CODE OF ETHICS

A strong organization is built on trust, responsibility, and respect. Maintaining a professional environment requires every employee to act with honesty, fairness, accountability, and consideration for others. The way employees make decisions, communicate, and conduct business directly influences relationships with colleagues, customers, suppliers, contractors, and other partners. Everyone is responsible for understanding the expectations connected to their role and for making choices that support ethical business practices and long-term success.

Ethical behavior begins with individual responsibility and is reinforced by leadership. Managers and supervisors are expected to demonstrate appropriate conduct, provide clear guidance, and encourage employees to follow established standards. Leaders should promote a workplace culture where employees feel comfortable asking questions, raising concerns, and making decisions based on integrity. These expectations also extend to outside organizations and individuals who provide services, products, or support to the business.

Employees should remain aware of situations that may affect their ability to make objective decisions. Personal relationships, financial interests, outside activities, family connections, investments, or secondary employment may sometimes create potential conflicts between personal interests and professional responsibilities. Any situation that could influence judgment or create the appearance of improper influence should be disclosed promptly. Seeking advice before taking action helps ensure that decisions are made fairly and appropriately.

All business activities must follow applicable laws, regulations, agreements, and internal requirements. Employees are expected to perform their duties honestly, protect organizational interests, and treat others with fairness and professionalism. When employees encounter behavior that appears inconsistent with legal or ethical expectations, they should report the matter through appropriate channels, including management, Human Resources, Legal, or other designated resources. Employees are encouraged to seek guidance whenever they are uncertain about the correct approach.

A respectful workplace depends on positive interactions among all individuals. Employees should communicate professionally and contribute to an environment free from discrimination, harassment, intimidation, retaliation, and inappropriate conduct. Employment decisions should be based on relevant qualifications, performance, business needs, and established workplace standards. Similar expectations apply to suppliers, contractors, and other external partners who interact with employees.

The organization is committed to conducting business through fair and responsible competition. Employees must not attempt to gain advantages through dishonest, illegal, or unethical methods. Confidential information, proprietary materials, trade secrets, and protected information belonging to other organizations must be respected and handled appropriately. Information obtained accidentally or through uncertain circumstances should not be used until proper guidance has been obtained.

Accurate records are essential to responsible business operations. Employees involved in financial, operational, purchasing, inventory, or administrative activities must ensure that information is complete, accurate, and properly documented. Records must reflect actual transactions and activities, and employees must never create misleading entries, hide information, manipulate reports, or interfere with authorized reviews, audits, or investigations. Transparency and accuracy are required in all official documentation.

Organizational resources must be protected and used appropriately. Company property includes physical equipment, facilities, technology systems, software, intellectual property, confidential information, business records, customer information, and employee time. Employees are responsible for preventing misuse, unauthorized access, damage, loss, or unnecessary waste. Intellectual property rights, including copyrights, trademarks, patents, and proprietary materials, must be respected at all times.

Business relationships should always be managed with professionalism and fairness. Gifts, entertainment, meals, travel arrangements, or other business courtesies must never be used to improperly influence decisions. Any exchange of hospitality should have a legitimate business purpose, remain reasonable, comply with applicable requirements, and avoid creating obligations or conflicts. Cash payments, improper incentives, and arrangements that could be viewed as bribery or unethical influence are not permitted.

Employees must avoid using their position, access, relationships, or confidential information for personal benefit. A conflict of interest may occur when personal interests interfere with professional responsibilities or appear to influence business decisions. Employees should not use business opportunities for personal advantage, provide improper benefits to relatives or close associates, or use employment-related information for unauthorized purposes. Financial or professional relationships with customers, suppliers, competitors, or other partners may require review and disclosure.

Outside activities should not interfere with workplace responsibilities. Employees must ensure that outside employment, consulting work, investments, or professional commitments do not compete with business interests or create divided loyalties. Opportunities discovered through employment should be handled according to appropriate procedures and should not automatically be treated as personal opportunities.

Protecting confidential information is a fundamental responsibility. Employees may have access to sensitive information related to business plans, financial details, customer records, employee information, supplier relationships, marketing strategies, product development, technology, or other proprietary matters. Such information should only be shared with authorized individuals who have a legitimate business need. Employees must take care to prevent accidental disclosure through conversations, documents, electronic communication, or public settings.

Personal information must also be handled responsibly. Data relating to customers, employees, partners, and other individuals should only be collected, accessed, processed, and shared for legitimate purposes. Appropriate safeguards must be maintained to prevent unauthorized access, misuse, alteration, or disclosure. Privacy responsibilities apply throughout the entire process of handling personal information.

Employees must comply with legal and regulatory requirements relevant to their responsibilities. These obligations may include rules related to anti-corruption, competition, privacy, trade controls, financial reporting, and other areas of business regulation. When legal requirements are unclear, employees should seek assistance from qualified internal resources rather than making assumptions.

Sensitive information that could affect investment decisions must be protected carefully. Employees must not misuse confidential information about the organization, business partners, customers, suppliers, or other entities for personal financial advantage. Information that has not been publicly released should not be shared improperly or used in violation of applicable investment regulations.

Employees should exercise caution when interacting with competitors or discussing commercially sensitive topics. Conversations involving pricing strategies, customers, markets, contracts, production plans, or other competitive information may create legal concerns. Employees should avoid inappropriate discussions and request guidance when necessary, especially during industry events, meetings, or informal gatherings.

Maintaining ethical standards requires employees to speak up when concerns arise. Individuals who become aware of possible misconduct, policy violations, unlawful actions, or serious workplace concerns should use approved reporting channels. Reports should include accurate information and relevant details to help the organization review the matter effectively. Employees are expected to cooperate honestly during any investigation or review process.

Individuals who raise concerns in good faith must be protected from retaliation. The organization does not permit punishment, threats, discrimination, harassment, or negative treatment against employees who report concerns or participate in investigations responsibly. Reports should be handled with appropriate care and confidentiality while allowing a fair and thorough review.

Violations of these standards may result in corrective action, disciplinary measures, termination, or other consequences depending on the circumstances. Certain actions may also create legal or regulatory consequences. The organization may take additional steps to address problems, improve processes, and prevent similar situations in the future.

Ethical guidelines cannot predict every possible workplace situation. Employees should become familiar with policies relevant to their responsibilities and ask questions whenever they need clarification. Understanding these expectations helps employees make responsible decisions and maintain a professional environment.

Employees may be required to confirm their understanding of workplace standards during onboarding or at other times as policies develop. A failure to complete an acknowledgement does not remove the responsibility to follow applicable requirements.

Questions about workplace responsibilities, ethical decisions, conflicts of interest, reporting procedures, or policy interpretation should be directed to available internal resources. Employees may contact management, Human Resources, Legal, or approved support channels for assistance. For additional guidance or inquiries, contact [email protected] or call 1-800-634-8573.