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ACCEPTANCE OF PAYMENTS 

No employee, officer, manager or director shall directly or indirectly seek or accept any payments, fees, services or other gratuities (irrespective of size or amount) outside the normal course of the employee’s, officer’s, manager’s or director’s business duties from any person, company or organization which does or seeks to do business with the Company.  Gifts of cash or cash equivalents of any amount are strictly prohibited. It is not inappropriate under this policy to be the recipient of common courtesies, sales promotional items of small value, occasional meals or reasonable entertainment appropriate to a business relationship and associated with business discussions. However, there’s always a risk that a business associate may try to “buy your favor”, a nice way of saying bribery.  Any bribe or improper payment is prohibited.  In addition to cash payments, bribes include kickbacks or kickback schemes, unexplained rebates, and payments for other disguised allowance or expenses.    Questions as to the appropriateness or legality of any such favor or courtesy should be reviewed by an immediate supervisor in advance of the receipt of the courtesy.