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DUTY TO REPORT VIOLATIONS OF LAW, REGULATIONS, COMPANY POLICY OR THIS CODE 

 

Each employee, officer, manager and director is responsible for promptly bringing to the Company’s attention any circumstances which he or she believes in good faith may constitute a violation of applicable law, regulations, Company policy or this Code. The Company considers that failure to discharge this responsibility may be as serious as the violation itself.  Employees, officers, managers and directors are encouraged and required to raise any concern about risks to the Company before these risks become actual problems. 

 

The Company has established procedures for the open, confidential, or anonymous submission by employees, officers, managers, directors and other persons of information about possible violations of law, regulations, Company policy or this Code  directly to a member of management, the General Counsel at (276) 619-4410, any member of the Internal Audit Department or, if they prefer, to the Company's ethics hotline by calling (866) 259-2480 (a toll-free service that is available 24 hours a day, 365 days of the year).  Although it may be impossible in certain circumstances to keep a person’s identity confidential, the Company will strive to take every action practicable to maintain confidentiality for any person reporting a violation.  The Company will not allow retaliation for reports made in good faith.  The Board of Directors’ Audit Committee has established a process described below that permits persons to submit concerns or complaints regarding accounting, financial reporting, internal accounting controls  or auditing matters for consideration by the Audit Committee.