CODE OF ETHICS
[YOUR COMPANY NAME]
[YOUR COMPANY NAME] will conduct its business honestly and ethically wherever we operate in the
world. We will constantly improve the quality of our services, products and operations and will create a
reputation for honesty, fairness, respect, responsibility, integrity, trust and sound business judgment. No
illegal or unethical conduct on the part of officers, directors, employees or affiliates is in the company’s
best interest. [YOUR COMPANY NAME] will not compromise its principles for short-term advantage. The
ethical performance of this company is the sum of the ethics of the men and women who work here.
Thus, we are all expected to adhere to high standards of personal integrity.
Officers, directors, and employees of the company must never permit their personal interests to conflict,
or appear to conflict, with the interests of the company, its clients or affiliates. Officers, directors and
employees must be particularly careful to avoid representing [YOUR COMPANY NAME] in any
transaction with others with whom there is any outside business affiliation or relationship. Officers,
directors, and employees shall avoid using their company contacts to advance their private business or
personal interests at the expense of the company, its clients or affiliates.
No bribes, kickbacks or other similar remuneration or consideration shall be given to any person or
organization in order to attract or influence business activity. Officers, directors and employees shall avoid
gifts, gratuities, fees, bonuses or excessive entertainment, in order to attract or influence business
activity.
Officers, directors and employees of [YOUR COMPANY NAME] will often come into contact with, or have
possession of, proprietary, confidential or business-sensitive information and must take appropriate steps
to assure that such information is strictly safeguarded. This information
–
whether it is on behalf of our
company or any of our clients or affiliates
–
could include strategic business plans, operating results,
marketing strategies, customer lists, personnel records, upcoming acquisitions and divestitures, new
investments, and manufacturing costs, processes and methods. Proprietary, confidential and sensitive
business information about this company, other companies, individuals and entities should be treated with
sensitivity and discretion and only be disseminated on a need-to-know basis.
Misuse of material
inside information in connection with trading in the company’s securities can expose
an individual to civil liability and penalties under the [ACT]. Under this Act, directors, officers, and
employees in possession of material information not available to t
he public are “insiders.” Spouses,
friends, suppliers, brokers, and others outside the company who may have acquired the information
directly or indirectly from a director, officer or employee are also “insiders.” The Act prohibits insiders from
trading in
, or recommending the sale or purchase of, the company’s securities, while such inside
information is regarded as “material”, or if it is important enough to influence you or any other person in
the purchase or sale of securities of any company with which we do business, which could be affected by
the inside information. The following guidelines should be followed in dealing with inside information:
Until the material information has been publicly released by the company, an employee must not
disclose it to anyone except those within the company whose positions require use of the
information.
Employees must not buy or sell the company’s securities when they have knowledge of material
information concerning the company until it has been disclosed to the public and the public has
had sufficient time to absorb the information.
Employees shall not buy or sell securities of another corporation, the value of which is likely to be
affected by an action by the company of which the employee is aware and which has not been
publicly disclosed.
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