Code of Ethics

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Date Submitted: 06/05/2011 06:51 PM

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VGC’s Code of Ethics

* Employees will abstain from holding financial interests that conflict with his or her job performance.

* Employees will not solicit or accept gifts from any external stakeholder, person or entity in exchange for a product or service.

* Employees will not use company time or equipment for personal gain.

* Employees will act impartial and treat all stakeholders, customers and organizations with fairness. No preferential treatment will be tolerated.

* Employees will follow all applicable state and federal laws and regulations that provide equal opportunity to all people regardless of race, color, religion, nationality, handicap, age, gender or sexual orientation.

* Employees will report any activities either internally or externally that violate applicable anti-discrimination, sexual harassment or affirmative action laws.

Very Good Consulting (VGC) will ensure that employees abide by and practice the code of ethics by developing an ethics department. The ethics department will consist of designated officers and coordinators that will perform routine surveys and investigations into ethics issues that arise within the organization. Through investigation and review of their findings, ethics officers will be able to respond and address issues and concerns. This office will be responsible for forwarding any escalated or clear violations of state and federal laws to the appropriate regulatory body for further handling.

In addition to an ethics department, management and supervisory staff will participate in focused training sessions that will teach them how to respond to allegations and violations of the code of ethics. They will also learn how to use alternative methods such as mediation (when applicable) in order to bring moral or ethics issues to quick resolution. Employees and new hires will be responsible taking a training seminar on the organization’s code of ethics policy and a review of the applicable laws will be...