Code of Business Conduct

Standard 9

Treat Government Investigations as Serious Matters. We will cooperate with all government investigations and reasonable requests for information.

From time to time, the company may be asked to cooperate with a government investigation or to respond to a request for information from the government about how we conduct our business. The request may come through official channels from the government to company management, or you could be contacted individually by a member of an enforcement agency, such as the Federal Bureau of Investigation, the Office of Inspector General or the Department of Justice.

When the company receives official requests for information or cooperation, it will notify you of your responsibilities and duties in connection with providing such information and cooperation. If you are contacted individually by government investigators and are asked to meet with them individually to discuss activities in connection with your employment by the company, the company requests that you immediately notify the legal department and inform them that you have been contacted. Of course, the decision of whether to cooperate with their inquiry is up to you alone, and you will not be rewarded, disciplined, punished or otherwise retaliated against whether you decide to cooperate or not to do so. However, if you decide to speak with government investigators, be sure that you are accurate and truthful in all your answers to their questions because if you are not, both you and the company could be subject to criminal prosecution.

Although company employees are free to cooperate individually with government investigators, you may not provide company documents or data in response to a government request for information without first obtaining authorization from the legal department.