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Code of Business Conduct

Standard 12

Recognize That the Company's Greatest and Most Valuable Asset Is Its Workforce. The company is committed to maintaining a safe and professional working environment for all of its employees and to ensuring that all employees are treated with fairness, dignity and respect.

A. General Principles

In order to comply with this standard, we must observe all government regulations and rules promoting protection of workplace health and safety and must take reasonable precautions to protect ourselves and our co-workers from workplace hazards. We must also comply with all laws, regulations and policies related to non-discrimination in all our personnel actions, which include recruiting, hiring, compensation, evaluations, transfers, promotions, corrective actions, discipline, terminations and staff reductions.

B. Harassment

Company employees should be able to work in an environment free of harassment and ridicule. Harassment can consist of offensive comments based upon the diverse characteristics or cultural backgrounds of our co-workers, degrading or humiliating jokes, and slurs or intimidation of any form. Sexual harassment includes unwelcome sexual advances or requests for sexual favors in connection with job decisions, or verbal or physical conduct of a sexual nature that interferes with an employee's work performance or creates an intimidating, hostile or offensive working environment.

At the extreme, harassment can also include workplace violence, such as threats of violence or violence directed against co-workers or the company, or "stalking" behavior committed by or directed at company employees. For this reason, company employees are prohibited from bringing to the company's premises, or having in their possession on the company's premises, firearms, weapons, explosive devices or other dangerous materials.

Harassment of any form is strictly prohibited by the company. If you are the victim of harassment, or you observe any form of harassment, you should immediately report the incident to your supervisor and the compliance officer. Employees who violate this standard will be subject to the full range of disciplinary sanctions, up to and including termination where appropriate.

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