Revised: May 18, 2017
As
a public company it is of critical importance that the Company’s reports to the
public and filings with the Securities and Exchange Commission be accurate and
timely.Depending on their position with
the Company, employees may be called upon to provide information to assure that
the Company’s public reports are complete, fair and understandable.The Company expects all of its personnel to
take this responsibility very seriously and to provide prompt and accurate
answers to inquiries related to the Company’s public disclosure requirements.
The
Finance Department bears a special responsibility for promoting integrity
throughout the organization, with responsibilities to stakeholders both inside
and outside of the Company.The Chief
Executive Officer and Finance Department personnel have a special role both to
adhere to these principles themselves and also to ensure that a culture exists
throughout the Company as a whole that ensures the fair and timely reporting of
the Company’s financial results and condition.
Because
of this special role, the Chief Executive Officer and all members of the
Company’s Finance Department are bound by the following Code of Ethics, and by
accepting this Code of Ethics, each agrees that he or she will:
Concerns about actions or circumstances that
appear inconsistent with our Code of Conduct should be dealt with as
follows:
If the matter is not resolved or if you do not
feel comfortable discussing the matter with any of the persons listed
above, you can contact the Company’s Integrity Line, which is operated by
an independent company, and report the matter, if permitted by local law.
You can contact the Integrity Line:
If the matter involves questionable accounting
or auditing matters, you can also contact the Audit Committee of the Board
of Directors:
Violations of this Code of Ethics, including failures
to report potential violations by others, will be viewed as a severe
disciplinary matter that may result in personnel action, including termination
of employment.
It
is against the Company’s policy to retaliate against any employee for good
faith reporting of violations of this Code.