ETHICS POLICY AND PROCEDURES
BRANDSTOM INSTRUMENTS, INC. BUSINESS ETHICS POLICY AND PROCEDURES
Brandstrom Instruments, Inc. (“Brandstrom”) is committed to operate all activities within the spirit and letter of all laws and regulations affecting its business and employees. Employees must exercise the highest level of integrity, ethics, and objectivity in their actions and relationships which may affect Brandstrom and its customers.
PROTECTION OF CONFIDENTIAL AND/OR PROPRIETARY INFORMATION
Confidential and/or proprietary information, discoveries and inventions created by Brandstrom and its employees are company assets and will be owned by Brandstrom. Brandstrom receives confidential and/or proprietary information of third parties, including from customers, that are assets of the third parties. Confidential and/or proprietary information includes all non-public information that might be useful to competitors or that could be harmful to Brandstrom or its customers if disclosed. All confidential and/or proprietary information should be maintained in strict confidence and appropriately kept in secure data storage and transmitted via secure communications channels.
COMPLIANCE WITH LAWS AND REGULATIONS
Brandstrom requires that all employees comply with all applicable laws and regulations. Extortion, fraud, bribery, kickbacks, and embezzlement in any form are strictly prohibited. Brandstrom will swiftly deal with any violations of the applicable laws and regulations and Brandstrom may be required to disclose the violation to the applicable law enforcement authorities.
HOLDING A SIGNIFICANT INTEREST IN SUPPLIERS, CUSTOMERS, OR COMPETITORS
Brandstrom employees may not have any ownership interests in, or own property with, any of Brandstrom’s vendors, suppliers, contractors, agencies, customers, or competitors unless Brandstrom determines that such ownership interests do not conflict with the employee’s obligations to Brandstrom. These restrictions do not apply to ownership of stock of a public company.
GIFTS AND GRATUITIES
To ensure the highest level of objectivity in dealing with Brandstrom’s vendors, suppliers, contractors, and agencies, and to avoid the appearance of impropriety, employees are not permitted to accept personal benefits, solicited or unsolicited, of any kind. This includes gifts, free services, discounts, loans, lavish entertainment, or other special favors. Infrequent gifts valuing not more than $100 may be accepted when unsolicited and are not given in return for a special consideration or decision.
CONFLICTS OF INTEREST
While Brandstrom has no wish to interfere with an employee’s outside activities, employees must avoid situations where a conflict of interest might occur or appear to occur. A conflict of interest exists where a person’s private interest conflicts with or interferes with Brandstrom’s interests. Brandstrom employees may not work for, or conduct any outside business with a competitor. Employees may not be engaged in any manner by a competitor of Brandstrom.
POLITICAL CONTRIBUTIONS AND ACTIVITIES
Political contributions shall not be made by or on behalf of Brandstrom. This restriction applies solely to the use of Brandstrom funds and does not prohibit or discourage individual employees from making political contributions or engaging in political activities on their own behalf.
No person will be subject to any discrimination in any aspect of the employment relationship including recruitment, hiring, compensation, benefits, work assignments, access to training, advancement, discipline, termination or retirement, on the basis of race, religious belief, color, gender, pregnancy, childbirth or related medical conditions, age, national origin, ancestry, sexual orientation, gender identification, physical or mental disability, medical condition, illness, genetic characteristics, family care, marital status, status as a veteran or qualified disabled veteran, caste, socio-economic situation, political opinion, union affiliation, ethnic group, illness or any other classification protected under the applicable laws and regulations.
I have read the preceding Policy and I accept and agree to the restrictions stated in the Policy. I hereby certify that I have complied with the Policy to the best of my knowledge and that all employees under my direct supervision are aware of the Policy and are in compliance with its terms.