Ethics and Code of Conduct Program Establishment and Maintenance

Ethics and Code of Conduct Program
Ethical standards and the law

All your employees, officers and directors must read and use this code of conduct to ensure that each business decision follows the commitment to the highest ethical standards and the law. Adherence to the code and to other official policies is essential to maintaining and furthering our reputation for fair and ethical practices among your patrons, stakeholders, and employees, and within the broader community.

It is the responsibility of every employee to comply with all applicable laws and regulations, all provisions of the Code of Conduct and related policies and procedures. Each employee must report any violations of the law or the code. Failure to report such violations, and failure to follow the provisions of the code may have serious legal consequences and will be disciplined by the company.
Conflicts of Interest

The employees must all be able to perform our duties and exercise judgment on behalf of the company without influence or impairment, interest or relationship that arises outside of work. When our loyalty to the company is affected by actual or potential benefit or influence from an outside source, a conflict of interest exists. The company should all be aware of any potential influences that impact or appear to impact to the company. You should avoid situations where your personal interests conflict, or appear to conflict, with those of the company.

Examples can include; Doing business with family members, participating in employment-related decisions affecting family members, including hiring, termination, promotion and/or performance evaluation matters, having a financial interest in another company with whom we do business, taking a second job, managing your own business, serving as a director of another business or in other organizations and diverting a business opportunity from the company.

The Ethics and Code of Conduct Program should address: Accepting Gifts and Entertainment, political Activity, responding to Inquiries from the Press, safeguarding Corporate Assets and Confidential Information

Employees have a responsibility to protect company assets entrusted to us from loss, theft, misuse and waste. Company assets and funds may be used only for business purposes and may never be used for illegal purposes.

Record Retention

Record Retention

Company records should be retained or discarded in accordance with the record retention policies and all applicable laws and regulations. From time to time employees are involved in legal proceedings that may require us to make some of our records available to third parties. It is a crime to alter, destroy, modify or conceal documentation or other objects that are relevant to a government investigation or otherwise obstruct, influence or impede an official proceeding.

If the existence of a subpoena or a pending government investigation is known or reported to you, you should immediately contact the Legal Department and you must retain all records that may pertain to the investigation or be responsive to the subpoena.
Accuracy of Company Records

All information you record or report must be done accurately and honestly. All records must be maintained in reasonable and appropriate detail, must be kept in a timely fashion, and must appropriately reflect transactions. Falsifying records or keeping unrecorded funds and assets is a severe offense and may result in prosecution or loss of employment. When a payment is made, it can only be used for the purpose spelled out in the supporting document.

Administration of the Code

All directors, officers and employees will receive a copy of this code when they join the company and sign an acknowledgement that they understand its contents. Updates of the code will be distributed to all directors, officers and employees.

Supervisors and Officers
Supervisors and officers have important roles under the code and are expected to demonstrate their personal commitment to the code by fostering a workplace environment that promotes compliance with the code and by ensuring that employees under their supervision participate in the company’s compliance training programs.
Reporting Violations

All employees are obliged to report violations of this code or the law and to cooperate in any investigations into such violations. Preferably, that you give your identity when reporting violations, to allow the company to contact you in the event further information is needed to pursue an investigation, and the identity of th4e employee will be maintained in confidence to the extent practicable under the circumstances and consistent with enforcing this code. However, you may anonymously report violations.


The company will initiate a prompt investigation following any credible indication that a breach of law or the code may have occurred. We will also initiate appropriate corrective action as we deem necessary, which may include notifying appropriate authorities.

Disciplinary Action

If an employee violates any provision of the code, you may be subject to disciplinary action, up to and including discharge. Please be aware that we may seek civil remedies from you and if your violation results in monetary loss, the employee may be required to reimburse us for that loss. If the employee is involved in a violation, the fact that you reported the violation, together with the degree of cooperation displayed and whether the violation is intentional or unintentional, will be given consideration in the investigation and any resulting disciplinary action.

No Retaliation

There will not retaliate against anyone who, in good faith, notifies us of a possible violation of law or this code, nor will we tolerate any harassment or intimidation of any employee who reports a suspected violation.

Adhering to the code is essential. Personally, take the time to study the Ethics and Code of Conduct Program carefully and encourage other employees to do the same. Ultimately, the most valuable asset to a company is the reputation. Complying with the principles and standards contained in the code is the starting point for protecting and enhancing that reputation.

William Owen Logan


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