Have a few more before reading further.
It is the policy of the Company that each Senior Officer:
Act honestly, ethically and with integrity.
Avoid situations in which their personal, family or financial interests conflict or appear to conflict with those of the Company, and disclose promptly any actual or apparent conflict of interest to the Company’s Audit Committee. Conflicts of interest include, without imitation, the following:
Engaging in any activity that interferes with such Officer’s performance of his or her responsibilities to the Company or is otherwise in conflict with or prejudicial to the Company (including accepting simultaneous employment with a Company supplier, customer, developer or competitor, or taking part in any activity that enhances or supports a competitor’s position);
Serving as a director of any company that competes with the Company or failing to obtain prior Audit Committee approval for serving as a director of a Company supplier, customer, developer or other business partner;
Conducting Company business with a relative or significant other, or with a business in which a relative or significant other is associated in any significant role, or employing any such individual in positions that have a financial dependence or influence;
Accepting any offer, payment, promise to pay, or authorization to pay any money, gift, or anything of value from customers, vendors, consultants, etc. that is perceived as intended, directly or indirectly, to influence any business decision, any act or failure to act, any commitment of fraud, or opportunity for the commission of fraud (except for inexpensive gifts, infrequent business meals, celebratory events and entertainment, provided they are not excessive and do not create an appearance of impropriety); and
Exploiting for personal gain opportunities that are discovered through the use of and control over corporate property, information or position unless the opportunity is disclosed fully in writing to the Company’s Board of Directors and the Board of Directors declines to pursue such opportunity.
Perform responsibilities with a view to causing disclosure in the Company’s public communications, including its periodic reports filed with the SEC, to be accurate, complete, fair, relevant, objective, understandable and timely.
Comply with applicable governmental laws, rules and regulations of the United States and of the jurisdictions in which the Company conducts business, and acquire appropriate knowledge of such laws, rules and regulations relating to the Senior Officer’s duties sufficient to enable the Senior Officer to recognize potential dangers and to know when to seek advice from the Company’s Audit Committee.
Promote ethical behavior among subordinates and peers.
Use corporate assets and resources employed or entrusted in a responsible manner.
Report promptly any conduct that the Senior Officer believes to be a violation of the Code to the Company’s Audit Committee and cooperate in any internal or external investigations of possible violations. The Company will not intentionally retaliate in any manner against anyone for good faith reporting of violations of applicable law, this Code or any other Company policy, or against any person who is assisting in any investigation or process with respect to such a violation.
In cases, if you are unsure about the appropriateness of an event or action, you should seek assistance in interpreting the requirements of this Code by contacting the Company’s Audit Committee.