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The Company is committed to operating its business in accordance with the highest level of integrity and ethics standards. The Company wants to make sure that everyone who does business on behalf of the Company fully understands what this Code requires, and is able to ask questions if advice is needed. Should an improper practice or irregularity occur within the Company, we are committed to correcting the problem and taking appropriate steps to ensure it does not happen again.
Not all situations will be clear-cut. They may present us with difficult choices. We cannot possibly anticipate all situations and conduct that may fall under the Code of Ethics. If you are unsure of what the Code requires, are concerned that the Company may be in violation of law, or feel that the Company Code of Ethics or another policy is being violated, you should follow these guidelines:
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Get the facts. |
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- It is difficult to determine a course of action without accurate data.
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Ask yourself these questions about the conduct at issue: |
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- Is it legal?
- Does it violate our Code of Ethics?
- Is it consistent with our Core Values?
- Is it fair and just?
- How would it look in a newspaper article?
- What would my family think?
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If the answers lead you to believe there may be a violation of the Code of Ethics or other Company policy, you should take one or both of the following actions:
Seek further clarification or guidance from the Legal Department or Internal Auditing;
Contact the Company's Compliance reporting hotline (888-881-7907) to report the possible violation in a completely anonymous manner.
We encourage you to come forward with questions and to report possible irregularities. You will be protected from any adverse consequences as a result of coming forward. All associates have a responsibility to the Company and to each other to make sure this Code of Ethics is followed in all our business dealings. |
