VAPEs "CODE OF CONDUCT AND ETHICS" (from the latest 10-Q 5/15/15)
Last Reviewed and Accepted on May 11, 2015
This Code has been created to promote transparency of the corporation and to ensure the integrity of the
corporation. ... In order for all Members (as defined herein) to uphold this Code, it should be remembered that the spirit of the Code is far more important than the specific written word. Where an infringement by any member of this Code is observed, it should be reported to the appropriate person and if required the full Board.
1. Introduction
The Board of the Company has adopted this Code, which is applicable to all its officers, directors and employees(collectively the “Members”), to:
2. Honest and Ethical Conduct (this is funny)
Each member owes a duty to the Company to act with
integrity. Integrity requires, among other things, being honest and candid. Deceit, dishonesty and subordination of principle are inconsistent with integrity. Service to the Company should never be subordinated to personal gain an advantage.
Specifically, each Member must:
? promote honest and ethical conduct, including the ethical handling of actual or apparent conflicts of
interest between personal and professional relationships;
Avoid conflicts of interest or the appearance of conflicts of interest wherever possible. Anything that would be a conflict for a Member will also be a conflict if it is related to a member of his or her family or a close relative.
Examples of conflict of interest situations, if material, include, but are not limited to, the following:
? any significant ownership interest in any supplier
or customer;
? any consulting or employment relationship with any
customer, supplier or competitor;
? any outside business activity that detracts from an
individual's ability to devote appropriate time and attention to his or her responsibilities with the Company
Seems someone may have some reporting to do to the board. I have a feeling the "board" already knows. Certainly the filing with the SEC was AFTER the creation of some of these insider held companies. I dont see any mention of them in the SEC filing. The "board" must have decided that owning these 14 new companies themselves was not a conflict of interest or did not create the appearance of a conflict of interest. Quite a decision. Borderline what?
All info is from public sources. Opinions are mine alone. Everyone should do their own DD.
AI
