At Company X, our goal is to provide an atmosphere of the highest professional integrity. Creating and continuously enhancing our image is of utmost importance to our long-term success. The Ethics Program described below was created based upon shared values between our company and the communities we serve. It is expected that all employees adhere to the guidelines set forth in this document. A. Ethics Standards and Procedures a. Legal Compliance: Employees must conform to all federal, state, and location laws and regulations, including the attainment of certifications and licensing, where applicable. b.Policy and Procedure Compliance: Employees will conform to all company policies and procedures, except in cases when those policies and procedures appear to conflict with law. Employees are expected to immediately report such cases to their supervisor or the Human Resources Department. c. Honesty: Employees will act with honesty in all business dealings including, but not limited to: contract issues, financial reporting, and dealing with customers, government, and other external entities. d. Reporting Ethics Violations: Employees must report any suspected Ethics violation to their supervisor or the Human Resources Department. . Dress Code: Employee attire must meet the following criteria i. Shoes must be worn at all times and must cover the heel, all toes, and bottom of the foot. ii. Shirts must be worn at all times and must completely cover the torso to include shoulders, chest, stomach, and back. iii. Pants or shorts must be no shorter than three inches above the knee. iv. Clothing print must be free of profanity or other offensive language. B. Ethics Training Program Elements a. Facilitation of Ethics Program: Ethics Training will be facilitated by the Human Resources Department.Employees will have the option to attend a live session in-person, live session via webinar, or a recorded session that is made available on the Human Resources website b. Frequency: Live sessions will be offered on a monthly basis. Recorded sessions will be available on-demand. c. Communication of Ethics Training Opportunities: The dates, times, locations and instructions for Ethics Training sessions will be communicated via a schedule published on the Human Resources website and also through monthly enterprise-wide email reminders. Employees may request n on-demand HR training session in the event that the scheduled monthly sessions are not offered at a time that is convenient to their work schedule. d. Annual Ethics Training: Employees must register for and attend at least one Ethics Program training course each calendar year. These sessions will be between two and four hours in length. C. Process for Handling Employee Misconduct a. Monitoring Employee Misconduct i. Supervisors are expected to constantly monitor for Ethics violations and remind employees that all violations should be reported immediately ii.Employees are expected to be vigilant of other employees and report any misconduct they witness iii. Closed-Circuit Cameras: Cameras have been installed at key locations on all Company X facilities. Video recordings will be reviewed in the event that questionable activity such as theft, sexual, or other misconduct has been reported in one of those areas. iv. Customer Feedback: Customers may provide feedback of ethical misconduct by Company X employees will be made available via a hyperlink located on Company X’s customer portal.This link will provide a form for providing details of the occurrence(s). Alternately, customers will be provided with the phone number of Company X’s Human Resources Department in the event that they prefer to report violations verbally. b. Auditing Employee Misconduct i. Internal Ethics Auditing 1. Theft and Loss: Each year representatives from Human Resources, Property Management, and Security Departments will collaboratively review capital equipment losses and look for year-to-year and department-specific trends that may indicate the level of success or failure of the Ethics Program. . Employee Satisfaction Surveys: Employees will complete a yearly survey that gathers their general level of satisfaction with respect to workplace ethics. ii. External Ethics Auditing 1. Customer Satisfaction Surveys: Customers will be invited to complete surveys that gather their general level of satisfaction with Company X with respect to Ethics. 2. Annual 3rd Party Audits: Each year Company X will hire an external firm to review the Ethics Program and perform a series of audits to check for compliance.These audits may include, but are not limited to, employee interviews and review of Human Resource employee misconduct reports c. Reporting Employee Misconduct i. Supervisors: Supervisors are expected to report Ethics violations to the Human Resources Department. ii. Employees: Employees are expected to report Ethics violations to either their supervisor or the Human Resources Department. iii. Anonymous Reporting: Employees are encouraged to report Ethics violations to their supervisors.However, in the event an employee does not feel comfortable reporting to their supervisor, anonymous feedback can be provided by placing a hard-copy note in the feedback boxes located in each employee break room or by sending an email to [email protected] com iv. Violation of Law: The Human Resources Department will report all employee violations of federal, state, or local law to the appropriate agency. This report must also be made available to the head of the department where the infraction took place as well as to every member of the Board of Directors and Company X’s Executive Team.D. Ongoing Ethics Improvement (EXPLAIN HOW WE WILL DO EACH OF THE FOLLOWING) a. Evaluation of Ethics Program Effectiveness i. Evaluation Frequency: The effectiveness of the Ethics Program will be evaluated on an annual basis ii. Methods of Evaluating Effectiveness 1. Ethics Review Team: In January of each year an Ethics Program Effectiveness Review Team will be assembled that consists of one representative from Human Resources, one representative from the Executive Team, and 5-10 randomly-selected employee volunteers.The representatives from Human Resources and the Executive Team will be appointed by the Chief Executive Officer. 2. In February of each year, the Ethics Program Effectiveness Review Team will review the findings of Employee surveys, Customer Surveys, and 3rd Party audits. These findings will be analyzed in isolation and will also be compared against findings from previous years to identify trends in employee behavior. Trends will be compared against changes in Ethics policy and procedure to determine if those changes were effective in improving employee behavior. . Implementing Ethics Program Changes i. In March of each year, the Ethics Program Effectiveness Review Team will draft recommendations for Ethics Program changes and provide them to the Human Resources Department. ii. In April of each year, the Human Resources Department will review the recommendations provided by the Ethics Program Effectiveness Review Team and consider whether or incorporate the recommendations in into the Ethics program. iii.In the event that any changes were made to Company X’s Ethics Program since the previous year, the Human Resources Department will draft a new set of policies and procedures prior to June 30th of that year and publish them on the Human Resources website. The Human Resources Department will also send a corporate-wide email informing all employees of the changes. iv. Any changes made to Company X’s Ethics Program will be incorporated into all employee training materials prior to June 30th of the year that changes were made.