Standards of Business Conduct

The Standards are designed to deter wrongdoing by the Company’s directors, officers, and employees and to promote the following:

  • Honest and ethical conduct;
  • Avoidance of conflicts of interest;
  • Full, fair, accurate, timely, and understandable disclosure in reports and documents that the Company files with, or submits to regulatory agencies and in other public communications made by the Company;
  • Compliance with applicable governmental laws, rules, and regulations;
  • Prompt reporting of any possible violations to a position identified in this Standard; and
  • Accountability for adherence to the Standard.
Respectful Work Environment
The Company is committed to fostering a work environment in which all individuals are treated with respect and dignity. Each individual should be permitted to work in a business-like atmosphere that promotes equal employment opportunities.
Prohibited Conduct
The following conduct will not be tolerated and could result in disciplinary action, including termination:

  • Any act which causes doubt about a Covered Person’s integrity, such as the falsifying of Company records and documents, competing in business with the Company, unauthorized use or disclosure of the Company’s Confidential Information, or engaging in any criminal conduct.
  • Any act which may create a dangerous situation, such as carrying weapons, firearms or explosives on Company premises or surrounding areas, assaulting another individual, or disregarding property and safety standards.
  • The use, sale or purchase or attempted use, sale or purchase of alcohol or illegal drugs while at work, or reporting to work in a condition not fit for work, such as reporting to work under the influence of alcohol or illegal drugs.
  • Insubordination, including refusal to perform a job assignment or to follow a reasonable request from a Covered Person’s manager or supervisor, or discourteous conduct toward customers, associates, or supervisors.
  • Harassment of any form including threats, intimidation, abusive behavior and/or coercion of any other person in the course of doing business.
  • Falsification or destruction of any timekeeping record, intentionally clocking in on another Covered Person’s attendance or timekeeping record, assisting another Covered Person’s tampering with their attendance record or tampering with one’s own attendance record.
  • Failure to perform work, which meets the standards/expectations of the Covered Person’s position.
  • Excessive unauthorized absenteeism, chronic tardiness, or consecutive absence of three or more days without notification or authorization.
  • Any act of dishonesty or falsification of any Company records or documents, including obtaining employment based on false, misleading, or omitted information.

Disciplinary Action
A Covered Person or the Company may terminate the employment or service relationship at will, at any time, without cause or advance notice. Thus, the Company does not strictly adhere to a progressive disciplinary system since each incident of misconduct may have a different set of circumstances or differ in its severity. The Company will take such disciplinary action as it deems appropriate and commensurate with any misconduct of the Covered Person.