Ethics

Company X – Ethics Program

Table of Contents

General Policies ----------------------------------------------- -------------------------- 1

Code of Conduct ------------------------------------------------------------------------- 2

Confidential Information--------------------------------------------------------------- 2

Delegation of Authority----------------------------------------------------------------- 3

Ethics Training --------------------------------------------------------------------------- 3

Employee Misconduct------------------------------------------------------------------- 5

Evaluating the Effectiveness of the Ethics Program------------------------------- 6

Process Improvement - Ethics Program-------------------------------------------- 6

General Policies

It is the policy of the Company to comply with all applicable laws, to act fairly, impartially, in an ethical and proper manner. The highest standards of conduct are required of our employees and all other persons who act on our behalf, which includes contractors, consultants, etc. Violations of these policies will result in disciplinary action, up to and including termination of employment. It is also Company practice to encourage everyone to ask questions, seek guidance, and express any concerns they may have.

No set policy guidelines can hope to cover all situations you may encounter. When in doubt, ask your self the questions.

* Would my actions be legal and ethical?

* Are my actions honest?

* Can I defend my actions if asked?

* Would I be offended if I heard others referencing my actions to others in commentary or conversation?

Code Of Conduct

Company X is committed to it’s integrity and maintaining the highest reputations of standards of ethical conduct in all of its directive actions. Our global success is dependent on the trusting relationships, which are built on this foundation of integrity. Our reputation is founded from the integrity of our Company...