Code of Conduct: Integrity Standard

Policy

We will keep accurate, true and complete Company records. Accuracy and reliability in the preparation of all business records is mandated by law and is of critical importance to the Company’s decision-making processes and to the proper discharge of our financial, legal and reporting obligations. We must never misrepresent facts, falsify or suppress records. In addition, all records should be stored for the period of time required by applicable laws or contracts or Company policy, whichever is longest.

Recordkeeping and Reporting
We must ensure that all Company records, business expense accounts, vouchers, bills, payrolls, service records, and reports, whether electronic or on paper, are reliable, accurate and complete. Transactions between the Company and outside individuals and organizations must be promptly and accurately entered in Company records in accordance with Company policies and procedures. We will not improperly alter or make false entries on, or willfully fail to make correct entries on, any Company record or document. False or misleading entries on records are unlawful and could subject the Company and, in some cases, individual employees to fines and other civil or even criminal penalties. In addition, we will not facilitate the creation of false or misleading records of any of our covered groups, vendors or any other business partner.

We will create and submit only true and accurate reports. We must not create or submit false or misleading reports of operating statistics or measurements, such as sales reports, performance data and utilization data. If we are not sure of the accuracy or reliability of information, we must take steps to verify it or immediately contact our Supervisor for advice.

We will establish, maintain, support and follow internal controls designed to provide reasonable assurance that transactions are authorized, and that transactions and other data are recorded and presented in a manner that is accurate, complete, current and not misleading. We will record all Company transactions in accordance with generally accepted accounting practices and principles or statutory accounting principles. We will charge all items to the appropriate account, regardless of the financial status of the line of business, contract or cost center. We will not maintain any secret or unrecorded funds. We will follow appropriate Company procedures to ensure that errors are corrected, as they become known, through credits, refunds or other mutually acceptable means.

We will never take any steps that would impede, obstruct, improperly influence the conclusions of, or affect the integrity or availability of any audit, review or investigation, regardless of whether that audit, review or investigation is performed by governmental, external or internal personnel.

Record Retention
We will preserve and maintain Company records in accordance with the Company’s and department’s document retention policies. We must not improperly destroy any corporate accounts, records or other official Company documents.

When litigation, a government audit or investigation is imminent or pending, our normal document destruction procedures will be suspended until all documents relevant to the litigation, audit or investigation can be identified and segregated.

Code of Conduct: Integrity Standard - Accuracy of Records