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Business Ethics Policy

March 07, 2008

The Business Ethics policy states management’s view on ethics. It reserves the right to determine when an employee’s activities represent a conflict with the Company’s interests and to take whatever action is necessary to resolve the situation—including terminating the employee. It also provides a partial list of activities that would be prohibited by an employee outside of the workplace.

Subject: Conflict of Interest and Business Ethics

Organization: Anonymous

Example of: Standard Policy

Exactly what constitutes a conflict of interest or an unethical business practice is both a moral and a legal question. The recognizes and respects the individual employee’s right to engage in activities outside of his or her employment which are private in nature and do not in any way conflict with or reflect poorly on the Company. Management reserves the right, however, to determine when an employee’s activities represent a conflict with the Company’s interests and to take whatever action is necessary to resolve the situation—including terminating the employee.

It isn’t possible in a general policy statement of this sort to define all the various circumstances and relationships that would be considered “unethical.” The list below suggests some of the types of activity that would reflect in a negative way on the employee’s personal integrity or that would limit his or her ability to discharge job duties and responsibilities in an ethical manner:

1. Simultaneous employment by another firm, particularly if the other firm is a competitor or supplier.

2. Carrying on Company business with a firm in which the employee, or a close relative of the employee, has a substantial ownership or interest.

3. Holding a substantial interest in, or participating in the management of, a firm to which the Company makes sales or from which it makes purchases.

4. Borrowing money from customers or firms, other than recognized loan institutions, from which our Company buys services, materials, equipment, or supplies.

5. Accepting substantial gifts or excessive entertainment from an outside organization or agency.

6. Speculating or dealing in materials, equipment, supplies, services, or property purchased by the Company.

7. Participating in civic or professional organization activities in a manner whereby confidential Company information is divulged. 8. Misusing privileged information or revealing confidential data to outsiders.

9. Using one’s position in the Company or knowledge of its affairs for outside personal gains.

10. Engaging in practices or procedures that violate the Sarbanes-Oxley Act, antitrust laws, or other laws regulating the conduct of Company business.

Note: Employment by the Company carries with it a responsibility to be constantly aware of the importance of ethical conduct. Employees must refrain from taking part in, or exerting influence in, any transaction in which their own interests may conflict with the best interests of the Corporation. Employees are encouraged to report conduct that they reasonably believe violated the law, without fear of reprisal or reprimand by the Company. Employees may not destroy or falsify documents in contemplation of, or related to, an investigation of the Company by any law enforcement agency.


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