Code of Ethics

Relationships with Clients and Partners

It is our policy to be service oriented and to treat all client and business partners in a courteous and respectful manner at all times. Our clients and business partners provide the primary source of our income and each employee’s job security. To promote excellent relations with our clients and business partners, all employees must represent the company in a positive manner and make such persons feel appreciated.

Employees who interact with our clients and business partners are expected to know our products and services and to learn what our clients and business partners want and need. Such employees should educate our partners about the use of our products and services and should seek new and innovative ways to serve them. Employees should be polite and thoughtful when using the telephone. A positive telephone contact can enhance goodwill, while a negative experience can destroy a valuable relationship.

Employees should be prepared to listen carefully to complaints and deal with them in a helpful, professional manner. If a controversy arises, the employee should consult his/her department manager. Clients and business partners who become unreasonable, abusive, or harassing should be referred to the employee’s department manager.

Competitor Relations

We compete in our markets vigorously but honestly. We will not seek to damage the reputation of competitors either directly or by implication or innuendo. The Company will not attempt to acquire information regarding a competitor’s business by disreputable means. This includes industrial espionage, hiring competitors’ employees to obtain confidential information, urging a competitor’s personnel or customers to disclose confidential information, or any other unethical approach. All statements made to third parties about our competitors must be made honestly and must be factually correct.

Additionally, you must avoid disclosing proprietary or confidential information about the company in any contacts with competitors. Please refer to the discussion under the heading “Trade Secrets and Other Proprietary Information” beginning on p. 10.

Business Records

Accurate and up-to-date accounting, financial and other business records are essential for the proper function of the company’s business and to assure that the company’s business is documented in accordance with its contractual obligations and legal requirements. Each employee is charged with ensuring that every business record for which he or she is responsible is as accurate, complete and reliable as possible. 

This standard applies to all operating reports and records prepared for internal and external purposes. As such:

•company books and records shall fairly and accurately reflect in reasonable detail the business transactions, acquisitions or disposition of assets and other activities of the company;

•no entry will be made on the books, records, documents or correspondence of the company that intentionally obscures or disguises the true nature of any transaction;

•books and records of the company shall be safeguarded from accidental destruction and shall be disposed of only as specified in the company’s retention procedures; and

•the company will not establish undisclosed or unrecorded funds or assets or make payments or contributions with the intention or understanding that any part is to be used for purposes not specified in the supporting documentation.

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