________________________will
conduct its business honestly and ethically wherever we. We will constantly
improve the quality of our services, products and operations and will maintain
a reputation for honesty, fairness, respect, responsibility, integrity, trust
and sound business judgment. We will not compromise our principles for
short-term gain. No illegal or unethical conduct on the part of officers,
managers, employees or affiliates is in the company’s best interest. The
ethical performance of this company is the sum of the ethics of the men and
women who work here. Thus, we are all expected to adhere to high standards of
personal integrity.
Officers, managers, and employees
of the company must never permit their personal interests to conflict, or even
appear to conflict, with the interests of the company, its clients or
affiliates. Officers, managers and employees must be particularly careful to
avoid representing ________________________in any transaction with others with
whom there is any outside business affiliation or relationship. Officers,
managers, and employees shall avoid using company contacts to advance their
private business or personal interests at the expense of the company, its
clients or affiliates.
No bribes, kickbacks or other
similar remuneration or consideration shall be given to any person or
organization in order to attract or influence business activity. Officers,
managers and employees shall avoid gifts, gratuities, fees, bonuses or
excessive entertainment, in order to attract or influence business activity.
We will often come into contact
with, or have possession of, proprietary, confidential or business-sensitive
information and must take all appropriate steps to assure that the confidentiality
of such information is maintained. This information—whether it belongs to our company
or any of our clients or affiliates – may include strategic business plans,
operating results, marketing strategies, customer lists, personnel records,
upcoming acquisitions and divestitures, new investments, or manufacturing
costs, processes and methods. Proprietary, confidential and sensitive business
information about our company, other companies, individuals and entities must
be treated with sensitivity and discretion and only be disseminated on a need-to-
know basis.
Any misuse of material inside
information in connection with trading in the company’s securities can expose
an individual to civil liability and penalties under the Securities Exchange
Act. Under this Act, managers, officers, and employees in possession of
material information not available to the public are “insiders.” Spouses,
friends, suppliers, brokers, and others outside the company who may have acquired
such information directly or indirectly from an officer, manager or employee
are also “insiders.” The Act prohibits insiders from trading in, or
recommending the sale or purchase of, the company’s securities, while such
inside information is regarded as “material”, or if it is important enough to
influence you or any other person in the purchase or sale of securities of any
company with which we do business, which could be affected by the inside
information. The following guidelines should be followed in dealing with inside
information:
• Until material information has
been publicly released by the company, an employee must not disclose it to
anyone except those within the company whose positions require use of that
information.
• Officers, managers and
employees must not buy or sell the company’s securities when they have
knowledge of material information concerning the company until it has been
disclosed to the public and the public has had sufficient time to absorb the information.
• Officers, managers and
employees shall not buy or sell securities of another corporation, the value of
which is likely to be affected by an action by the company of which the
employee is aware and which has not been publicly disclosed.
Officers, managers and employees
are required to report all information accurately and honestly, and as
otherwise required by applicable reporting requirements.
Officers, managers and employees
are prohibited from gathering competitor intelligence by improper means and
refrain from acting on knowledge that has been gathered in such a manner. The
officers, managers and employees of [Company Name] will seek to avoid
exaggerating or disparaging comparisons of the services and competence of their
competitors.
Officers, managers and employees
must obey all applicable Equal Employment Opportunity laws and act with respect
and responsibility towards others in all of their dealings.
Officers, managers and employees
are required to promptly disclose any unethical, dishonest, fraudulent and
illegal behavior, or any violation of company policies and procedures, directly
to management.
Violation of this Code of Ethics
will result in discipline, including possible termination. The degree of
discipline imposed may be influenced by the existence of voluntary disclosure
of any ethical violation whether or not the violator cooperated in any
subsequent investigation. If you ever have any doubt about whether your conduct
or that of anyone else meets the company’s ethical standards or compromises the
company’s reputation, please discuss it with [your manager, supervisor, human
resource department, ethics officer, etc.]
Remember that good ethics is good
business!
