions and demands are besides imposed by jurisprudence. Any Director. employee or agent who does non follow with these criterions and demands is moving outside the range of his or her employment. duties or bureau. The underlying formal policies themselves have more item than is contained in this brochure. It is the duty of each Director. employee or agent to familiarise himself or herself with the inside informations of the policies of the Company that apply to his or her assigned responsibilities. If an employee wants to mention to the complete policies summarized in this brochure. they are available in electronic and written signifier. If a Director. employee or agent has any inquiries about the policies summarized in this brochure. he or she should reach the Law Department.

Ethical Business Practices
Company policy requires Directors. employees and agents to detect high criterions of concern and personal moralss in the behavior of their responsibilities and duties. Directors and employees must pattern carnival covering. honestness and unity in every facet of covering with other Company employees. the populace. the concern community. stockholders. clients. providers. rivals and authorities governments. When moving on behalf of the Company. Directors and employees shall non take unjust advantage through use. privacy. maltreatment of privileged information. deceit of material facts. or other unfair-dealing patterns. Company policy prohibits improper favoritism against employees. stockholders. Directors. officers. clients or providers on history of race. colour. age. sex. sexual orientation. faith or national beginning. All individuals shall be treated with self-respect and regard and they shall non be unreasonably interfered with in the behavior of their responsibilities and duties. No Director or employee should be misguided by any sense of trueness to the Company or a desire for profitableness that might do him or her to disobey any applicable jurisprudence or Company policy. Misdemeanor of Company policy will represent evidences for disciplinary action. including. when appropriate. expiration of employment.

Sensitive Minutess
Company policy prohibits its Directors. employees and agents from come ining into sensitive minutess. If such a dealing occurs. the Company and its officers. Directors and employees straight involved may be capable to mulcts. imprisonment and civil judicial proceeding. The term “sensitive transactions” is normally used to depict a wide scope of concern traffics by and large considered to be either illegal. unethical. immoral or to reflect adversely on the unity of the Company. These minutess are normally in the nature of kickbacks. gifts of important value. payoffs or final payments made to favorably act upon some determination impacting a company’s concern or for the personal addition of an person. These minutess may ensue in misdemeanor of assorted Gallic Torahs and similar Torahs of other states. Company policy prohibits the Company and its officers. Directors. employees and agents from corruptedly offering or giving anything of value to: • An functionary. including any individual moving in an official capacity for a authorities in France and outside France or an functionary of a public international organisation ;

• A political party functionary or political party in France and outside France ; or • A campaigner for political office in France and outside France straight or indirectly. for the intent of act uponing any act or determination of these functionaries in their official capacity or in misdemeanor of their lawful responsibilities or to procure any improper advantage in order to assist the Company obtain or retain concern or direct concern to any individual. Employees of government-owned companies. such as national oil companies. are considered to be authorities functionaries. Company policy prohibits any Director. employee or agent from doing any payment or prosecuting in any dealing that is prohibited by the FCPA. It may be hard to separate a legal facilitating payment from an illegal payoff. kickback or final payment. Consequently. easing payments must be purely controlled and every attempt must be made to extinguish or minimise such payments. Facilitating payments. if required. will be made merely in conformity with the beforehand counsel of the Law Department. All facilitating payments must be recorded accurately as easing payments in the accounting records of the Company.

Commercial Bribery
Company policy prohibits commercial payoffs. kickbacks and other similar final payments and benefits paid to any providers or clients. Directors. employees and agents are besides prohibited from having. straight or indirectly. anything of a important value ( other than salary. rewards or other ordinary compensation from the Company ) in connexion with a dealing entered into by the Company. Bribery of providers or clients includes any payment for the benefit of any representative of the provider or client. It includes: • Gifts of other than nominal value ; • Cash payments by Directors. employees or 3rd individuals. such as agents or advisers. who are reimbursed by the Company ; • The unsalaried usage of Company services. installations or belongings. except as may be authorized by the Company ; and • Loans. loan warrants or other extensions of recognition. This policy does non forbid outgos of sensible sums for repasts and amusement of providers and clients which are an ordinary and customary concern disbursal. if they are otherwise lawful. Outgos of this type should be included on disbursal studies and approved under standard Company processs.

Accounting Controls. Procedures and Records
Applicable Torahs and Company policy require the Company to maintain books and records that accurately and reasonably reflect its minutess and the temperaments of its assets. In add-on. the Company must keep a system of internal accounting controls that will guarantee the dependability and adequateness of its books and records. Failure to run into such demands may represent a misdemeanor of jurisprudence. To fulfill these demands. the Company has adopted policies to guarantee that merely proper minutess are entered into by the Company. that such minutess have proper direction blessing. that such minutess are decently accounted for in the books and records of the Company. and that the studies and fiscal statements of the Company are seasonably prepared. apprehensible and to the full. reasonably and accurately reflect such minutess. All Directors and employees holding any duty for such maps must be familiar with the Company’s policies. accounting controls. processs and records. and must follow with their demands.

Use and Disclosure of “Inside Information”
The Torahs of France and many other states regulate the usage and revelation of nonpublic information refering the Company because its portions are publically traded. This information is frequently referred to as “inside information” because it has non been publically disclosed. The Company has policies ( based in portion

on such Torahs ) refering the usage and revelation of inside information. Company policy prohibits the revelation of inside information to anyone other than individuals within the Company whose places require them to cognize such information. Company policy besides prohibits trading in Company securities. including stock options. by any employee while in the ownership of stuff inside information. Information is “material” if it could impact a person’s determination whether to purchase or sell securities. It is besides against Company policy for any individual in ownership of inside information to urge that others buy or sell Company securities on the footing of such information.

If an employee or agent of the Company has inside information about the Company. he or she must wait until the terminal of concern on the 2nd concern twenty-four hours after the information has been decently disclosed to the populace before purchasing or selling Company securities. More restrictive regulations apply to certain cardinal employees. officers and Directors. A Director. employee or agent shall non merchandise in the securities of another company if. in the class of his or her employment or due to his or her place with the Company. nonpublic information is learned about such other company that is likely to impact the monetary value of such securities. Company Directors. employees and agents are discouraged from short-run guess in the securities of the Company. It is Company policy that no discriminatory intervention will be given with regard to the revelation of inside information. The Company has adopted processs to avoid improper discriminatory revelations.

Confidential or Proprietary Information
Company Directors. employees and agents frequently learn confidential or proprietary information about the Company or its clients. Company policy prohibits Directors. employees and agents from unwraping or utilizing confidential or proprietary information outside the Company or for personal addition. either during or after employment. without proper written Company mandate to make so. An unauthorised revelation could be harmful to the Company or a client or helpful to a rival. The Company besides works with proprietary informations of clients. providers and joint venture spouses. This is an of import trust and must be discharged with the greatest attention for the Company to deserve the continued assurance of its clients. providers and joint venture spouses. No Director. employee or agent shall unwrap or utilize confidential or proprietary information outside the Company without Company mandate. nor shall any Director. employee or agent unwrap such information to other employees except on a needto-know footing.

Conflicts of Interest
Company policy prohibits struggles between the involvements of its Directors or employees and the Company. A complete definition of what constitutes a struggle of involvement is hard. There are some state of affairss. nevertheless. that will ever be considered a forbidden struggle of involvement. These state of affairss occur when a Director or employee or any individual holding a close personal relationship with the Director or employee: Obtains a important fiscal or other good involvement in one of the Company’s providers. clients or rivals without first advising the Company and obtaining written blessing from the Chief Executive Officer or his or her designee ; • Engages in a important personal concern dealing affecting the Company for net income or addition. unless such dealing has foremost been approved in composing by the Chief Executive Officer or his or her designee ; • Accepts money. gifts of other than nominal value. inordinate cordial reception. loans. warrants of duties or other particular intervention from any provider. client or rival of the Company ( loans from loaning establishments at prevalent involvement rates are excluded ) ;

• Participates in any sale. loan or gift of Company belongings without obtaining written blessing from the Chief Executive Officer or his or her designee ; • Learns of a concern chance through association with the Company and discloses it to a 3rd party or invests in or takes the chance personally without first offering it to the Company ; • Uses corporate belongings. information. or place for personal addition ; or • Competes with the Company. A struggle of involvement may originate because of outside directorships. personal usage of Company belongings or obtaining Company services for personal benefit. “Person holding a close personal relationship with the Director or employee” refers to the Director’s or employee’s partner. parents. kids. siblings. mothers- and fathers-in-law. sons- and daughters-in-law. brothers- and sisters-in-law. any individual life in the same house with the Director or employee or any concern associate of the Director or employee. Sporadically the Company requires certain employees to attest to the Company that they have complied with all demands of the Code of Business Conduct. Disclosure of a peculiar state of affairs that may be a struggle of involvement does non intend that the Company will see it to be significant adequate to be prohibited. Each state of affairs will be considered on an single footing.

Fraud and Similar Abnormalities
Company policy prohibits fraud and establishes processs to be followed refering the acknowledgment. coverage and probe of suspected fraud. Fraud includes. but is non limited to: • Dishonest or deceitful act ; • Embezzlement ; • Forgery or change of negotiable instruments such as Company cheques and bill of exchanges ;

Embezzlement of Company. employee. client. spouse or supplier assets ; Conversion to personal usage of hard currency. securities. supplies or any other Company plus ; Unauthorized handling or coverage of Company minutess ; and Falsification of Company records or fiscal statements for personal or other grounds.

Directors and employees are obligated to protect the Company’s assets and guarantee their efficient usage. Larceny. sloppiness and waste of Company assets by Directors and employees are prohibited since such actions and behavior have a direct and negative impact on the Company’s profitableness. All Company assets shall merely be used for the legitimate concern intents of the Company. Any Director. employee or agent who suspects that any deceitful activity may hold occurred is required to describe such concern to the Law Department. Audit Services. Security Department. or the Company’s Chief Financial Officer. All fraud probes will be conducted under the way of the Law Department.

Export Matters and International Business Relationships Export Administration and International Economic Sanctions Although the Company operates in many states throughout the universe. as a Gallic company it must follow with the export disposal and international economic countenances Torahs of France. Company policy requires that the Company behavior all of its concern and export its services. merchandises and engineering in conformity with such Torahs. There are no exclusions to this policy. The Company has established a comprehensive internal monitoring plan to guarantee conformity with such Torahs. The demands of these Torahs are complex and sometimes hard to understand. Any inquiries refering the demands of this policy or the applicable jurisprudence should be addressed to the export control director or the Law Department. All Company Directors. employees and agents must detect all demands of the internal controls plan and act in conformity with these Torahs.

Applicable Torahs and Company policy prohibits cooperation with certain boycotts imposed by the Torahs of other states. Applicable Gallic Torahs besides require that the Company non supply certain information refering the individuality and nationality of its employees. Directors. stockholders. subcontractors and providers. or information about where the Company does concern when such information is requested to back up a forbidden boycott. The Company is besides required to describe petitions it receives to back up such boycotts even though it does non follow with such petitions. Sometimes requests to back up a forbidden boycott are difficult to observe. All employees and agents who are likely to come in contact with such petitions must be to the full cognizant of the inside informations of this policy.

International Business Relationships
The Company frequently enters into concern relationships with other individuals and companies outside France. These “International Business Relationships” take the signifier of bureau understandings. joint ventures and other signifiers of concern combinations. Company policy governs the mode in which it will come in into and pull off these concern relationships. The term “International Business Relationships” includes the followers: • Employment of an agent. gross revenues representative. patron or any other party to help the Company to obtain concern or advance the distribution. selling or gross revenues of its merchandises and services. including a licensing understanding where another party distributes. markets or sells the merchandises. services or engineering of the Company ; • Entering into a joint venture. pool. partnership. stockholder understanding or any other agreement where another party obtains an equity involvement in an entity owned by the Company. or a portion of the net incomes from the concern of a joint venture. pool. partnership or entity owned by the Company ;

• Entering into a contract or subcontract where another party will execute the bulk of the work to be performed under the Company’s contract. While International Business Relationships are utile in the behavior of the Company’s concern. they must be adequately capable to the Company’s systems of control to protect the Company’s assets against unauthorised usage. Besides. the Company may be held accountable for actions taken by agents and others on its behalf. Therefore. Company policy requires that choice of other parties with whom the Company will fall in in International Business Relationships must be capable to allow direction control and probe. All proposed understandings set uping or amending such relationships must be carefully reviewed by legal. fiscal and direction forces prior to subscribing the understanding. Further. these understandings must necessitate that the other parties agree to follow with the Company’s Code of Business Conduct for International Business Relationships. This separate codification of behavior applies to International Business Relationships. It includes many of the same demands as the Company’s Code of Business Conduct. Any employee who has duties with regard to International Business Relationships must be familiar with the more elaborate applicable Company policies.

Antitrust and Competition
The antimonopoly Torahs of France and EEC and other states prohibit understandings or actions that might extinguish or deter competition. convey about a monopoly. abuse a dominant market place. unnaturally maintain monetary values or otherwise illicitly hamper or falsify commercialism. Antimonopoly cases have often resulted in judgements against companies amounting to 10s of 1000000s and. on occasions. 100s of 1000000s of dollars. The Company does non digest any concern activity that violates antimonopoly Torahs that apply to the Company’s concern. Company policy requires that no Director. employee or agent of the Company shall come in into any understanding. understanding. program or strategy. express or implied. formal or informal. with any rival in respect to monetary values. footings or conditions of sale or service. production. distribution. districts or clients ; nor exchange or discuss with a rival monetary values. footings or conditions of sale or service. or any other competitory information ; nor prosecute in any other behavior which violates any of the antimonopoly Torahs.

However. farm outing agreements or joint proposals with rivals which are non in misdemeanor of applicable antimonopoly Torahs and which have been approved by the Law Department are non prohibited. Any treatment with rivals in connexion with a undertaking in which the rival is an confederation spouse. joint venturer. or subcontractor must be precleared and coordinated with the Law Department. Antitrust Torahs are complex and sometimes hard to understand. Any Director. employee or agent of the Company who has duty for concern behavior that might be capable to antimonopoly Torahs must be guided by the advice of the Law Department. Any inquiries refering antimonopoly deductions must be referred to the Law Department before taking any action. There are no exclusions to this policy and no 1 is authorized to O.K. any action in misdemeanor of this policy.

Employment and the Workplace Equal Employment Opportunity
Company policy prohibits all improper favoritism against any employee or applier for employment. The Company is committed to supplying equal chance to all qualified persons in its hiring and publicity policies. The Company will endeavour to make a work force that is a contemplation of the diverse population of the communities in which it operates. With regard to operations governed by Gallic and EEC jurisprudence. this policy relates to all stages of employment. including enlisting. hiring. arrangement. publicity. transportation. compensation. benefits. preparation. educational. societal and recreational plans. and the usage of Company installations. It covers all other forces actions in all occupation classs and at all degrees. including employment of qualified handicapped persons. handicapped veterans. It is intended to supply employees with a working environment free of favoritism. torment. bullying or coercion associating straight or indirectly to race. colour. faith. sex. sexual orientation. age. disablement or national beginning. All Directors. members of direction and other employees shall actively back up this policy.

The Company believes that all employees should be treated with self-respect and regard. It is the policy of the Company to supply a work environment which is free from torment. As used in this policy. torment includes sexual. racial. cultural. and other signifiers of torment. including torment based upon disablement. Some illustrations. depending on the facts and fortunes. include: • Verbal or Written Harassment — unwelcome or derogative remarks sing a person’s race. colour. sex. sexual orientation. faith. lineage. cultural heritage. mental or physical disablement. age or visual aspect ; menaces of physical injury ; or the distribution of stuff holding such effects. including by electronic mail or show in any Company work country. • Physical Harassment — hitting. forcing or other aggressive physical contact or menaces to take such action. or inappropriate gestures. • Sexual Harassment — unwelcome sexual behavior. whether verbal or physical. including sexual progresss. demands for sexual favours. or other verbal or physical behavior of a sexual nature. whether or non it was designed or intended to advance an confidant relationship.

It is non considered torment for supervisors and other members of direction to implement occupation public presentation and criterions of behavior in a just and consistent mode. Any employee who believes she or he is being harassed should see stating the piquing party that she or he objects to that behavior. This frequently solves the job. However. if an employee is non comfy facing the piquing party ( or if the piquing party’s unwelcome behavior continues ) . the employee should rede his or her immediate supervisor of the piquing behavior. If the employee is more comfy discoursing the issue with person other than his or her immediate supervisor. or if the immediate supervisor has non taken what the employee respects as appropriate action to work out the job. the employee should reach a Human Resources or Law Department representative. Reports of torment will be investigated quickly and discreetly. Any employee who reports any act of torment in good religion. including sexual torment. will non be retaliated against because of such study.

Health. Safety and Environment
Protection of wellness. safety and the bar of pollution to the environment are primary ends of the Company. The Company will endeavor to develop and supply merchandises and services that have no undue environmental impact and are safe in their intended usage. efficient in their ingestion of energy and natural resources and can be recycled. reused or disposed of safely. All employees must carry on their responsibilities and duties in conformity with applicable jurisprudence and industry criterions associating to wellness and safety in the workplace and bar of pollution to the environment. The Chief Health. Safety and Environment Officer of the Company is the Chief executive officer of the Company and shall supervise the disposal of this policy.

Political Activities
The Company believes strongly in the democratic procedure. Its Directors and employees should take an active involvement in furthering rules of good authorities in the states and communities in which they live. Directors and employees may pass their ain clip and financess back uping political campaigners and issues. but they will non be reimbursed by the Company. Directors and employees should guarantee that their personal political parts and activities are in conformity with applicable jurisprudence. Further. some political behavior which is permitted and encouraged for persons is improper for corporations. Company policy requires Directors. employees and agents who represent the Company in political and governmental affairs to follow with all Torahs modulating corporate engagement in public personal businesss. To guarantee that these demands are met and as counsel to them. the undermentioned policies have been adopted:

• No Director. employee or agent shall use any force per unit area on any other employee that infringes that individual’s right to make up one’s mind whether. to whom and in what sum a personal political part is to be made ; • No parts of Company financess. belongings or services shall be made in support of political campaigners in France or in other states where such parts are prohibited. • No political part of Company financess. belongings or services can be made by the Company. • When permitted by jurisprudence and authorized by the Chief Executive Officer. outgos of Company financess may be made to inform or act upon the voting populace on an issue of importance to the concern of the Company and its stockholders. If an employee or Director is requested to do a political part or to supply aid on behalf of the Company. whether personal or corporate. and such employee or Director has any inquiries sing this Company policy or applicable jurisprudence. the employee or Director should reach the Company’s Chief Executive Officer.

Gallic and EEC. British. United Arab Emirates. Congolese. Singaporean and Malayan Government Contracting and UN undertaking To guarantee that the Company complies with ordinances on Gallic and EEC. British. UAE. Congolese. Singaporean and Malayan governmental contracts and UN contracts. all employees involved in the public presentation of work under governmental contracts and UN contracts are to be adequately informed and sufficiently trained in the policies and patterns contained in the Code of Business Conduct and other Company policies specifically associating to authorities catching and UN catching. Each concern unit director with contracts with the above listed authoritiess and UN is responsible for guaranting that developing Sessionss sing these policies are conducted and that the preparation Sessionss are decently documented. The Company takes appropriate. timely action to rectify misdemeanors of Gallic and EEC. British. UAE. Congolese. Singaporean and Malaysian governmental criterions and UN criterions. If any employee has a inquiry on the properness of a dealing. the employee must describe the dealing to the immediate supervisor.

If the supervisor finds the inquiry to hold substance. the supervisor must describe the dealing to the General Counsel or his or her designee. The supervisor must rede the employee of the action the supervisor has taken. If the employee disagrees with the supervisor or if the employee is non comfy describing the dealing to the supervisor. the employee may reach the General Counsel or his or her designee straight. When cost and pricing informations are required to react to a authorities solicitation or UN RFP/RFQ/RFI. the cost and pricing informations must be current. accurate. and complete at the clip of entry. All costs are to be decently recorded. documented. and retained in conformity with French and EEC. British. UAE. Congolese. Singaporean and Malaysian governmental and UN procurement ordinances. Each concern unit making concern with the Gallic and EEC. British. UAE. Congolese. Singaporean and Malaysian governmental and UN must invoice the authorities and UN in rigorous conformity with French and EEC. British. UAE. Congolese. Singaporean and Malaysian governmental criterions and UN criterions.

Confidential Reporting of Alleged Code Misdemeanors
If you need advice or aid or know of a misdemeanor of the Code of Business Conduct. you should reach direction or the Law Department in individual or by telephone. You may besides direct an electronic mail to [ electronic mail protected ]To confer with the Code of Business Conduct you can besides travel to: World Wide Web. iec-telecom. com 1. You may forbear from placing yourself ( although. in the absence of such designation. the Company may hold deficient information to look into the allegations ) . 2. No requital shall be imposed on you for doing the study in good religion unless you are one of the lawbreakers. 3. Your confidentiality shall be maintained unless revelation is: • Required or advisable in connexion with any governmental probe or study ; • In the involvements of the Company. consistent with the ends of the Code ; • Required or advisable in the Company’s legal defence of the affair. The Ethics e-mail reference is non intended to be used for personal grudges. All affairs that do non look to represent misdemeanors of the Code of Business Conduct will be referred to the appropriate section ; for illustration. studies refering forces grudges will be sent to the Human Resources Department.

The reference of the Mailbox for doing Code studies is: Director of Business Conduct IEC Telecom 10 herb of grace de la Sabliere 92230 gennevilliers France Contact the Board of Directors You may describe concerns about the Company’s accounting. internal accounting controls or scrutinizing affairs to the Company’s Audit Committee. or other concerns to the Board of Directors. by taking one of the undermentioned options. By composing to: Board of Directors c/o Director of Business Conduct IEC Telecom 10 herb of grace de la Sabliere 92230 Gennevilliers France By naming: +33 1 40 17 08 60 You may describe concerns anonymously and confidentially. Your confidentiality shall be maintained unless revelation is: • Required or advisable in connexion with any governmental probe or study ; • In the involvements of the Company. consistent with the ends of the Code ; • Required or advisable in the Company’s legal defence of the affair.

Distribution The Company’s Code of Business Conduct is a really of import portion of the administration of the Company. A sum-up of the Code is published in a figure of linguistic communications and is distributed to employees in difficult transcript and on the Company’s intranet. The Code of Business Conduct is besides published on the Company’s Internet place page at hypertext transfer protocol: //www. iec-telecom. com. To obtain a full transcript of the Company’s Code of Business Conduct. reach the Director of Business Conduct.

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