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Code of Business Conduct

Standard 11

Don't Engage in Improper Political Activities. Because the company's ability to participate in political activities is constrained by federal, state and local law, all organizational political activity must be cleared by the company's legal department.

As an organization, the company's political activities must be conducted in accordance with applicable law. Accordingly, company employees should not use company assets to engage in political activities without the prior review and approval of the company's legal department.

Company employees are strictly prohibited from including political contributions on their expense accounts and must not allow company assets to be used for a political cause, candidate or campaign. While you are free to participate in the political process on your own time and at your own expense, if you do so, you must make clear that you are speaking or acting on your own behalf. You must not conduct your activities in a way which gives others the impression that you are speaking on behalf of the company or otherwise represent the company.

If your position in the company requires you to have personal contact with governmental entities and officials on the company's behalf, be sure that you are aware of and understand all relevant regulatory provisions applicable to such contacts. If you have questions about your actions, get in touch with the legal department before you act.

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