Avoiding Questionable or Illegal Practices

The Company’s policy is to comply with all laws and regulations that apply to its business, and to avoid any activity that may be regarded as questionable or unethical.  Fraudulent, illegal or unethical acts will not be tolerated.  No action that would otherwise be questionable is permissible simply because it is customary in a particular location or business.

If you are confronted with a situation that raises an issue under this policy, ask yourself these questions:

• Is the life, health or safety of anyone, or the environment, endangered by the action?
• Is it legal?
• Does it feel honest, fair and ethical?
• Does it compromise anyone’s trust or integrity?
• Would the public disclosure of the activity in any way be embarrassing to you, the Company or any other affected employees?

You should be sufficiently familiar with any laws and regulations that apply to your area of work and responsibility.  That will permit you to recognize possible breaches of the law and to know when to seek legal advice.  If in doubt, you should discuss the matter with a member of senior management.