Code of Conduct: Integrity Standard - Gifts, Gratuities & Kickbacks

Policy:
We must maintain the highest standards of integrity and objectivity in dealing with vendors and service providers. We are prohibited from accepting or giving gifts or gratuities beyond common business courtesies of nominal value. Gifts or items of value must never be offered to or accepted from government employees. Under no circumstances will we accept or give kickbacks when obtaining or awarding contracts, services, referrals, goods, or business. A kickback means to willfully offer, receive, request or pay anything of value, even nominal value, in order to induce or reward referrals of business including goods or services.

We will not accept or offer gifts, gratuities, or favors, except those associated with common business courtesies of a nominal value, of $50 or less. The value of all gifts received in one year from all sources must not exceed $100. Gifts exceeding this policy may be made to customers or other persons subject to President, Executive Vice President or Senior Vice President approval.

We must not offer or accept gifts of cash or cash equivalents to or from any current, former or potential vendor, customer, broker, or provider. Cash equivalents include checks, honorariums, money orders, stocks and saving bonds. Gift certificates and gift cards are not considered cash equivalents but are subject to the limitation on common business courtesies stated above.

Entertainment and meals offered or received by employees as part of legitimate business activity are not included in the $50 gift limit, but must be within the boundaries of reason and moderation. Generally, raffles and prizes that are part of an outside business activity are not considered gifts.

Although the Company does not set a dollar limit on gift giving among employees, it is important to always use reason and good judgment when giving or accepting a gift. Gifts of nominal value are always best and contributing to a gift should always be voluntary. A gift should never be given to another employee to influence, gain favor or show favoritism. In addition, Company-approved gifts to employees or prizes that are part of Company-sponsored events such as a raffle are not considered gifts for the purposes of this Standard but are subject to all applicable federal, state and local tax requirements.