Ethics Policy

Purpose

[Company Name] expects all employees to conduct [Company Name]'s business with integrity and to comply with all applicable laws in a manner that excludes considerations of personal advantage or gain.

Policy

Gifts, Favors, and Payments by the Company

Gifts, favors, and payments may be given to others at [Company Name]'s expense, if they meet all of the following criteria:

• They are consistent with accepted business practices.
• They are of sufficiently limited value and in a form that will not be construed as a bribe or payoff.
• They are not in violation of applicable law and generally accepted ethical standards.
• Public disclosure of the facts will not embarrass [Company Name].

Payments, commissions or other compensation to or for the benefit of employees of customers (or their family members or associates) not required by written contract are contrary to this policy.

Gifts, Favors, Entertainment and Payments Received by Company Employees

Employees shall not seek or accept for themselves or others any gifts, favors, entertainment or payments without a legitimate business purpose from any person or business organization that does or seeks to do business with or is a competitor of the [Company Name].

Employees may accept for themselves and members of their families' common courtesies usually associated with customary business practices. These include but are not limited to:

• Lunch and/or dinner with vendors sometimes including spouses as long as the invitation is extended by the vendor.
• Gifts of small value from vendors such as calendars, pens, pads, etc.
• Tickets to events (sports, arts, etc.) are acceptable if offered by the vendor and the vendor accompanies the employee to the event. These are not to be solicited by the company employee and must be approved by the appropriate company officer.
• Overnight outings are acceptable under the condition that individuals from either other companies or the vendor are in attendance. The employee must have prior approval from the appropriate company officer.
• The receipt of alcoholic beverages is discouraged.
• Gifts of perishable items usually given during the holidays such as hams, cookies, nuts, etc., are acceptable.

A strict standard is expected with respect to gifts, services, discounts, entertainment or considerations of any kind from suppliers.

• Day outings such as golf, fishing and hunting are acceptable with prior approval from the appropriate company official. The vendor must be in attendance and participation by the employee's family members is not acceptable.
• Use of vendor's facilities (vacation homes, etc.) by employees or their families for personal use is prohibited. In the event the vendor is present for the duration of the visit such a situation is acceptable as long as it is only once per year and for a limited duration (i.e., a long weekend.) The employee must have prior approval from the appropriate company officer.
• It is never permissible to accept a gift in cash or cash equivalent such as stocks or other forms of marketable securities of any amount.

Management employees should not accept gifts from those under their supervision of more than limited value.

Conflicts of Interest

Employees should avoid any situation which involves or may involve a conflict between their personal interest and the interest of [Company Name]. As in all other facets of their duties, employees dealing with customers, suppliers, contractors, competitors or any person doing or seeking to do business with the company are to act in the best interest of the company.  Each employee shall make prompt and full disclosure in writing to their manager of any potential situation which may involve a conflict of interest. Such conflicts include:

Ownership by an employee or by a member of their family of a significant interest in any outside enterprise which does or seeks to do business with or is a competitor of the company.

Serving as a director, officer, partner, consultant, or in a managerial or technical capacity with an outside enterprise which does or is seeking to do business with or is a competitor of the company. Exceptions to this can be approved by the chief executive officer of [Company Name].  

Acting as a broker, finder, go-between or otherwise for the benefit of a third party in transactions involving or potentially involving [Company Name] or its interests.

Any other arrangements or circumstances, including family or other personal relationships, which might dissuade the employee from acting in the best interest of the company.

Confidential Information

The revelation or use of any confidential product information, data on decisions, plans, or any other information which might be contrary to the interest of the company without prior authorization, is prohibited. The misuse, unauthorized access to, or mishandling of confidential information, particularly personnel information, is strictly prohibited and will subject an employee to discipline up to and including immediate discharge.

Compliance

Any violation of this policy will subject the employee to disciplinary action or immediate discharge. Any [Company Name] employee having knowledge of any violation of this policy shall promptly report such violation to the appropriate level of management. Each vice president and company officer of [Company Name] is responsible for compliance in their area of responsibility. When questions arise concerning any aspect of this policy, contact the corporate vice president of human resources.