Task 2

Est1 Task 2

ETHICS PROGRAM

A. Code of Ethics

1. Dealings with Government Officials

It is policy of the company to comply fully with all state and federal laws and regulations. The behavior of every employee is required to signal the company’s desire to conduct relations with government officials and agencies in compliance with all applicable laws and regulations.

2. Gifts and Payments

Company employees must be careful that their conduct cannot rationally be construed as a bribe or other inappropriate enticement to perform a business act or improperly influence the recipient.

Examples of gifts and payments include but are not limited to: meals, travel and travel accommodations, tickets to sporting events, gift certificates, wine or alcohol, and any other merchandise or service.

3. Unfair Trade Practices

Unfair or misleading practices or manner of competition, such as false advertising, spreading of rumors or false statements aiming to harm competitors or their products/services and give the company an unfair advantage in the marketplace are forbidden. In addition, employees are also prohibited from making or publishing false or misleading statements to customers, potential customers or any other person or entity information about the nature, quality or performance of any company activity or the terms or conditions of sales or marketing proposals.

4. Conflicts of Interest

It is the company’s policy that all employees avoid business and personal circumstances that can escalate to conflicts of interest. A “conflict of interest” happens when an employee’s personal activity interferes with – or appears to interfere with – the interests of the company as a whole. Conflicts of interest may also arise when employee or their immediate family receives inappropriate gain as a result of their position the company. “Immediate family” includes but is not limited to an employee’s spouse, parents, children, siblings, in-laws, and anyone residing in...