Code Of Ethics

a. Associates may accept for themselves and members of their families common courtesies usually associated with customary business practices. These include but are not limited to:

• Lunch and/or dinner with vendors sometimes including spouses as long as the invitation is extended by the vendor.
• Gifts of small value from vendors such as calendars, pens, pads, knives, etc.
• Tickets to events (such as sports, arts, etc.) are acceptable if offered by the vendor and the vendor accompanies the associate to the event. These are not to be solicited by the company associate and must be approved by the appropriate company officer.
• Overnight outings are acceptable under the condition that individuals from either other companies or the vendor are in attendance. The associate must have prior approval from the appropriate company officer.
• Gifts of perishable items usually given during the holidays such as hams, cookies, nuts, etc., are acceptable.

b. A strict standard is expected with respect to gifts, services, discounts, entertainment or considerations of any kind from suppliers

• Day outings such as golf, fishing, and hunting are acceptable with prior approval from the appropriate company official. The vendor must be in attendance and participation by the associate’s family members is not acceptable.
• Use of vendor’s facilities (vacation homes, etc.) by associates or families for personal use is prohibited (Exception: Vendor presence required, once per year, limited duration, prior approval).

It is never permissible to accept a gift in cash or cash equivalent segments such as stocks or marketable securities.