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III.
Code of Ethics
C.
Gifts and Entertainment


We do not offer or accept gifts or entertainment of
substantial value.


 

Associates may accept and give normal minimal-value business amenities that facilitate discussion of business or foster good business relations.

Business meals, drinks, tickets to sporting events, and the like, which do not exceed common courtesies are generally acceptable. However, the level of expense must be similar to what the Company's expense reimbursement policy would support, and the frequency of such meals and entertainment from one source or to one recipient cannot be excessive or unreasonable. Any entertainment for overnight or longer must be approved by the associate's supervisor. Gifts of nominal value may be accepted from or given to current or prospective customers, suppliers or vendors with whom the associate maintains an actual or potential business relationship. Cash is never an acceptable gift. Corporate and marketing events for multiple customers are not covered by this Code.

No associate should accept a gift, amenity, or other personal benefit in excess of the acceptable limits described above. These items must be refused or returned with a "thank you, but" explanation of the Company's practices. Discounts and price reductions not available to all associates are considered gifts and should not be accepted. Associates may never accept nor offer a cash gift, and are expressly prohibited from soliciting or demanding for themselves anything of value in connection with Company business.

Corporate assets shall not be used to make contributions to any political party, committee, organization or candidate. Associates shall not make any payments in the nature of a "kick-back" or "bribe" to actual or potential customers, vendors, suppliers or business partners, or to any government official.

Code of Ethics
Table of Contents
I.

Introduction from the
Leadership Team

II.
Purpose of Code of Ethics
III.
Code of Ethics
  A. Confidentiality
  B. Conflicts of Interest
  C. Gifts and Entertainment
  D.

Internal Accounting Systems and Controls;
Use of Company Assets

  E.

Insider Trading

  F.

Workplace Environment

  G.

Environmental Compliance and Protection

  H.

Use of Electronic Systems

  I.

Fair Competition

  J.

Seeking Advice and Reporting Suspected Violations

  K.

Consequence for Non-Compliance

Code of Ethics
(PDF version)