Code of Business Conduct and Ethics
In furtherance of the Company's pursuit of the objectives listed above, all employees, officers and directors shall comply with all applicable governmental laws, rules and regulations, including without limitation those regulating public accounting, securities regulation, export restrictions, trade practices and advertising, antitrust, foreign corrupt practices, and civil rights.
All employees, officers and directors shall also refrain from illegally trading the Company's securities while in possession of material, nonpublic ("inside") information. The Company's Insider Trading Policy, which is distributed to all employees, officers and directors at the time they join the Company, describes the nature of inside information and the restrictions placed on trading in the Company's stock.
In particular, no officer or employee shall:
Employees shall notify their immediate supervisor of the existence of any actual, apparent or potential conflict of interest. Conflicts or potential conflicts involving officers or directors shall be brought to the attention of the Chairman of the Company's Audit Committee.
Confidential information includes (1) information marked "Confidential," "Private," "For Internal Use Only," or similar legends, (2) technical or scientific information relating to current and future products, services or research, (3) business or marketing plans or projections, (4) earnings and other internal financial data, (5) personnel information, (6) supply and customer lists, and (7) other non-public information that, if disclosed, might be of use to the Company's competitors, or harmful to the Company or its suppliers, customers or other business partners.
To avoid inadvertent disclosure of confidential information, employees, officers and directors shall not discuss confidential information with or in the presence of any unauthorized persons, including family members and friends.
The Company's senior management or Audit Committee will investigate any reported violations and will oversee an appropriate response, including corrective action and preventative measures. Employees and officers who violate any laws, governmental regulations or this Code will face appropriate, case specific disciplinary action, which may include demotion or discharge.