Here is a example of a "CODE OF BUSINESS CONDUCT AND ETHICS " for Mark and Brett to look at since it seems like they forgot about their responsibilities:
This Code of Business Conduct and Ethics (the "Code") of XXXXX Holdings Inc. ("XXXXX3", or the "Corporation") and its subsidiaries and affiliates is intended to document the principles of conduct and ethics to be followed by the Corporation's directors, officers employees and where practical, key consultants (being, those who are engaged in an employee-like capacity) (collectively, the "Personnel") of the Corporation. The Code applies to interpersonal and electronic communications. Its purpose is to:
Reiterate XXXXX’s commitment to full compliance by the Corporation, its subsidiaries
and affiliates, and its Personnel with the United States’ Foreign Corrupt Practices Act
("FCPA"), Canada’s Corruption of Foreign Public Officials Act ("CFPOA"), and any local
anti-bribery or anti-corruption laws that may be applicable;
Promote fair dealing with the Corporation's customers, suppliers, competitors and other
third parties;
Promote honest and ethical conduct, including the ethical handling of actual or apparent
conflicts of interest between personal and professional relationships;
Promote avoidance of conflicts of interest, including disclosure to an appropriate person of
any material transaction or relationship that reasonably could be expected to give rise to
such a conflict;
Promote full, fair, accurate, timely and understandable disclosure in reports and documents
that the Corporation files with, or submits to, the relevant regulatory authorities in Canada
and each province thereof, and in other information disseminated to the public;
Promote compliance with applicable governmental laws, rules and regulations as well as
the rules of the Canadian Securities Exchange;
Promote the prompt internal reporting to an appropriate person of violations of this Code;
Promote accountability for adherence to this Code, the FCPA and the CFPOA;
Provide guidance to Personnel to help them recognize and deal with ethical issues;
Promote a workplace free from bullying and harassment;
Provide mechanisms to report unethical or inappropriate conduct; and
Help foster a culture of honesty and accountability.
