Attached files
file | filename |
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S-1 - FORM S-1 - Asia Cork Inc. | akrk_s1.htm |
EX-10.15 - Asia Cork Inc. | akrk_ex1015.htm |
EX-10.14 - Asia Cork Inc. | akrk_ex1014.htm |
EX-10.10 - Asia Cork Inc. | akrk_ex1010.htm |
EX-10.6(A) - Asia Cork Inc. | akrk_ex106a.htm |
EX-10.9 - Asia Cork Inc. | akrk_ex109.htm |
EX-23.1 - Asia Cork Inc. | akrk_ex231.htm |
EX-10.12 - Asia Cork Inc. | akrk_ex1012.htm |
EX-10.6(B) - Asia Cork Inc. | akrk_ex106b.htm |
EX-10.11 - Asia Cork Inc. | akrk_ex1011.htm |
EX-10.13 - Asia Cork Inc. | akrk_ex1013.htm |
EX-10.16 - Asia Cork Inc. | akrk_ex1016.htm |
EX-10.17 - Asia Cork Inc. | akrk_ex1017.htm |
EXHIBIT
14.4
ASIA
CORK, INC.
CORPORATE CODE OF CONDUCT AND
ETHICS
FOREWORD
This
Corporate Code of Conduct and Ethics, referred to as the "Code," is intended
to
provide our associates, as defined below, with a clear understanding of the
principles of business conduct and ethics that are expected of them. The
standards set forth in the Code apply to us all. Every associate of the company
must acknowledge his or her review of and agreement to comply with the Code as a
condition of his or her relationship with the company. The term "associate"
means every full and part-time employee of the company and its subsidiaries, all
members of the company's senior management, including the company's Chief
Executive Officer and Chief Financial Officer, and every member of the company's
Board of Directors, even if such member is not employed by the
company.
Many of the
standards outlined on the following pages will be familiar, for they reflect the
fundamental values of fairness and integrity that are a part of our daily lives.
Applying these standards to our business lives is an extension of the values by
which we are known as individuals and by which we want to be known as a
company.
It is our
responsibility to conduct ourselves in an ethical business manner and also
to ensure
that others do the same. If anyone of us violates these standards, he or she can
expect a disciplinary response, up to and including termination of any
employment or other relationship with the company, and possibly other legal
action. If any breach of the Code is known to you, you are obligated to report
violations to the Corporate Compliance Officer or any member of the Audit
Committee, described in more detail in Section vm of the Code. By doing so, we
ensure that the good faith efforts of all of us to comply with the Code are not
undermined.
The ultimate
responsibility for maintaining our Code rests with each of us. As individuals
of personal integrity, we can do no less than to behave in a way that will
continue to bring credit to ourselves and our company.
While it is
impossible for this Code to describe every situation that may arise, the
standards
explained in this Code are guidelines that should govern our conduct at all
times. If you are confronted with situations not covered by this Code, or have
questions regarding the matters that are addressed in the Code, you are urged to
consult with the Corporate Compliance Officer or a member of the Audit
Committee.
The
provisions of the Code regarding the actions the company will take are
guidelines which the company intends to follow. There may be circumstances,
however, that in the company's judgment require different measures or actions
and in such cases it may act accordingly while still attempting to fulfill the
principles underlying this Code.
Page
2
I.
|
GENERAL
PRINCIPLES AND REQUIREMENTS
|
To be honest,
fair, and accountable in all business dealings and obligations, and to
ensure:
the provision
of high quality products and service on a timely basis consistent with customer
requirements, with emphasis on fair competition and long lasting relationships
with all customers and suppliers and the ethical handling of conflicts of
interest between personal and professional relationships;
full, fair,
accurate, timely and understandable disclosure in the reports required to be
filed by the company with the Securities and Exchange Commission;
compliance
with applicable governmental rules and regulations;
safe working
conditions and an environment characterized by fairness, respect for the
individual, dignity and equal opportunity; and
the pursuit
of growth and earnings objectives in accordance with the foregoing
principles.
II.
|
CONFLICTS
OF INTEREST
|
Associates
should avoid any situation that may involve, or even appear to involve,
a
conflict between their personal interests and the interests of the company. In
dealings with current or potential customers, suppliers, contractors, and
competitors, each associate should act in the best interest of the company to
the exclusion of personal advantage. Associates are prohibited from any of the
following activities which could represent an actual or perceived conflict of
interest:
No associate
or immediate family member of an associate shall have a significant financial
interest in, or obligation to, any outside enterprise which does or seeks to do
business with the company or which is an actual or potential competitor of the
company, without prior approval. No associate shall engage in activities that
are directly competitive with those in which the company is
engaged.
Page
3
No associate
shall conduct a significant amount of business on the company's behalf with an
outside enterprise which does or seeks to do business with the company if an
immediate family member of the associate is a principal, officer or employee of
such enterprise, without prior approval of the Audit Committee, or in the case
of executive officers or members of the Board of Directors, the full Board of
Directors or a committee thereof.
No associate
shall divert a business opportunity from the company to such
individual's own benefit. If an associate becomes aware of an opportunity to
acquire or profit from a business opportunity or investment in which the company
is or may become involved or in which the company may have an existing interest,
the associate should disclose the relevant facts to the Corporate Compliance
Officer or a member of the Audit Committee. The associate may proceed to take
advantage of such opportunity only if the company is unwilling or unable to take
advantage of such opportunity as notified in writing by the Audit
Committee.
No associate
or immediate family member of an associate shall receive
any loan or advance from the company, or be the beneficiary of a guarantee by
the company of a loan or advance from a third party, except for customary
advances or corporate credit in the ordinary course of business or approved by
the Audit Committee. Please see Section III.D. below, "Corporate Advances", for
more information on permitted corporate advances.
In addition,
the Board of Directors will review and approve all related-party
transactions, as required by the Securities and Exchange Commission or any other
regulatory body to which the company is subject.
Each
associate should make prompt and full disclosure in writing to the Corporate
Compliance Officer or a member of the Audit Committee of any situation that may
involve a conflict of interest. Failure to disclose any actual or perceived
conflict of interest is a violation of the Code.
III. PROTECTION
AND PROPER USE OF COMPANY ASSETS
Proper
protection and use of company assets and assets entrusted to it by others,
including
proprietary information, is a fundamental responsibility of each associate of
the company. Associates must comply with security programs to safeguard such
assets against unauthorized use or removal, as well as against loss by criminal
act or breach of trust. The provisions hereof relating to protection of the
company's property also apply to property of others entrusted to it (including
proprietary and confidential information).
A. Proper Use of Company
Property
The removal
from the company's facilities of the company's property is prohibited,
unless authorized by the company. This applies to furnishings, equipment, and
supplies, as well as property created or obtained by the company for its
exclusive use such as client lists, files, personnel information, reference
materials and reports, computer software, data processing programs and data
bases. Neither originals nor copies of these materials may be removed from the
company's premises or used for purposes other than the company's business
without prior written authorization.
The company's
products and services are its property; contributions made by any associate
to their development and implementation are the company's property and remain
the company's property even if the individual's employment or directorship
terminates.
Each
associate has an obligation to use the time for which he or she receives
compensation
from the company productively. Work hours should be devoted to activities
directly related to the company's business.
B.
Confidential Information
The company
provides its associates with confidential information relating to the
company
and its business with the understanding that such information is to be held in
confidence and not communicated to anyone who is not authorized to see it,
except as may be required by law. The types of information that each associate
must safeguard include (but are not limited to) the company's plans and business
strategy, unannounced products and/or contracts, sales data, significant
projects, customer and supplier lists, patents, patent applications, trade
secrets, manufacturing techniques and sensitive financial information, whether
in electronic or conventional format. These are costly, valuable resources
developed for the exclusive benefit of the company. No associate shall disclose
the company's confidential information to an unauthorized third party or use the
company's confidential information for his or her own personal
benefit.
C. Accurate
Records and Reporting
Under law,
the company is required to keep books, records and accounts, and retain
documents related thereto, that accurately and fairly reflect all transactions,
dispositions of assets and other events that are the subject of specific
regulatory record keeping requirements, including generally accepted accounting
principles and other applicable rules, regulations and criteria for preparing
financial statements and for preparing periodic reports filed with the
Securities and Exchange Commission. All company reports, accounting records,
sales reports, expense accounts, invoices, purchase orders,
and other documents must accurately and clearly represent the relevant facts and
the true nature of transactions. Reports and other documents should state all
material facts of a transaction and not omit any information that would be
relevant in interpreting such report or document. Under no circumstance may
there be any unrecorded liability or fund of the company, regardless of the
purposes for which the liability or fund may have been intended, or any improper
or inaccurate entry knowingly made on the books or records of the company. No
payment on behalf of the company may be approved or made with the intention,
understanding or awareness that any part of the payment is to be used for any
purpose other than that described by the documentation supporting the payment.
In addition, intentional accounting misclassifications (e.g., expense versus
capital) and improper acceleration or deferral of expenses or revenues are
unacceptable reporting practices that are expressly prohibited.
The company
has developed and maintains a system of internal controls to provide reasonable
assurance that transactions are executed in accordance with management's
authorization, are properly recorded and posted, and are in compliance with
regulatory requirements. The system of internal controls within the company
includes written policies and procedures, budgetary controls, supervisory review
and monitoring, and various other checks and balances, and
safeguards.
The company
has also developed and maintains a set of disclosure controls and procedures
to ensure that all of the information required to be disclosed by the company in
the reports that it files or submits under the Securities Exchange Act is
recorded, processed, summarized and reported within the time periods specified
by the Securities and Exchange Commission's rules and forms.
Responsibility for compliance with these
internal controls and disclosure controls and procedures rests not solely with
the company's accounting personnel, but with all associates involved in
approving transactions, supplying documentation for transactions, and recording,
processing, summarizing and reporting of transactions and other information
required by periodic reports filed with the Securities and Exchange
Commission.
Any associate
who believes the company's books and records are not in accord with
these requirements should immediately report the matter to the Corporate
Compliance Officer or a member of the Audit Committee. The company has adopted
explicit non-retaliation policies with respect to these matters, as described in
Section VIII below.
D. Corporate Advances
Under law,
the company may not loan money to associates except in limited circumstances.
It shall be a violation of the Code for any associate to advance company funds
to any other associate or to himself or herself except for usual and customary
business advances for legitimate corporate purposes which are approved by a
supervisor or pursuant to a corporate credit card for usual and customary,
legitimate business purposes. Company credit cards are to be used only for
authorized, legitimate business purposes. An associate will be responsible for
any unauthorized charges to a company credit card.
IV.
|
FAIR DEALING WITH CUSTOMERS,
SUPPLIERS, COMPETITORS, AND
ASSOCIATES
|
The company
does not seek to gain any advantage through the improper use of favors or
other inducements. Good judgment and moderation must be exercised to avoid
misinterpretation and adverse effect on the reputation of the company or its
associates.
Offering,
giving, soliciting or receiving any form of bribe to or from an employee
of a
customer or supplier to influence that employee's conduct is strictly
prohibited.
A. Giving
Gifts
Cash or
cash-equivalent gifts must not be given by an associate to any person or
enterprise.
Gifts, favors and entertainment may be given to non-governmental employees if
what IS given:
is consistent
with customary business practice;
is not
excessive in value and cannot be construed as a bribe or pay-off;
is not in
violation of applicable law or ethical standards; and
will not
embarrass the company or the associate if publicly disclosed.
See also
subsection D below for considerations relating to gifts to foreign officials and
Section V. B below for considerations relating to gifts to government
employees.
B. Receiving
Gifts
Gifts,
favors, entertainment or other inducements may not be accepted by associates
or members of their immediate families from any person or organization that does
or seeks to do business with, or is a competitor of, the company, except as
common courtesies usually associated with customary business practices. If the
gift is of more than token value, the Audit Committee must approve its
acceptance.
An especially
strict standard applies when suppliers are involved. If a gift unduly
influences
or makes an associate feel obligated to "pay back" the other party with
business, receipt of the gift is unacceptable.
It is never
acceptable to accept a gift in cash or cash equivalent.
C. Unfair
Competition and Antitrust Concerns
Although the
free enterprise system is based upon competition, rules have been imposed
stating what can and what cannot be done in a competitive environment,
including, without limitation, federal and state antitrust laws that are
intended to preserve the free enterprise system by ensuring that competition is
the primary regulator of the economy.
Compliance
with the antitrust laws is in the public interest, in the interest of the
business
community at large, and in our company's interest. A primary focus of antitrust
laws is on dealings between competitors. Another focus of antitrust law is how a
company deals with customers, suppliers, contractors and other third parties. In
all interactions with third parties all associates must follow these
rules:
Never agree
with a competitor or a group of competitors to charge the same
prices or to use the same pricing methods, to allocate services, customers,
private or governmental payor contracts or territories among yourselves, to
boycott or refuse to do business with a provider, vendor, payor or any other
third party, or to refrain from the sale or marketing of, or limit the supply
of, particular products or services.
Never discuss
past, present, or future prices, pricing policies, bundling, discounts
or allowances, royalties, terms or conditions of sale, costs, choice of
customers, territorial markets, production quotas, allocation of customers or
territories, or bidding on a job with a competitor.
Make every
output-related decision (pricing, volume, etc.) independently, in light
of costs and market conditions and competitive prices.
Engage in
other prohibited activity, such as illegal price discrimination, reciprocal
buying and selling or tying of products, and trade restraint
Be careful of
your conduct. An "agreement" that violates the antitrust laws may be
not only a written or oral agreement, but also a "gentlemen's agreement" or a
tacit understanding. Such an "agreement" need not be in writing. It can be
inferred from conduct, discussions or communications of any sort with a
representative of a competitor.
In addition,
the following practices can lead to liability for "unfair competition"
and
should be avoided. They are violations of the Code.
Disparagement of Competitors. It
is not illegal to point out weaknesses in a
competitor's service, product or operation; however, associates may not spread
false rumors about competitors or make misrepresentations about their
businesses. For example, an associate may not pass on anecdotal or unverified
stories about a competitor's products or services as the absolute truth (e.g.,
the statement that "our competitors' diagnostic testing procedures have poor
quality control").
Disrupting a Competitor's
Business. This includes bribing a competitor's
employees, posing as prospective customers or using deceptive practices such as
enticing away employees in order to obtain secrets or destroy a
competitor's
organization.
For example, it is not a valid form of "market research" to visit a competitor's
place of business posing as a customer.
Finally,
always immediately inform the Corporate Compliance Officer or the Audit
Committee if local, state or federal law enforcement officials request
information from the company concerning its operations.
D. Unfair
Practices in International Business
Page 9
Under the
Foreign Corrupt Practices Act ("FCPA"), associates of the company are
prohibited
from making certain gifts to foreign officials. "Foreign officials" include not
only persons acting in an official capacity on behalf of a foreign government,
agency, department or instrumentality, but also representatives of international
organizations, foreign political parties and candidates for foreign public
office. The gift is "corrupt" under the FCP A if it is made for the purpose
of:
Influencing
any act or decision of a foreign official in his official capacity;
Inducing a
foreign official to do or omit to do any act in violation of his lawful
duty;
Inducing a
foreign official to use his position to affect any decision of the government;
or
Inducing a
foreign official to secure any "improper advantage."
A gift is
still "corrupt" even when paid through an intermediary. Any associate
who has
any questions whatsoever as to whether a particular gift might be "corrupt"
under the FCP A, please contact the Corporate Compliance Officer or any member
of the Audit Committee.
V.
|
GOVERNMENT
RELATIONS
|
Associates
must adhere to the highest standards of ethical conduct in all relationships
with government employees and must not improperly attempt to influence the
actions of any public official.
A. Government
Procurement
The U.S.
Government and many state and local governments have adopted comprehensive
laws and regulations governing their purchases of products from private
contractors. These laws and regulations are intended to assure that governmental
entities receive pricing, terms, and conditions equivalent to those granted to
the company's most favored commercial customers and that there is full and open
competition in contracting.
When selling
products or services to government procurement agencies, the company is
accountable for complying with all applicable procurement laws, regulations, and
requirements. Certifications to, and contracts with, government agencies are to
be signed by a company associate authorized by the Board of Directors to sign
such documents, based upon knowledge that all requirements have been fully
satisfied.
B. Payments to
Officials
Payments or
gifts shall not be made directly or indirectly to any government official
or associate if the gift or payment is illegal under the laws of the country
having jurisdiction over the transaction, or if it is for the purpose of
influencing or inducing the recipient to do, or omit to do, any act in violation
of his or her lawful duty. Under no circumstances should gifts be given to
employees of the United States Government.
C. Political
Contributions
Company
funds, property or services may not be contributed to any political party
or
committee, or to any candidate for or holder of any office of any government.
This policy does not preclude, where lawful, company expenditures to support or
oppose public referendum or separate ballot issues, or, where lawful and when
reviewed and approved in advance by the Audit Committee, the formation and
operation of a political action committee.
VI.
|
COMPLIANCE WITH LAWS, RULES AND
REGULATIONS
|
All employees
must comply with the laws and regulations applicable to the nation,
state and localities in which they do business. Without limiting the
foregoing:
A. Insider
Trading Policy
The company
expressly forbids any associate from trading on material non-public information
or communicating material non-public information to others in violation of the
law. This conduct is frequently referred to as "insider trading." This policy
applies to every associate of the company and extends to activities both within
and outside their duties to the company, including trading for a personal
account.
The concept
of who is an "insider" is broad. It includes officers, directors and
employees
of a company. In addition, a person can be a "temporary insider" if he or she
enters into a special confidential relationship in the conduct of a company's
affairs and as a result is given access to information solely for the company's
purpose. A temporary insider can include, among others, a company's investment
advisors, agents, attorneys, accountants and lending institutions, as well as
the employees of such organizations. An associate may also become a temporary
insider of another company with which our company
has a contractual relationship, to which it has made a loan, to which it
provides advice or for which it performs other services.
Trading on
inside information is not a basis for liability unless the information is
material. This is information that a reasonable investor would consider
important in making his or her investment decisions, or information that is
likely to have a significant effect on the price of a company's
securities.
Information
is non-public until it has been effectively communicated to the marketplace.
Tangible evidence of such dissemination is the best indication that the
information is public. For example, information found in a report filed with the
Securities and
Exchange Commission or appearing in a national newspaper would be considered
public.
B. Equal Employment
Opportunity
The company
makes employment-related decisions without regard to a person's race,
color, religious creed, age, sex, sexual orientation, marital status, national
origin, ancestry, present or past history of mental disorder, mental
retardation, learning disability or physical disability, including, but not
limited to, blindness and genetic predisposition, or any other factor unrelated
to a person's ability to perform the person's job. "Employment decisions"
generally mean decisions relating to hiring, recruiting, training, promotions
and compensation, but the term may encompass other employment actions as
well.
The company
encourages its associates to bring any problem, complaint or concern
regarding any alleged employment discrimination to the attention of Corporate
Compliance Officer or a member of the Audit Committee.
C. Sexual
Harassment Policy
The company
is committed to maintaining a collegial work environment in which all
individuals are treated with respect and dignity and which is free of sexual
harassment. In keeping with this commitment, the company will not tolerate
sexual harassment of associates by anyone, including any supervisor, co-worker,
vendor, client or customer, whether in the workplace, at assignments outside the
workplace, at company-sponsored social functions or elsewhere.
D. Health, Safety & Environment
Laws
Health,
safety, and environmental responsibilities are fundamental to the company's
values. Associates are responsible for ensuring that the company complies with
all provisions of the health, safety, and environmental laws of the United
States and of other countries where the company does business.
Page
12
The penalties
that can be imposed against the company and its associates for failure to comply
with health, safety, and environmental laws can be substantial, and include
imprisonment and fines.
VII.
|
IMPLEMENTATION OF THE
CODE
|
The company's
Board of Directors has appointed the Audit Committee to administer,
update and enforce the Code. Ultimately, the Board of Directors of the company
must ensure that the Audit Committee fulfills its responsibilities. As further
set forth in Section VIII below, the company has attempted to design procedures
that ensure maximum confidentiality and, most importantly, freedom from the fear
of retaliation for complying with and reporting violations under the
Code.
The Audit
Committee, which has overall responsibility for overseeing the implementation
of the Code, shall appoint a Corporate Compliance Officer to implement the Code.
Unless otherwise designated by the Audit Committee, the Chief Financial Officer
shall serve as the Corporate Compliance Officer. Specific responsibilities of
the position are to:
Ensure that
the Code is distributed to all associates and that all associates acknowledge
the principles of the Code;
Implement a
training program around the Code;
Audit and
assess compliance success with the Code;
Serve as a
point person for reporting violations and asking questions under the Code;
and
Revise and
update the Code to respond to detected violations and changes in the
law.
The Corporate
Compliance Officer shall promptly report all violations and suspected violations
of the Code to the Audit Committee. The primary responsibilities of the Audit
Committee, in its oversight of the Code, are to:
Page
13
Assist the
Corporate Compliance Officer in developing and updating the Code;
Monitor and
audit compliance with the Code;
Serve as
point persons for reporting violations and asking questions under the
Code;
Conduct
internal investigations, with the assistance of counsel, of suspected compliance
violations;
Evaluate
disciplinary action for associates who violate the Code;
In the case
of more severe violations of the Code, make recommendations regarding
disciplinary action to the Board of Directors or a committee thereof;
and
Evaluate the
effectiveness of the Code and improve the Code.
The Audit
Committee will provide a summary of all matters considered under
the
Code to
the Board of Directors at each regular meeting thereof, or sooner if warranted
by the severity of the matter. All proceedings and the identity of the person
reporting will be kept as confidential as practicable under the
circumstances.
VIII.
|
REPORTING
VIOLATIONS UNDER THE CODE:
NON-RETALIATION
|
POLICY
Any associate
of the company having any information or knowledge regarding the
existence of any violation or suspected violation of the Code has a duty to
report the violation or suspected violation to the Corporate Compliance Officer
or any member of the Audit Committee. Failure to report suspected or actual
violations is itself a violation of the Code and may subject the associate to
disciplinary action, up to and including termination of employment or legal
action. The company will endeavor to keep reports confidential to the fullest
extent practicable under the circumstances.
Any associate
who reports a suspected violation under the Code by the company, or its
agents acting on behalf of the company, to the Corporate Compliance Officer or
any member of the Audit Committee, may not be fired, demoted, reprimanded or
otherwise harmed for, or because of, the reporting of the suspected violation,
regardless of whether the suspected violation involves the associate, the
associate's supervisor or senior management of the company.
In addition,
any associate who reports a suspected violation under the Code which
the
associate reasonably believes constitutes a violation of a federal statute by
the company, or its agents acting on behalf of the company, to a federal
regulatory or law enforcement agency, may not be reprimanded, discharged,
demoted, suspended, threatened, harassed or in any manner discriminated against
in the terms and conditions of the associate's employment for, or because of,
the reporting of the suspected violation, regardless
of whether the suspected violation involves the associate, the associate's
supervisor or senior management of the company.
IX.
|
QUESTIONS
UNDER THE CODE AND WAIVER
PROCEDURES
|
Associates
are encouraged to consult with the Corporate Compliance Officer and Audit
Committee about any uncertainty or questions they may have under the
Code.
If any
situation should arise where a course of action would likely result in a
violation
of the Code but for which the associate thinks that a valid reason for the
course of action exists, the associate should contact the Corporate Compliance
Officer or a member of the Audit Committee to obtain a waiver prior to the time
the action is taken. Except as noted below, the Audit Committee will review all
the facts surrounding the proposed course of action and will determine whether a
waiver from any policy in the Code should be granted. It is the company's policy
only to grant waivers from the Code in limited and compelling
circumstances.
Waiver
Procedures for Executive Officers and Directors. Waiver requests by an
executive
officer or member of the Board of Directors shall be referred by the Audit
Committee, with its recommendation, to the Board of Directors or a committee
thereof for consideration. If either (i) a majority of the independent directors
on the Board of Directors, or (ii) a committee comprised solely of independent
directors agrees that the waiver should be granted, it will be granted. If
required to comply with applicable law, the company will disclose the nature and
reasons for the waiver on a Form 8-K to be filed promptly with the Securities
and Exchange Commission or as otherwise as required by the Securities and
Exchange Commission. If the Board denies the request for a waiver, the waiver
will not be granted and the associate may not pursue the intended course of
action.
APPENDIX
ASSOCIATE'S
AGREEMENT TO COMPLY
I have
read the Asia Cork, Inc. Corporate Code of Conduct and Ethics (the
"Code"). I have obtained an interpretation of any provision about which I had a
question. I agree to abide by the provisions of the Code. Based on my review, I
acknowledge that
To the best
of my knowledge, I am not in violation of, or aware of any violation
by others
of, any provision contained in the Code;
OR
I have
made a full disclosure on the reverse side of this acknowledgment of the
facts
regarding any possible violation of the provisions set forth in the
Code.
In addition,
I understand that I am required to report any suspected or actual violation
of the Code. I understand that I am required to cooperate fully with the company
in connection with the investigation of any suspected violation. I understand
that my failure to comply with the Code or its procedures may result in
disciplinary action, up to and including termination.
By:
__________________________________
Date:
_________________________________
Name
(Please print): _____________________
Department/Location:
____________________