Ethics Policy

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COMPANY X

ETHICS AND CONDUCT POLICY

CURRENT AS OF NOVEMBER, 2011

TABLE OF CONTENTS FOR COMPANY X
CODE OF ETHICS POLICIES

PageContents
2Introduction
2Commercial Bribery
3Conflict of Interest
3Employee Relations
a. Norms
b. Resolving conflict
3Internal Company Conduct
4Ethics training requirements
5Reporting violations
5Company Code of ethics review policy

INTRODUCTION

This policy applies to Company X and its employees, whether contracted, part-time, or full-time. Employees must always consider how their actions affect the integrity, credibility, and reputation of the company as a whole. While the company must compete in order to make a profit, the company and all of its employees must act in an ethical manner and comply with all laws and regulations. These regulations include, but are not limited to commercial bribery, conflict of interest, employee relations, and internal company conduct.

COMMERCIAL BRIBERY

The company insists on honesty, integrity, and fairness in all aspects of its business and expects the same in its relationships with all business partners. Both suppliers and customers should be treated with courtesy and fairness at all times. The company and its employees shall not seek business from customers by commercial bribery or the payment of kickbacks. Modest hospitality is an accepted courtesy of a business relationship. However, the frequency and scale of hospitality given to suppliers and customers should be reasonable and not appear improper. See the guidelines for providing and receiving hospitality for suppliers and customers in the Conflict of Interest Section.

CONFLICT OF INTEREST

There are two categories regarding conflict of interest addressed in this section of the policy. Gifts, Favors, and Meals
Employees should not request any money, gift, free service, or special favors from any supplier or customer. Unsolicited gifts which are excessive in value should never be accepted. Services should not be promised to customers in exchange for gifts or favors regardless of value.

Financial Interests
Company employees should avoid having a financial interest in an organization that competes with the company or has a business relationship with the company such as a supplier or a customer.

EMPLOYEE RELATIONS

NORMS
* Be punctual
* Do not talk about others who are not present
* Treat others the way you want to be treated
* Healthy conflict

RESOLVING CONFLICT
Employees should try to resolve conflict on their own when possible. If a resolution cannot be reached, employees should involve their manager. If the conflict cannot be handled at the manager level or if the conflict is with the manager, Human Resources should be notified.

INTERNAL COMPANY CONDUCT

Internal company conduct should be understood in this policy as the Company and the employees being held responsible for creating and maintaining a safe work environment. Company X pledges to take all reported matters seriously, and to investigate each matter independent of each other. Employees are responsible for adhering to guidelines and standards set by policies such as Alcohol and Drug use, Harassment, and Misconduct outlined in the Employee handbook.

ETHICS TRAINING REQUIREMENTS

ORIENTATION ETHICS TRAINING

All employees of Company X will be trained on company ethics and conduct policies during the orientation period. Depending on the start date of future employees and the availability of the company’s training staff, a “quick start” orientation may be necessary. In this case, the employee will be required to attend the full orientation at a later date. All employees of Company X will be required to sign off and acknowledge that they have been trained on the company’s ethics and conduct policies before starting their probation period.

YEARLY ETHICS REFRESHER TRAINING

Company X will provide ethics training at the...
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