Code of Business Conduct – Conflicts of Interest

• Core Values
• Mission Statement
• Understanding the Code
  • Summary
  • Your Expectations
• Creating a Successful Work Process
  • Our Expectation
  • Equal Oppurtunity
• Record Keeping
• Conflicts of Interest
• Confidentiality
• PACA
• Labor Policy
• Worker’s Contract

Conflicts of Interest

A basic principle of ethical business conduct requires that each employee of The Company support positively, both on and off the job, our Company’s business activities. One important safe way we satisfy this responsibility is to ensure that our business dealings are never influenced by –or even appear to be influenced by –our own personal interests.

More specifically, and by way of example only, you may not, directly or indirectly, during your employment with us:

1. Work for, be associated with, or provide an unauthorized service or material or receive any compensation from any competitor of the Company.
2. Have any financial interest in any customer, potential customer, competitor, supplier or vendor of the Company.
3. Work for, be associated with or provide an unauthorized service or material to any customer, potential customer, supplier or vendor of the Company, other than on behalf of the Company in the course of your employment with the Company.
4. Solicit any gifts, money, services or anything else of value from any competitor, customer, potential customer, supplier or vendor of the Company.
5. Accept any gifts, money, services or anything else of value from any competitor. You may accept gifts (but never money) from customers, potential customer, suppliers or vendors of the Company, but only if immediately reported to and approved by the Executive Officers of the Company.
6. Give or promise to give any gifts, gratuities or other similar items of value to influence customers, potential customers, vendors or suppliers. Gifts are permitted only if approval has been obtained in advance by the Executive Officers of the Company.
7. Engage in any other outside employment, independent consulting or volunteer activity with may interfere or conflict with your duties and responsibilities to our Company, regardless of its nature.
8. Use the Company name for any outside activities including sponsorship of athletic teams, support for charitable organizations and/or conducting business with outside entities. You may only use the Company name for such activities if approval has been obtained in advance by the Executive Officers of the Company.
9. Serve as an office or director of or receive any compensation from an outside organization that is not a professional, social, religious, educational, civic or charitable organization.

Under certain narrow circumstances, exceptions to prohibitions (2, 3, 5, 8, 9) may be permitted, but only if disclosed to and approved in advance in writing by the Chief Operating Officer or President of the Company.