Company Interests

As an employee or director, they are expected to act at all times in the Corporation's best interests and to exercise sound judgment unclouded by personal interests or divided loyalties.

Both in performing their duties at Corporation and in their outside activities, they should avoid the appearance as well as the reality of a conflict of interest.

A conflict of interest exists if their circumstances would lead a reasonable person to question whether their motivations are aligned with the Corporation's best interests. If, for example, they are involved in an outside activity or have a financial or other personal interest that might interfere with their objectivity in performing company duties and responsibilities, they may have a conflict of interest.

While it is impractical to describe all situations that may create a conflict of interest, the following provides policy guidance about some of the most common conflict of interest situations:

- Use of Company Information for Private Gain
- Friends and Family Stock
- Outside Activities - Non-Profit and Civic Organizations
- Employment Outside Corporation - Moonlighting
- Service on a Board of Directors
- Technical Advisory Boards
- Family and Romantic Relationships
- Spouses, Domestic Partners, Immediate Family Members or Relatives as Suppliers, Vendors, and other Business Partners
- Kickbacks and Rebates by Suppliers or Vendors
- Gifts from Vendors, Suppliers or Customers
- Honorariums

Please note that the above is not an exhaustive list of examples. There are many other situations that may also create a potential for a conflict of interest or the appearance of a conflict of interest. It is up to the employees or directors to be aware of the potential for a conflict of interest in their own particular situation and to resolve the issue in accordance with this policy.