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How Shall Employees Conduct Themselves?

Guidelines for Conducting Business with Those outside Our Company

Our employees are the most effective advertisement of our values, beliefs, and abilities. Always keep in mind that when you are acting in your capacity as our employee, you are contributing materially to the public image and the ultimate success of this company.

Gifts for Influence

No payment or gift of money, goods, or services should be given or received to influence government or business decisions. Accurate and complete records for all accounts will be strictly monitored for everyone's protection.

If it becomes apparent to you in the course of the performance of your business responsibilities that a payment of some kind is expected by your business associate, please contact your division president.

Conflict of Interest

A conflict of interest can be described as a situation where a person has a vested interest in two areas of the business world that may give him or her an unfair advantage in business dealings. Our employees should be sensitive to any relationship that creates such a relationship--or even creates the appearance of such a relationship.

Keep these rules in mind:

  • Throughout your employment period, be vigilant about potential conflicts of interest between this company's interests and your personal or immediate family's interests.
  • Don't use your position with this company to obtain a personal benefit of any kind.
  • Avoid any action or relationship that creates, or even creates the appearance of, a conflict of interest. For example, having an interest in a nonpublic company that competes or does business with our company or any of its affiliates might create the appearance of a conflict of interest and might prompt accusations and/or an investigation.


This company respects your privacy, as well as your right to conduct your personal affairs without interference; however, you must make prompt, complete, and continuing disclosure of all facts relating to any factual or potential conflict of interest.


Inquiries or investigations may be undertaken at this company's direction by its attorneys, investigators, internal auditors, or independent public accountants. Employees should regard this vigilance as the company's commitment not only to fair competition but also to the protection of its employees. Your cooperation is needed for your protection as well as that of this company, and it is a condition of your employment.

This excerpt is a composite of information from several business documents.