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Code of Business Conduct

Standard 8

Compete Ethically and Fairly. We must take special care to avoid engaging in anti-competitive activities or unfair trade practices.

A sincere commitment to ethical professionalism requires us to conduct our business in a manner that helps maintain a free and competitive market for our goods and services. Activities that would artificially restrain a competitive market are contrary to that philosophy and to federal laws against anti-competitive activities. Accordingly, we must ensure that we avoid engaging in activity that could be considered to violate those laws.

Activities that could run afoul of that goal include discussing pricing or supplier relationships with a competitor, agreements to allocate the market for our goods and services among ourselves and our competitors, and agreements among competitors to refuse to deal with particular suppliers or vendors. We must be especially vigilant when attending gatherings such as trade association meetings that we do not get drawn into discussions of inappropriate topics, such as discussions concerning pricing, labor costs, marketing plans and the like. If you find yourself in such a situation, immediately end the conversation, and if appropriate, ask that your refusal to participate be documented in the meeting minutes. You should also immediately report any such incident to the company's legal department.

In addition, we must ensure that all information we obtain about our competitors is done in compliance with the law and the standards set forth in the Code of Conduct. We must not solicit or obtain confidential information about a competitor in a manner that would be illegal or would require a person to violate a contractual agreement, such as a confidentiality agreement with a prior employer.

Finally, we must also ensure that all information we provide to our customers and the community at large about our products and services is truthful and accurate and does not contain misleading or deceptive information.

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