Accurate Books & Records |
The falsification or improper modification of information in the Company's books and records, or the improper omission of information from the Company's books and records. (Examples include: misstatement of revenues, misstatement of expenses, misstatement of assets, misapplications of GAAP principles, wrongful transactions) |
Anti-Kickback/Bribery |
The payment or provision of any money, fee, commission, credit, gift, gratuity, thing of value or compensation of any kind that is provided directly or indirectly, and that has as one of its purposes, the improper obtaining or rewarding of favorable treatment in a business relationship. |
Competition and Fair Dealing |
Unethical or illegal business practices, such as through manipulation, concealment, misrepresentations of material facts, or any other unfair business practice. |
Compliance with Laws and Regulations |
Failure to comply with laws, regulations, rules and regulatory orders applicable in the country, state and local jurisdictions where business is conducted, including securities laws, antitrust laws and other fair competition laws. |
Conflict of Interest |
A conflict of interest is defined as a situation in which a person, such as a public official, an employee, or a professional, has a private or personal interest sufficient to appear to influence the objective exercise of his or her official duties. (Examples include: inappropriate vendor relations, bribery, misuse of confidential information, inappropriate customer relations) |
Contract Compliance |
Concerns about how the Company is fulfilling its contractual obligations to a customer or supplier. |
Customer Relations |
The real or perceived display of lack of customer service or courtesy exhibited by employees of the company either by actions, lack of action, or something which was said by an employee or a combination of both. |
Disclosure of Confidential Information |
Unauthorized and unlawful disclosure of corporately owned intellectual property or trade secrets, as well as employee, customer or consumer information, marketing and other corporate data bases, marketing plans, business proposals and strategies. |
Discrimination |
Unlawful treatment on the basis of age, race, sex, disability, marital status, national origin and creed. (Examples include: bias in hiring, bias in assignments, wrongful termination, bias in promotions). |
Document Creation and Retention |
Relates to the violation of Company retention policies and the improper alteration, destruction, mutilation, concealing or falsification of a document, including in the context of any ongoing or known contemplated official proceeding or investigation. |
Doing Business with Government Agencies and Government Contractors |
Failure to comply with applicable state, province or local laws and regulations or contractual obligations relating to government business or government agencies. Examples may include failure to abide by government bidding rules and deviating from government contract requirements. |