TABLE OF CONTENTS RESOURCES LAST PAGE VIEWED HELPLINE 31 We 昀椀ght crime and corruption Our promise What is “anything of value”? To win the 昀椀ght against crime and corruption Our process It really can mean “anything.” Some examples include: + Cash or cash equivalents like gi昀琀 cards We believe that the quality of our o昀昀erings and services, not illegal business practices, should bring us success. That’s why we don’t tolerate any acts of + Special favors corruption, bribery or money laundering. + Inappropriate gi昀琀s or entertainment We never bribe. Although the laws on bribery and corruption can be + Discounts unavailable to the public complicated, doing the right thing is simple: We don’t bribe. That means + Charitable donations or political contributions we never o昀昀er or accept anything of value to win business, gain an unfair + Payment of travel expenses advantage or in昀氀uence a business decision. We keep accurate records. Of course, it’s important to never bribe—but it’s also important to avoid anything that even looks like a bribe. We make sure that our books and records accurately re昀氀ect our business so that we can easily explain the appropriate reason something was given and received. We work with those who share our Values. We understand that we can be held responsible for the things our business partners do. That’s why we choose them carefully, then watch them closely. We stay alert to money laundering. Money laundering happens when funds are generated through criminal acts, like drug tra昀昀icking or terrorist activities, and then hidden (or “laundered”) by being run through legitimate businesses. It’s a way for criminals to disguise the pro昀椀ts of their criminal conduct. We stay alert for this activity and work to keep these funds from entering the Company. Code of Ethics and Business Conduct Ethics Helpline