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COMPANY RECORDS 

 

Accurate, timely financial records provide the core information that is necessary to manage our business.  Company business records must always be prepared accurately and reliably. They are of critical importance in meeting our financial, legal and management obligations to our shareholders and the general public at large.  Records must be maintained to comply with applicable statutory, regulatory or contractual requirements, as well as those pursuant to prudent business practices.

 

Records are to be kept in accordance with accepted accounting rules and controls at all times, fully and accurately reflecting all transactions, and follow effective internal controls, including procedures to protect the Company’s assets. No unrecorded or undisclosed corporate account, fund or asset may be maintained. No false or misleading entry, record or report may be made or permitted to go uncorrected.  Mistakes should never be covered up, but should be immediately disclosed in full and corrected.  No employee should rationalize or even consider misrepresenting facts or falsifying records. 

 

All reports, vouchers, bills, payroll and service records, measurement and performance records, and other essential data must be prepared with care and honesty. All business transactions must be properly authorized as well as completely and accurately recorded on the Company’s books.  Procedures for doing so must comply with the Company's financial policies, as well as follow generally accepted accounting practices.

 

Misapplication or improper use of  corporate or customers’ funds or property, or false entry to records by employees or others, must be reported to the Company’s General Counsel.  Any such behavior may result in disciplinary action, up to and including termination.  

 

Records containing personal data about employees, officers and directors are confidential. They are to be carefully safeguarded and kept current, relevant and accurate. They should be disclosed only to authorized personnel and in accordance with lawful process.  Financial information can be made available outside the Company only with proper prior authorization.

 

Employees, officers, managers and directors must comply with the Company’s policy concerning the retention, storage, retrieval and destruction of records.  Of particular concern are records that are potentially relevant to a violation of law or any litigation or any pending, threatened or foreseeable government investigation or proceeding.  Destruction or falsification of any document that is potentially relevant to a violation of law or a government investigation may lead to prosecution. Employees can contact the Company’s General Counsel for specific information on record retention.