Saga Smarts is founded by a group of dedicated teachers, engineers and innovators, focusing on serving Chinese ethnic students in the United States with outstanding backgrounds and helping them to successfully acquire a good educational experience through intelligent test preparation, sound planning and effective guidance.

Mr. Guy B. Palumbo is the President of Saga Smarts, Inc. and has an extensive background in several industries in the New York City area. He is a retired US Army Lieutenant Colonel and he has served as a Military Academy Liaison Officer (MALO) West Point and was personally responsible for interviewing high school students desiring to attend West Point. In recognition of his services he was awarded “The Meritorious Service Medal for “Using personal magnetism and extraordinary managerial talents, he expertly organized and managed the New York City area. His experiences and performance working for West Point, which is the premier worldwide military academy and its admission standards, place it well within the “Ivy League’ level.

High end college counseling presents a paradox: personalized service time is inversely proportional to the number of students. We have a clear but solid understanding of high-end admissions. Tailored, customized service is destined to be difficult to reconcile the limited time between service providers and student’s individual needs.

We are in effect a boutique firm that works with a limited number of students/families who agree with our philosophy and approach.

We design a detailed program based on our observation and understanding of the students by investing extensive time in accumulating all aspects of the student’s needs, educational practices and desires. We do not forget the parents and include them in all aspects of the tailored program taking into consideration the financial, social and family environments.

Why Saga Smarts, Inc.?

• Real and Successful Experience: Successful Counseling Hundreds of students to win admissions to prestigious schools. We placed over 20 students in 2016-2017 to get into top schools including Princeton.

• Elite Mode: We are a “boutique” service and do not take all students;

• Understanding students: we take the time to learn the student so a tailored, student specific plan can be developed;

• Parental involvement: Parents are an integral part of our programs and they must participate by monitoring the student to follow the final program;

• Growth: We also provide detailed career planning not just college acceptance;

• Referrals are truly based on the students success and look for parental endorsements once a student is accepted based on an agreed list of educational institutions;

• 100% Success rate: We boastly enjoy the 100% success rate, since we provide every client with extreme professionalism and care. 

 

 

Saga Smarts, Inc.
Code of Ethics and Business Conduct

The success of our business is dependent on the trust and confidence we earn from our employees, customers and shareholders. We gain credibility by adhering to our commitments, displaying honesty and integrity and reaching company goals solely through honorable conduct.

When considering any action, it is wise to ask: will this build trust and credibility for Saga Smarts, Inc. Will it help create a working environment in which Saga Smarts, Inc. can succeed over the long term? Is the commitment I am making one I can follow through with? The only way we will maximize trust and credibility is by answering “yes” to those questions and by working every day to build our trust and credibility.

 Respect for the Individual

We all deserve to work in an environment where we are treated with dignity and respect. Saga Smarts, Inc. is committed to creating such an environment because it brings out the full potential in each of us, which, in turn, contributes directly to our business success.

Saga Smarts, Inc. is an equal employment/affirmative action employer and is committed to providing a workplace that is free of discrimination of all types from abusive, offensive or harassing behavior. Any employee who feels harassed or discriminated against should report the incident to his or her manager or to human resources.

 Create a Culture of Open and Honest Communication

At Saga Smarts, Inc. everyone should feel comfortable to speak his or her mind, particularly with respect to ethics concerns. Managers have a responsibility to create an open and supportive environment where employees feel comfortable raising such questions. We all benefit when employees exercise their power to prevent mistakes or wrongdoing by asking the right questions at the right times.

Saga Smarts, Inc. will investigate all reported instances of questionable or unethical behavior. In every instance where improper behavior is found to have occurred, the company will take appropriate action. We will not tolerate retaliation against employees who raise genuine ethics concerns in good faith.

Saga Smarts, Inc.’s Whistleblower policy is as follows:

Employees are encouraged, in the first instance, to address such issues with their managers or the HR manager, as most problems can be resolved swiftly. If for any reason that is not possible or if an employee is not comfortable raising the issue with his or her manager or HR, Saga Smarts, Inc.’s Vice President does operate with an open-door policy.

Management has the added responsibility for demonstrating, through their actions, the importance of this policy. In any business, ethical behavior does not simply happen; it is the product of clear and direct communication of behavioral expectations, modeled from the top and demonstrated by example.

To make our Policy work, managers must be responsible for promptly addressing ethical questions or concerns raised by employees and for taking the appropriate steps to deal with such issues. Managers should not consider employees’ ethics concerns as threats or challenges to their authority, but rather as another encouraged form of business communication.

Saga Smarts, Inc.’s commitment to integrity begins with complying with laws, rules and regulations where we do business. Further, each of us must have an understanding of the company policies, laws, rules and regulations that apply to our specific roles. If we are unsure of whether a contemplated action is permitted by law or Saga Smarts, Inc. policy, we should seek the advice from the resource expert. We are responsible for preventing violations of law and for speaking up if we see possible violations.

Because of the nature of our business, some legal requirements warrant specific mention here.

 Competition

We are dedicated to ethical, fair and vigorous competition. We will sell Saga Smarts, Inc. products and services based on their merit, superior quality, functionality and competitive pricing. We will make independent pricing and marketing decisions and will not improperly cooperate or coordinate our activities with our competitors. We will not offer or solicit improper payments or gratuities in connection with the purchase of goods or services for Saga Smarts, Inc. or the sales of its products or services, nor will we engage or assist in unlawful boycotts of particular customers.

 Proprietary Information

It is important that we respect the property rights of others. We will not acquire or seek to acquire improper means of a competitor’s trade secrets or other proprietary or confidential information. We will not engage in unauthorized use, copying, distribution or alteration of software or other intellectual property.

 Selective Disclosure

We will not selectively disclose (whether in one-on-one or small discussions, meetings, presentations, proposals or otherwise) any material nonpublic information with respect to Saga Smarts, Inc., its securities, business operations, plans, financial condition, results of operations or any development plan.

 Avoid Conflicts of Interest

 Conflicts of Interest

We must avoid any relationship or activity that might impair, or even appear to impair, our ability to make objective and fair decisions when performing our jobs. At times, we may be faced with situations where the business actions we take on behalf of Saga Smarts, Inc. may conflict with our own personal or family interests. We owe a duty to Saga Smarts, Inc. to advance its legitimate interests when the opportunity to do so arises. We must never use Saga Smarts, Inc. property or information for personal gain or personally take for ourselves any opportunity that is discovered through our position with Saga Smarts, Inc.

Here are some other ways in which conflicts of interest could arise:

1. Being employed by, or acting as a consultant to, a competitor or potential competitor, supplier or contractor, regardless of the nature of the employment, while you are employed with Saga Smarts, Inc.
2. Hiring or supervising family members or closely related persons.
3. Serving as a board member for an outside commercial company or organization.
4. Owning or having a substantial interest in a competitor, supplier or contractor.
5. Placing company business with a firm owned or controlled by a Saga Smarts, Inc. employee or his or her family.
6. Accepting gifts, discounts, money (bribe), favors or services from a customer/potential customer, competitor or supplier, unless equally available to all Saga Smarts, Inc. employees.

Determining whether a conflict of interest exists is not always easy to do. Employees with a conflict of interest question should seek advice from management. Before engaging in any activity, transaction or relationship that might give rise to a conflict of interest, employees must seek review from their managers or the HR department.

 Gifts, Gratuities and Business Courtesies

Saga Smarts, Inc. is committed to competing solely on the merit of our products and services. We should avoid any actions that create a perception that favorable treatment of outside entities by Saga Smarts, Inc. was sought, received or given in exchange for personal business courtesies. Business courtesies include gifts, gratuities, meals, refreshments, entertainment or other benefits from persons or companies with whom Saga Smarts, Inc. does or may do business. We will neither give nor accept business courtesies that constitute, or could reasonably be perceived as constituting, unfair business inducements to include cash (bribes) or the promises for the future that would violate law, regulation or polices of Saga Smarts, Inc. or customers, or would cause embarrassment or reflect negatively on Saga Smarts, Inc.’s reputation.

 Accepting Business Courtesies

Most business courtesies offered to us in the course of our employment are offered because of our positions at Saga Smarts, Inc. We should not feel any entitlement to accept and keep a business courtesy. Although we may not use our position at Saga Smarts, Inc. to obtain business courtesies, and we must never ask for them, we may accept unsolicited business courtesies that promote successful working relationships and good will with the firms that Saga Smarts, Inc. maintains or may establish a business relationship with.

Employees who award contracts or who can influence the allocation of business, who create specifications that result in the placement of business or who participate in negotiation of contracts must be particularly careful to avoid actions that create the appearance of favoritism or that may adversely affect the company’s reputation for impartiality and fair dealing. The prudent course is to refuse a courtesy from a supplier or customer when Saga Smarts, Inc. is involved in choosing or reconfirming a supplier or under circumstances that would create an impression that offering courtesies is the way to obtain Saga Smarts, Inc. business.

 Meals, Refreshments and Entertainment

We may accept occasional meals, refreshments, entertainment and similar business courtesies that are shared with the person who has offered to pay for the meal or entertainment, provided that:

• They are not inappropriately lavish or excessive.
• The courtesies are not frequent and do not reflect a pattern of frequent acceptance of courtesies from the same person or entity.
• The courtesy does not create the appearance of an attempt to influence business decisions, such as accepting courtesies or entertainment from a supplier whose contract is expiring in the near future.
• The employee accepting the business courtesy would not feel uncomfortable discussing the courtesy with his or her manager or co-worker or having the courtesies known by the public.

 Gifts

Employees may accept unsolicited gifts, other than money, that conform to the reasonable ethical practices of the marketplace, including:

• Flowers, fruit baskets and other modest presents that commemorate a special occasion.
• Gifts of nominal value, such as calendars, pens, mugs, caps and t-shirts (or other novelty, advertising or promotional items).

Generally, employees may not accept compensation, honoraria or money of any amount from entities with whom Saga Smarts, Inc. does or may do business. Tangible gifts (including tickets to a sporting or entertainment events) that have a market value greater than $100 may not be accepted unless approval is obtained in advance from management.

Employees with questions about accepting business courtesies should talk to their managers or the HR department.

 Offering Business Courtesies

Any employee who offers a business courtesy must assure that it cannot reasonably be interpreted as an attempt to gain an unfair business advantage or otherwise reflect negatively upon Saga Smarts, Inc. An employee may never use personal funds or resources to do something that cannot be done with Saga Smarts, Inc. resources. Accounting for business courtesies must be done in accordance with approved company procedures and always in advance.

Other than to our government customers, for whom special rules apply, we may provide nonmonetary gifts (i.e., company logo apparel or similar promotional items) to our customers. Further, management may approve other courtesies, including meals, refreshments or entertainment of reasonable value, provided that:

• The practice does not violate any law or regulation or the standards of conduct of the recipient’s organization.
• The business courtesy is consistent with industry practice, is infrequent in nature and is not lavish.
• The business courtesy is properly reflected on the books and records of Saga Smarts, Inc.

 Report Results Accurately

 Accurate Public Disclosures

We will make certain that all disclosures made in financial reports and public documents are full, fair, accurate, timely and understandable. This obligation applies to all employees, including all financial executives, with any responsibility for the preparation for such reports, including drafting, reviewing and signing or certifying the information contained therein. No business goal of any kind is ever an excuse for misrepresenting facts or falsifying records.

Employees should inform management and the HR department if they learn that information in any filing or public communication was untrue or misleading at the time it was made or if subsequent information would affect a similar future filing or public communication.

 Corporate Recordkeeping

We create, retain and dispose of our company records as part of our normal course of business in compliance with all Saga Smarts, Inc. policies and guidelines, as well as all regulatory and legal requirements.

All corporate records must be true, accurate and complete, and company data must be promptly and accurately entered in our books in accordance with Saga Smarts, Inc.’s and other applicable accounting principles.

We must not improperly influence, manipulate or mislead any unauthorized audit, nor interfere with any auditor engaged to perform an internal independent audit of Saga Smarts, Inc. books, records, processes or internal controls.

Substance Over Form

We are all faced with decisions we would rather not have to make and issues we would prefer to avoid. Sometimes, we hope that if we avoid confronting a problem, it will simply go away.

At Saga Smarts, Inc., we must have the courage to make the tough decisions and difficult choices, secure in the knowledge that Saga Smarts, Inc. is committed to doing the right thing. At times this will mean doing more than simply what the law requires. Merely because we can pursue a course of action does not mean we should do so.

Although Saga Smarts, Inc.’s guiding principles cannot address every issue or provide answers to every situation, they can define the spirit in which we intend to do business and should guide us in our daily conduct.

 Accountability

Each of us is responsible for knowing and adhering to the values and standards set forth in this policy and for raising questions if we are uncertain about company policy. If we are concerned whether the standards are being met or are aware of violations of the policy, we must contact the HR department or Vice President.

Saga Smarts, Inc. takes seriously the standards set forth in the policy, and violations are cause for disciplinary action up to and including termination of employment.

Confidential and Proprietary Information

Integral to Saga Smarts, Inc.’s business success is our protection of confidential company information, as well as nonpublic information entrusted to us by employees, customers and other business partners. Confidential and proprietary information includes such things as programs, computer files, IT methods or procedures, emails, pricing and financial data, customer names/addresses or nonpublic information about other companies, including current or potential supplier and vendors. We will not disclose confidential and nonpublic information without a valid business purpose and proper authorization.

 Use of Company Resources

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

Employees and those who represent Saga Smarts, Inc. are trusted to behave responsibly and use good judgment to conserve company resources. Managers are responsible for the resources assigned to their departments and are empowered to resolve issues concerning their proper use.

Generally, we will not use company equipment such as computers, copiers and fax machines in the conduct of an outside business or in support of any religious, political or other outside daily activity, except for company-requested support to nonprofit organizations. We will not solicit contributions nor distribute non-work-related materials during work hours.

In order to protect the interests of the Saga Smarts, Inc. network and our fellow employees, Saga Smarts, Inc. reserves the right to monitor or review all data and information contained on an employee’s company-issued computer or electronic devices, to include cellular telephones the use of the Internet or Saga Smarts, Inc.’s intranet. We will not tolerate the use of company resources to create, access, store, print, solicit or send any materials that are harassing, threatening, abusive, sexually explicit or otherwise offensive or inappropriate.

Questions about the proper use of company resources should be directed to your manager.

 Media Inquiries

Saga Smarts, Inc. plan is to be a high-profile company in our community, and from time to time, employees may be approached by reporters and other members of the media. In order to ensure that we speak with one voice and provide accurate information about the company, we should direct all media inquiries to the Vice President. No one may issue a press release without first consulting with the Vice President.

 Do the Right Thing

Several key questions can help identify situations that may be unethical, inappropriate or illegal. Ask yourself:

• Does what I am doing comply with the Saga Smarts, Inc. guiding principles and company policies?
• Have I been asked to misrepresent information or deviate from normal procedure?
• Would I feel comfortable describing my decision at a staff meeting?
• How would it look if it made the headlines?
• Am I being loyal to my family, my company and myself?
• What would I tell my child to do?
• Is this the right thing to do?

While there are many situations which cannot be foreseen, it is incumbent on all employees to keep in mind that different cultures and industries have varied business practices. Some may seem unusual and employees should inform management before proceeding when something is presented that does not conform to our standards.

Whenever in doubt contact your immediate supervisor or the Vice President.

 

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Contact:

Address:

Saga Smarts, Inc.

401 Park Avenue South

10th Floor

New York, NY 10016

Email: info@sagasmarts.com

Tel: 917-636-5885