Academi is obviously mindful of some of the past controversies its ancestral companies were embroiled in and has taken steps, as much as humanly possible, to make a repeat of such incidents impossible.
The scandal at Penn State is a shadow across the soul of the university, a bitter reminder that the president who fails to confront corruption will ultimately fail completely, taking down countless other people as he crashes.
Evidently, the ICoC, to paraphrase Captain Barbossa of the Pirates of Caribbean: The Curse of the Black Pearl movie, is more of a guideline than an actual rule. Welcome aboard the Black PSC, Miss Turner.
As I've said before, codes of conduct are better than nothing, but lacking enforcement or the means to exact consequences, if the code is violated, not much more so. Let's just say that codes have a certain amount of elasticity.