Compliance & Ethics

Compliance & Ethics

We understand that our customers, investors and other stakeholders hold us to the highest standard of integrity. We strive to not only meet these high expectations but to exceed them.

To advance this commitment, we have adopted our Company Values and our Company Code of Business Conduct and Ethics which set forth our expectations regarding the conduct of each of our directors, officers and employees. Our Company Values are the principles that guide us in conducting our business and interacting with our colleagues, customers, business partners and regulators. For example, one of our Company Values is Integrity, which we define as an unwavering commitment to honesty, mutual respect and ethical behavior without arrogance or hierarchy.

Our Company Code of Business Conduct and Ethics sets forth standards and guidelines regarding the lawful behavior and ethical conduct of each of our directors, officers and employees. The Code addresses, among other things:

  • Compliance with applicable laws and regulations, including conducting activities in compliance with environmental laws, a prohibition of any illegal payments to any government officials or political party representatives of any country, and complying with securities laws;

  • Conflicts between personal interests of directors, officers and employees and our interests;

  • Confidentiality of information entrusted to directors, officers and employees by us or our suppliers, customers, franchises or other business partners;

  • Protection and use of corporate assets;

  • Fair and honest dealing with each other and with customers, suppliers, franchises, competitors and other third parties;

  • Providing full, fair, accurate, timely and understandable disclosure in periodic reports and other public communications; and

  • Reporting of known or suspected unethical behavior or actual or possible violations of law, regulations or the Code through reporting channels, and in certain cases the Ethics Hotline, with the assurance of no retaliation against a reporting person acting in good faith.

We understand that our customers and employees entrust their personal information to us. We recognize our obligation to maintain the privacy of this information and are committed to meet this obligation. For example, we submit the privacy practices of our U.S. website for certification by TRUSTe, a leading internet privacy compliance authority.

We are committed to conducting our business in compliance with all applicable laws, rules and regulations in every community in which we do business and in an ethical manner. We recognize and respect the local cultures, customs and practices of our customers and employees.