The Company prides itself in conducting its business in a manner that does not violate any applicable law and ensuring that no illegal or immoral activity is conducted on property owned, controlled or used by the Company. The employees, officers, managers and directors owe a duty to the Company to see that all laws are complied with and no illegal or immoral activity is conducted on its property. Any violation of law could result in disciplinary action or termination. Employees could also be terminated for (i) failure to report a violation of law or the Code, (ii) failure to cooperate in an investigation of violations, (iii) retaliation against another employee for reporting any violation or (iv) failure to effectively monitor actions of subordinates.
The sale of goods and services to the U.S. government is heavily regulated. Company employees involved in sales to government customers must take the necessary steps to ensure that all government related transactions and relationships comply with applicable laws and regulations. In addition, it is Company policy to cooperate with all reasonable requests concerning Company operations from governmental authorities. If an employee is unclear about the appropriate procedures in responding to such requests, notify the General Counsel immediately and wait for instructions before proceeding.
Company policy and the law forbid the purchase or sale of Company securities by an employee, officer, manager or director or by any others who learn material information from him or her, if such material information is not generally available to the public. “Material information” is any information that a reasonable investor would consider important in deciding whether to buy, sell or hold securities. Such insider trading is both illegal and unethical. The Company has adopted a policy against insider trading and tipping that is designed to promote compliance with securities laws and to protect the Company as well as Company representatives from the very serious liability and penalties that can result from violations of these laws. Contact the General Counsel to obtain the full text of the Company’s Policy on Insider Trading and Information Disclosure.
In addition, the Company’s directors and executive officers are subject to reporting requirements and short-swing profits liability under the U.S. Securities Exchange Act of 1934, as amended. Directors and executive officers will be responsible for filing related reports in a timely and accurate manner.
These policies are designed to help employees avoid the inadvertent disclosure of information or illegal securities trades. Any questions concerning the Company’s policy, the law governing insider trading or directors’ and executive officers’ reporting obligations should be referred to the Company’s General Counsel.