Business Ethics

We are committed to conducting our business according to the highest ethical standards and upholding our corporate responsibilities as a public company operating for the benefit of our shareholders. Our Board of Directors has adopted a Code of Business Ethics that applies to our directors, officers, and other team members. It was formed to codify and formalize certain of our long-standing policies and principles that help ensure our business is conducted in accordance with the highest standards of moral and ethical behavior. The Code of Business Ethics includes our commitment to dealing fairly with all of our customers, service providers, suppliers, and competitors. We conduct annual training with our employees regarding ethical behavior and require all employees to acknowledge the terms of, and abide by, our Code of Business Ethics.

We are also committed to a harassment-free workplace, expecting every employee to behave professionally and respectfully. Our employees have access to members of our Board of Directors to report anonymously, if desired, any suspicion of misconduct by any member of our senior management or executive team. The company will not tolerate any form of retaliation against a team member for engaging in a complaint made in good faith. Anonymous reporting is always available through the company’s whistleblower hotline which is tested annually and reported to our Audit Committee quarterly.

We operate in compliance with the U.S. Foreign Corrupt Practices Act (FCPA) and as such, have adopted an Anti-Corruption & Foreign Trade Control Policy as well as an Anti-Money Laundering & Anti-Terrorist Financing Policy. These policies prohibit team members and third parties acting on behalf of our company from corruptly paying, offering, promising, authorizing, taking, soliciting, or accepting for personal benefit, any bribe, kickback, illicit payment, or advantage, in money or in any kind, to or from any foreign official or to or from any other person or entity, including terrorist-related groups. Team members are required to notify our General Counsel if they know of or suspect any possible violation.

We have an internal audit function that evaluates compliance with such policies and procedures.

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