Our Responsibilities

You Should:

  • Make sure that you know, understand and model your behavior consistent with the Code.
  • Let those employees reporting to you know that you are available to discuss their concerns.
  • Support those employees reporting to you who raise concerns honestly and treat them with respect.
  • Take questions and concerns from those employees reporting to you seriously.
  • Feel free to seek guidance before responding.
  • Act to stop violations of the Code or the law by employees and contractors.
  • Raise all concerns to the appropriate level and function.
  • Never let those employees reporting to you feel that their concerns are being ignored. Ensure that no retaliation occurs against someone for reporting a suspected violation of the Code or participating in an investigation.

Officers and board members must report, in person or in writing, any known or suspected violations of the laws, governmental regulations or this Code to the Chief Compliance Officer. Board members also must report any known or suspected violations to the Chair of the company’s Audit Committee. Employees who are not officers or board members shall report such violations to their immediate supervisor and the Chief Compliance Officer. The company will not allow any retaliation against an employee, officer or board member who acts honestly and in good faith in reporting any such violation or suspected violation.

The Chief Compliance Officer will ensure that any reported violations will be investigated and will oversee an appropriate response, including corrective action and preventative measures. Code violations and the results of investigations are reported to Senior Management and the company’s Audit Committee.

Waivers

The provisions of this Code may be waived for employees who are not board members or executive officers by the Company’s Chief Executive Officer. If the Company’s Chief Executive Officer grants a waiver, that waiver will be disclosed to the Company’s Audit Committee.

The provisions of this Code may be waived for board members or executive officers only by the Company’s Audit Committee.

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