Ethics Handbook

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RE: Standards of Conduct and Ethics

I. Purpose

This Code of Business Conduct and Ethics helps ensure compliance with legal requirements and our standards of business conduct. All employees of Q Company are expected to read and understand this Code of Business Conduct and Ethics, uphold these standards in day to day activities, comply with all applicable policies and procedures, and ensure that all agents and contractors are aware of, understand and adhere to these standards.

In any employment relationship, management and staff have expectations of each other and an effective and productive working relationship depends on the fulfillment of these expectations. Our Standards of Conduct and Ethics are driven by the Q Company which provides the fundamental direction on what type of organization we aspire to be and in guiding our behavior. Our Standards of Conduct and Ethics provide a framework for our behavior, the way we conduct business and the way we interact with each other. As a Q Company employee, you must conduct yourself in a diligent and professional manner, with due regard for the safety, security and integrity of the facility in which you work and well-being of everyone in the facility.

It is neither possible, nor desirable to write prescriptive policies for every situation we may face at work. The standards are general in nature and are not intended to advise in detail the appropriate behavior for every situation that may arise. Where examples are provided, they are illustrative and not exhaustive. You must use judgment in applying the standards to specific factual settings and you should seek guidance from supervisory personnel when appropriate. Accordingly, it is important that we all comply with the spirit of the Standards of Conduct which relies on the notion of everyone accepting personal responsibility for their behavior. This Code of Business Conduct and Ethics supersedes all other...