Code of Conduct: Sox

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Date Submitted: 02/15/2015 12:19 PM

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Section 406 of the Sarbanes-Oxley (SOX) Act of 2002 discusses the Code of Ethics for Senior Financial Officers. Section 406 (c) states that the code of ethics comprises necessary standards to promote honest and ethical conduct. This conduct includes ethical handling of apparent or actual conflicts of interest between personal and professional relationships. The standards are also to promote full, fair, accurate, timely and understandable disclosure in the reports which are required to be filed by the issuer. Lastly, the code of ethics is comprised to promote compliance with applicable governmental rules and regulations. For any changes to an established code of ethics, prompt disclosure is necessary. This is to be disclosed to the public by means of the internet or any other electronic means. This step is to be made by any issuer of any change in, or waiver of the code of ethics for senior financial officers (Section 406).

Section 806 of the SOX Act of 2012 pertains to the protections afforded to whistle blowers. Employees of publicly traded companies who provide evidence of fraud are given certain protections against acts of discrimination or discipline. Section 806 says that no company may discharge, demote, suspend, threaten, harass or discriminate in any other way against any employee because of the lawful act. There are provisions in 806 that allow for an employee to file a complaint with the Secretary of Labor if that employee feels like they have been retaliated against. If the Secretary has not issued a final decision within 180 days, there will be a de novo review. A de novo review is when a district United States court will appeal the claim without regard to the amount. Section 806 also says that an employee who prevails in any section under the subsection (b)(1), Enforcement Action, shall be provided with the necessary relief can be seen in reinstatement of the same seniority status, back pay-with interest, or compensation for special...