Code of Business Conduct & Ethics
 Record Keeping
Financial statements and the books and records on which they are based must accurately reflect all corporate transactions. All receipts and disbursements of Company funds must be properly recorded in the books, and records must disclose the nature and purpose of the Company’s transactions. All records and transactions are subject to review by internal and external auditors. Full cooperation with the auditors is expected and under no circumstances will any relevant information be intentionally withheld from them.
The following requirements apply to all Company records:
Business records and communications often become public, and we will avoid exaggeration, derogatory remarks, guesswork or inappropriate characterizations of people and companies that can be misunderstood. This applies equally to e-mails, internal memos and formal reports. Records will always be retained or destroyed according to our record retention policies.
Political Contributions and Activities
We encourage our staff to maintain an interest in political matters in their home country, but recognize that participation in politics is primarily a matter of individual choice. Involvement and participation in political activities must be on an individual basis.
No Company funds or assets, including the work time of an employee, will be contributed, loaned, or made available, directly or indirectly, to any political party or to the campaign of any candidate for political office.
Prohibited Payments
It is our policy to deal with clients and suppliers, and the governments of all jurisdictions in which we operate, in a straightforward and aboveboard manner.
In addition to other standards of conduct set forth in this Code, staff may not directly or indirectly offer or provide any gift, gratuity, or entertainment as a bribe, kickback, or other payment to any government official or employee to obtain or retain business or special concessions.
Similarly, staff are not authorized to make payments as a bribe, kickback or other payment, including commissions, finder’s fees, etc., to employees of other companies or organizations, directly or indirectly, for the purpose of obtaining favorable treatment in securing business or otherwise obtaining special concessions from such other companies or organizations.
Retaining Agents, Consultants and Representatives
Our agents, consultants and representatives are expected to comply with the applicable provisions of this Code. Staff may not hire or retain any person or entity to assist with the acquisition, development or retention of business until the Company has received full details regarding the background and reputation of the individual or entity to be hired or retained. In addition, staff may not hire or retain any person or entity other than pursuant to a written agreement which has been approved in advance by the President of the relevant operating company and by the General Counsel or his designee.
Competition and Fair Dealing
We seek to outperform our competition fairly and honestly. We seek competitive advantages through superior performance, never through unethical or illegal business practices. Stealing proprietary information, possessing trade secret information that was obtained without the owner’s consent, or inducing such disclosures by past or present employees of other companies is prohibited. Our staff will endeavor to respect the rights of and deal fairly with customers, suppliers, competitors and employees. Our staff will not take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or any other intentional unfair-dealing practice.
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