Very few individuals plan to act unethically. However, pressures do exist in the business world that can tempt otherwise valued employees to become involved in illegal or unethical behavior. Examples of these pressures include competing for a major contract or meeting tight budgets and schedules. While MEC is focused on meeting and exceeding high expectations, it must be clear to each of us that it is never in our best interests to compromise our standards.

Our Ethics Program recognizes that these pressures exist, and our Code of Conduct provides a common understanding of our expectations. I urge all employees to periodically review the Code and to ask any questions if you are unsure as to its meaning or applicability. We have appointed ethics officers in all our business locations that are available not only to report concerns but also seek guidance. Each of these resources enables you to obtain assistance and advice if you have any doubts, concerns or questions about the appropriateness of a particular activity.

Maintaining our hard-earned reputation as an ethical company requires the concerted effort of all employees. If we do the right thing when we are faced with tough decisions, then we can take pride in the continued building of MEC’s reputation in the marketplace and the ethical work environment we create for each other.

Our Code of Conduct: The Basics
Purpose of the Code

Integrity is a core value at MEC, and our reputation is a valuable corporate asset. We uphold our reputation for integrity in the marketplace and provide an ethical work environment for all of our employees. We will do the right thing each time we face a tough decision. The MEC Code of Conduct reflects MEC’s commitment to integrity and the protection of our reputation, and it establishes a standard of ethics and conduct for our employees, agents, and directors.

It is inevitable that employees encounter questions of business ethics and conduct in the course of performing their duties with the Company. The way employees decide these issues should be consistent with the Code. The Code represents MEC’s desire to communicate a standard that not only meets, but exceeds, the requirements of the law and industry practice, and presents a way to resolve these issues.

Applicability of the Code

Our Code applies to all MEC officers, directors, and employees (collectively “employees”), regardless of their location, as well as to our agents, representatives, consultants, and subcontractors. It is not possible to address all potential scenarios in this Code of Conduct; when in doubt, ask for guidance.

Responsibilities under the Code

As a condition of initial and continued employment with MEC, all Employees must comply with the Code, MEC’s applicable policies and procedures, and all applicable laws. All employees are expected to cooperate fully in Company investigations of alleged violations of the Code, MEC’s policies, or applicable laws. Company investigations may be conducted or directed by Internal Audit, Legal, Talent Management, Corporate Security, or third-party investigators. If you have any concerns about the legitimacy of an investigator, contact an Ethics Officer.

MEC’s managers have the additional obligation to ensure that their departments are operating in accordance with the Code and fostering an open, ethical environment in which employees are encouraged to discuss any ethical issues they perceive and to seek guidance when they are in doubt. MEC’s Directors are subject to an additional code of conduct in their activities as Directors.

Violation and Enforcement

It is never within the scope of employment or activities on behalf of the Company for an employee to violate the law or the Code. Violations are grounds for corrective action, up to and including termination, possible legal prosecution, or are other appropriate action.
If You Have a Concern

All employees benefit from an atmosphere of good ethical conduct. Employees who suspect misconduct, illegal activities, fraud, abuse of corporate assets, or violations of the standards of the Code or Company policy are responsible for reporting such matters. Several methods to report such violations are described in Where to Go for Help, page 16.

Strict Non-Retaliation Policy

Retaliation against any employee for making a good faith report or raising an issue regarding a suspected violation of the law, regulations, contracts, or the Code is strictly prohibited and is itself a violation of the Code. The Company will take disciplinary action against a supervisor or employee who initiates, condones, or participates in any act of retaliation.

Ethics Committee and Ethics Officers

The Board of Directors has ultimate oversight over Ethics compliance. The Board established the Ethics Committee, composed of executives from corporate departments including Legal, Audit and Talent Management, to administer the Code of Conduct. The Ethics Committee is also charged with educating and training employees on ethics. The Ethics Committee reports regularly to the Board of Directors on ethics issues. The Committee appoints Ethics Officers who are selected from among the corporation’s many legal entities and regions. Employees may contact any Ethics Officer at any time regarding ethics issues. See Where to Go for Help, page 16.

Questions & Answers

Q. What is the role of the Ethics Officer?

A. The Ethics Officer is a resource in matters of ethical conduct and Code interpretation. The Ethics Officer may also be called upon to provide consultation with employees, managers, the Legal department, and the Talent Management department in the resolution of some ethical issues. Occasionally the Ethics Officer will participate in an investigation of an ethics complaint.

Q. What does the Code mean when it says to avoid “the appearance of impropriety”?

A. it means that you should avoid any conduct that may appear to others to violate the law, ethical standards, or expectations. As a general rule, consider if you would feel comfortable seeing this conduct reported on a TV news program or newspaper.

Financial Controls

Accurate Recordkeeping

Employees are required to record and report information accurately and honestly. This includes time worked, job charges, business expenses incurred, revenues and costs, job-related data, and other business-related activities. Corporate records are subject to audit, and financial records should be maintained in accordance with generally accepted accounting principles. No undisclosed or unrecorded corporate accounts or unauthorized bank accounts shall be established for any purpose.

Reporting, organizing, or destroying information in an attempt to mislead or misinform is prohibited. No entry shall be made or purposely omitted on any records or data that intentionally hides or disguises the true nature of the transaction, project, plan, or other business information, nor shall any data regarding Company business or services be falsified or distorted in any way.

Conflicts of Interest

When does a Conflict Exist? A conflict of interest occurs when an employee’s private interest interferes in any way with the interests of the Company as a whole. These private interests may include the financial or employment relationships of not just the employee but also his or her close family members and other members of an employee’s household or close friends. MECs’ policy prohibits conflicts that could impair an employee’s ability to act in the best interest of MECs or its clients. MECs also requires its employees to disclose conflicts of interest to the proper company officials so that they can be properly resolved.

This Code is intended to provide general guidance to employees to avoid actual conflicts of interest and the appearance of conflicts of interest. If you have any questions, consult your manager. If this is not possible, or you have further questions or want to report violations, you should follow the procedures described in WHERE TO GO FOR HELP at the end of this policy document.

Conflicts of interest are sometimes very subtle and complicated. The Ethics Officer assigned to your employment group is one resource for reviewing facts to determine the extent to which a conflict may be present. The Legal Department is another resource for determining whether a conflict of interest exists in certain situations.

A conflict may exist and yet not be a violation of the Code if the company determines that a reasonable accommodation can be made. However, failure to report a conflict, even one that can be accommodated, is a serious violation of the Code. If you intend to engage in activities that may be or may appear to be a conflict, disclose the details to an Ethics Officer or the Talent Management or Legal Department. They will determine whether the conflict is prohibited or whether, with adequate disclosure and suitable precautions, the conflict may be permitted.

Red Flag Examples

Listed below are some examples of red flags” that may indicate the presence of a conflict of interest that should be raised with the company:

 Any ownership interest (other than nominal amounts of stock in publicly traded companies) acquired by you or a close relative in any business that either does or wishes to do business with MEC, or competes or may compete with MEC.

 Someone proposes a business relationship between MEC and another organization or person in which you, a member of your family, or a close personal friend has a financial interest.

 Any consulting or employment relationship between you and a supplier, contractor, subcontractor, client, competitor, or other agent or business associate of MEC, including service on the board of directors of that business.

 Any outside business activity that competes with any part of MEC’s business.

 Any outside activity is calling into question your ability to devote appropriate time and attention to your job at MEC.

 Performing personal activities or personal business on the job, except for occasional and minor activities that are no routine and do not infringe upon your job responsibilities.

 Taking personal advantage of any opportunity in connection with information you learned in the course of your employment with MEC, such as acquiring property or leases, which MECs might want to purchase or lease.

 Selling anything to the Company or buying anything from the Company except through regular programs and procedures offered to all employees.

Offering or Accepting Gifts, Entertainment, or Gratuities

MEC’s reputation is based on exceptional service to its clients at a competitive price. Therefore, the solicitation of improper advantage in a business relationship by offering anything of substantial value, including gifts, entertainment, drinks, meals, transportation, lodging, or other business courtesies, is unacceptable. Apart from additional restrictions that apply to government employees, employees may only provide or pay for reasonable entertainment, drinks, and meals and give gifts or promotional items such as pens and calendars of modest value to clients, contractors, and other business associates. Such courtesies and gifts must also be lawful, performed or given only occasionally, unsolicited by the recipient and allowable under the rules of the recipient’s employer. If you have any questions, consult your manager.

In addition, employees cannot directly or indirectly accept anything of substantial value if receipt could or might appear to influence a business decision with regard to any person or entity. Apart from additional restrictions that apply in the governmental area, you may only accept meals, drinks, or entertainment of reasonable monetary value and gifts or promotional items, such as pens and calendars, of modest value. Your acceptance of meals, drinks, or entertainment must also be directly connected with business discussions. Such courtesies or gifts must also be lawful, unsolicited, and infrequently provided in accordance with customary business practices and not appear to influence your business decisions. Do not accept reimbursement for lodging or free lodging or travel expenses without the express approval of your manager.

Questions & Answers

Q. Can I take a second job to supplement my income? Will this cause a conflict of interest problem for me?

A. While you are not barred from taking a second job, as a full-time employee your first work obligation is to the Company. This means you must avoid a conflict of interest with your job, as described in the question above, whether you are self-employed or employed by someone else. You should discuss this matter with your manager in advance to see if there is a conflict of interest. If there is no clear resolution of the matter, or you want further consultation, you and your manager should discuss the situation with an Ethics Officer. Some further guidelines: You may not use company time, equipment, Confidential Information, or supplies to perform work for yourself or another employer. While employed by MECs as a full-time or part-time employee, you cannot work for a competitor or supplier.

Q. If my spouse accompanies me on a business trip and receives a gift from the company I’m visiting, is he/she permitted to keep the gift?

A. Your spouse is under the same ethical obligations in this regard as you are for the receipt of gifts or gratuities. However, if refusal or return of the gift would cause embarrassment to the Company or to the parties with whom you are doing business, disclose the gift to your manager and the Ethics Officer, and its proper disposition will be determined.

Political Contributions

Most countries, in which MEC does business, impose significant restrictions and limitations on the ability of a corporation to actively participate in the political process. All proposals or requests by employees, business unit offices, or projects to use corporate funds or corporate assets, such as telephones, computers, stationery, copying, employee time, office facilities, refreshments, or the like (called in-kind contributions), in support of or for contributions to political candidates and parties, ballot measures and initiatives, and political causes and campaigns, must be submitted in writing to MEC’s Government Relations department and to the General Counsel for prior review and approval.

Employees may donate personal time and resources for political purposes, but it is against Company policy and in certain locations illegal, for employees to use their time at work, or company property, facilities, resources, or assets for political activities and purposes.

No direct or indirect pressure in any form is to be put on employees to make any political contributions or to participate in the support of a political party or the candidacy of any individual.

Unsanctioned Boycotts

MEC is prohibited from complying with or supporting any boycott unless the Federal or State Government sanctions such a boycott. Such requests may take the form of a bid invitation, contract, letter of credit, or oral request in connection with an international transaction. An employee who receives or learns of a boycott or boycott-related information request should report it immediately to the Legal department, which will pursue a resolution of the issue. Employees who are involved in international transactions should seek guidance from the Legal Department on anti-boycott requirements.

Bribes MEC does not condone bribery of any kind, whether by our employees or by our partners, our subcontractors, or our agents. MECs will walk away from any project that requires a bribe to win it and will cut ties with any partner, subcontractor, or agent who pays bribes, even if not on our projects, or who suggests that MECs pay a bribe.

Bribery is prohibited under the Code. Bribery of government officials is a criminal offense. Bribery includes any direct or indirect payments to a client, supplier, contractor, subcontractor, or business associate (including any representative, agent, or employee of such party) with the specific intent to induce or influence the person or the client to act in a specific way. Bribery could potentially take the form of giving, promising, or authorizing a payment in cash or in kind or any service to government officials (including executives of state-owned companies), political

candidates, political parties, or officials of public international organizations for the purpose of acquiring or maintaining business or securing an improper advantage.

Under the anti-bribery laws, a company can be held liable even if its own employees did not directly make the improper payment and even if the company did not have actual knowledge that a third party was making an improper payment on its behalf. A company might be in violation of such laws by making improper payments or gifts through third parties working with this company on a project. Contact the Legal department if you have any questions or want to report concerns about potential bribery or violations of the anti-bribery provisions of this Code of Conduct

Anti-Money Laundering

Money laundering is the process by which large amounts of illegally obtained money is given the appearance of having originated from a legitimate source. According to the International Monetary Fund, the aggregate scope of money laundering equals between 2% and 5% of the world’s gross domestic product.

More than 100 countries have enacted anti-money laundering laws, and MEC is fully committed to complying with all such legislation in the countries in which we do business. Because of the kind of work MEC performs, the likelihood that you will encounter money laundering schemes is greatly reduced. Nevertheless, you should be aware of the following red flags that may indicate a money laundering scheme:

 A customer, agent, or proposed joint venture partner who is reluctant to provide complete information; provides insufficient, false, or suspicious information; 

or is anxious to avoid reporting r record-keeping requirements.

 Payments using monetary instruments that are not consistent with the business activities of the client, appear to have no identifiable link to the customer or have been identified as money laundering mechanisms.

 Requests by a customer, agent, or proposed joint venture partner to pay in cash

 Unusually complex deal structures, payment patterns that reflect no real business purpose, or unusually favorable payment terms

 Unusual fund transfers to or from foreign countries unrelated to the transaction

 Transactions involving locations that have been identified as tax havens or areas of

known money-laundering activity

 Structuring of transactions to evade recordkeeping or reporting requirements (e.g., multiple transactions below the reportable threshold amounts)

 Wire transfer activity that is not consistent with the business activities of the customer or that originates or terminates with parties unrelated to the transaction

Requests to transfer money to a third party or an unknown or unrecognized account

Protecting Corporate Assets

Confidential and Proprietary Information

Employees of MEC must preserve all tangible and intangible assets, including confidential and proprietary information belonging to MECs, its subsidiaries, affiliates, clients, and agents (including, but not limited to, contractors, subcontractors, representatives, counsel, and consultants).

Except as required by your employment, confidential and proprietary information may not be disclosed or released unless written authorization is given to you by MEC after review by the Legal department. Within the scope of their responsibilities, employees should ensure that information is properly stored and protected, and disseminated on a need-to-know basis, thereby preventing unauthorized access, use, or removal. All employees must take great care to avoid disseminating confidential company information to unauthorized recipients when using email, blogs, social networking sites, or any other medium.

Confidential and proprietary information obtained as a consequence of your employment may not be used for your personal profit or that of anyone else as a result of association with you. Use for personal profit can include taking advantage of such information by (a) trading, or providing information for others to trade, in securities of any company; (b) acquiring a property interest of any kind; or (c) receiving compensation of any kind for communicating such information to any other person.

Upon termination of employment for any reason, you may not copy or retain any documents or data stored in any form containing MECs’ confidential or proprietary information. The rule against disclosing confidential and proprietary information extends beyond your employment.


A copyright gives the owner of an original work (such as a magazine article, photo, design, or software program) the right to copy, display, and distribute that work, prepare derivative works, and keep others from doing so without permission. You may not copy and/or distribute reproductions of copyrighted materials from publications, works, or software that you receive through MECs, including copyrighted materials from clients, or from the Internet, beyond the scope of MEC’s subscription or express permission from the copyright owner. Violation of copyright laws can result in substantial penalties. In addition, works produced on the job or based on information you received at MECs are known under the law as “works made for hire.” These documents, programs, articles, designs, and others, in whatever form, are the property of MEC and cannot be reproduced, distributed, displayed, or published without MECs’ approval, and they may be subject to MECs’ assertion of ownership rights.

Software Use Software owned by other companies is usually provided for use by MEC under software licensing agreements. These licensing agreements contain restrictions and conditions regarding the use of licensed software. If a MEC employee fails to comply with these conditions and restrictions, MECs may be responsible to the company that owns the software. For this reason, MEC’s employees must follow the rules in using this software.

A typical restriction in software agreements prohibits copying the software for any purpose (including personal use) without the written permission of the owner. When employee copies software for use on a personal computer, or to give to others, that employee is not only violating MEC’s policy but may also be causing MEC to breach the licensing agreement. If there is any doubt about the requirements of a licensing agreement, contact your supervisor to learn about limitations on the use of the software.

MEC sometimes creates its software for specific purposes. Restrictions also apply to MECcreated software, but these restrictions may be different from those for software provided by others. Some of this software is for internal, administrative, and financial purposes and is considered proprietary and confidential. Other software may be for project use with the intention of licensing clients to use the software. Employees should understand the proper uses of software in the course of their work. Be sure to ask your supervisor if you have any questions or concerns.

Workplace Standards

Employment Practices People are MEC’s’ most valuable asset. Clients want our services because we have a diverse and highly qualified workforce. To ensure that we maintain this competitive advantage and our high standards, MEC is committed to providing equal employment opportunity and a safe and respectful workplace for all employees.

Equal Employment Opportunity MEC recruits promotes, compensates, and retains employees based on merit. All employment decisions are based on a person’s job qualifications, such as education, experience, skills, and performance, and without regard to race, color, religion, national origin, age, sex, sexual orientation, gender identity or expression, employable physical or mental disability, veteran status, marital status, or pregnancy.

Harassment Everyone should work in an environment that is safe and free from all forms of harassment. MECs has zero tolerance for harassment of any person for any reason, including race, sex, color, religion, age, disability, or veteran status. Employees should feel free to report any perceived harassment or to cooperate in an investigation without fear of retaliation. Retaliation is not tolerated at MEC.

This policy applies to employees working at any MEC’s facility, other assigned locations, on business travel, or socializing for business or corporate sponsored events and to any persons who interact with MECs’ employees in a business relationship with the Corporation.

Harassment creates a demeaning or offensive work environment. Sexual harassment includes unwelcome sexual advances, requests for sexual favors, sexually suggestive jokes, comments, pictures, email messages or gestures, touching, and inappropriate comments about appearance. Other forms of harassment include offensive jokes, comments, gestures, pictures, or email messages relating to race, religion, national origin, age, gender, or disability.

Workplace Health and Safety As an industry-leading engineering, construction, and technical services firm, MECs is firmly committed to maintaining a safe and healthy working environment at all its offices and project facilities. We share the National Safety Council’s Safety and Health Code of Ethics as the principles guiding our commitment to safety:

• We will hold safety and health as our highest core value. • Executive management will lead the safety improvement process. • Safety will be a responsibility shared by everyone in our organization. • Safety performance will be a key indicator of our organizational excellence and will be incorporated into our business processes. • We will communicate safety performance openly with employees. • All employees will be given the knowledge and skills necessary to safely perform their jobs. • We will extend our safety efforts beyond the workplace to include transportation, homes, and communities. • We will continually strive to improve our safety and health processes.

Competing Fairly

At MECs, we compete in the marketplace based on the superior quality and competitive pricing of our professional services and products. We never compromise our high ethical standards by attempting to fix prices or by using confidential or proprietary information belonging to our competitors.

Antitrust The global activities of MECs are subject to the antitrust laws of the United States and many other countries. These laws generally prohibit agreements or actions in restraint of trade or competition. Examples include agreements among competitors to fix or control prices, boycotts of targeted suppliers or clients, and allocation of territories or markets between competitors. Special care must be taken to comply with all applicable antitrust laws.

Trade Secrets Trade secrets are protected by law in the United States and many other countries. A trade secret can be any useful information that is not generally known and that derives value from not being generally known. Examples of trade secrets include formulas, designs, engineering or technical information, pricing information, product or marketing plans, and customer lists. A trade secret is not information or know-how that is generally known to professionals in the field or is otherwise publicly available. For example, information available to the public in annual reports, financial statements, websites, newspapers, magazines, professional journals, or at trade shows is not a trade secret. MECs competes fairly by gathering competitive data only from publicly available sources or reputable firms that gather and compile industry data legally.

Guidelines for Competing Fairly • Avoid any discussion of any kind with competitors about pricing, contract terms, bids, or proposals. • Never directly or indirectly solicit any confidential or proprietary information from an employee or a former employee of another company. • Never use another company’s confidential or proprietary information, including confidential or proprietary information from a former employer. • Never make disparaging statements or spread false information about competitors. • Contact the Legal department immediately if you learn of information that raises questions or concerns about the antitrust or trade secrets laws.

Investigations and Audits

Government Investigations At MECs, we conduct business legally, ethically, and with integrity. We do the right thing every time. This means that we cooperate with governmental authorities in conducting investigations or gathering information relating to potential violations of law. Any employee who receives a request for information, subpoena, or other legal document regarding Company business from any governmental agency should notify the General Counsel immediately. Employees must also retain and preserve documents, electronically stored information, and other evidence. The General Counsel will help employees review information and respond to governmental authorities. An investigation is a nonroutine inquiry of the Company or its employees, regarding a possible violation of the law by MECs, an employee, or any other company or person. It does not mean routine government audits, compliance reviews, or personal legal matters.

Internal Audits The Company’s Internal Audit department investigates and analyzes compliance with Company policies and the Code. Employees are required to cooperate with internal auditors by telling the whole truth, preserving and providing relevant information or evidence, and not discussing the investigation with anyone unless instructed to do so.

Legal Matters All legal matters relating to MECs’ business should be referred to the Legal department. Any engagement of counsel must be initiated and approved by the Legal department. If you receive documents that appear to have legal significance to MECs, send them to the Legal department. If you have a question, contact the Legal department.

Searches As permitted by law, the Company may monitor or search Company computers, systems, telephones, facilities, and vehicles on Company premises to determine whether any person has engaged in conduct that is harmful to MECs or its people. Such conduct includes, but is not limited to, the theft of any Company property, including proprietary information, or the property of any employee or visitor. It also includes possession of drugs, alcohol, firearms, or anything else that is prohibited or restricted on Company property. Everyone is expected to cooperate in the Company’s reasonable security efforts and to report any suspected harmful conduct to security personnel.

Government Contracts

MECs’ customers include federal, state, and local governments; therefore, it is necessary to comply with all statutes, regulations, rules, and ordinances that apply to these transactions. Compliance generally falls into five main categories.

Accuracy and Compliance The federal government has special rules on accounting for costs, proposal and bidding procedures, pricing, and time charging. Furthermore, the Company may be required to certify accuracy regarding cost or pricing data, and compliance with specifications, quality control, and testing requirements for government projects. These rules may apply whether the Company is performing as a prime contractor or as a subcontractor. Employees involved in negotiating government prime contracts or subcontracts must ensure that all statements, communications, and representations to the customer representatives are accurate and truthful.

Bribes, Gifts, Gratuities, and Kickbacks Bribery of government officials, kickbacks, and illegal gratuities are a violation of the Code and are prohibited by law. It is also a violation of federal law to pay any commission or fee to any person to solicit or obtain a government contract, other than a MECs’ employee or commercial agent. In addition, we are required by law to report promptly a violation of the kickback laws to the Government if we have reasonable grounds to believe that a kickback has taken place.

If you have questions about providing a gift or anything of value to a government employee, contact General Counsel. Also, before entering into any arrangement with any person to solicit or obtain a government contract, contact General Counsel.

National Security and Classified Information In the course of our work, it is sometimes necessary for employees to have access to, generate, or store information classified for national security purposes. Only employees with the proper security clearance are permitted to have access to such data. Employees are required to take appropriate steps to safeguard classified information and to ensure that it is not improperly released. Any suspected breach of national security regulations must be reported immediately to the responsible manager administering corporate security functions.

Procurement Integrity: Procurement-Sensitive and Confidential Data No employee shall accept or attempt to obtain, either directly or indirectly, government information or documents that are procurement sensitive, a competitor’s proprietary or confidential data, or information regarding a competitor’s bid or proposal if there is any reason to believe that the release of such information is unauthorized.

Employing Present or Former Government Employees Special restrictions apply to recruit present and former government personnel and retaining them as employees or consultants. Before you enter into employment discussions with any individual employed by the government as either an employee or a consultant within the last three years, obtain the approval of the responsible Director of Talent Management.

Corrective Actions and Sanctions

The Code of Conduct reflects MECs’ commitment to integrity and establishes a standard of business ethics and conduct for all employees. Allowing unethical behavior to go unreported can be just as harmful as participating in the behavior. Every employee is required to report violations of the Code to a supervisor, Ethics Officer.

MECs will not tolerate any form of retaliation against an employee who reports a suspected violation of the Code or cooperates in an investigation of a reported violation. If you or any other employee experience retaliation, contact an Ethics Officer or the third-party Ethics Hotline immediately. Appropriate disciplinary action, up to and including termination, will be taken against anyone who retaliates.

When notified of a violation, the Ethics Committee or the Legal department will initiate an investigation. Employees are required to cooperate with internal auditors by telling the whole truth, preserving and providing relevant information or evidence, and by not discussing the investigation with anyone unless instructed to do so. The Company will also keep the matter confidential to the extent possible and will limit disclosure of information regarding an investigation to those who have a legitimate need to know.

If the Ethics Committee determines that the Code has been violated, discipline, up to and including termination, can be imposed. In some cases, the Company may even have a legal or ethical obligation to report violations to governmental or law enforcement agencies.

Where To Go For Help

You may resolve legal and ethical questions and report legal and ethical violations you experience on the job in a variety of ways. If you have any questions about an ethical or legal issue or if you want to know how to proceed if you observe a violation, the following channels are available:

• Contact the next level of supervision in your department or location. Contact any Ethics Officer. Contact may be made under your name or anonymously in any of the following ways: • Call the Ethics Officer by telephone. • Send the Ethics Officer an email message.

If your situation requires that your identity is kept secret, we will protect your anonymity, unless required by law to disclose it. However, in some circumstances, violations may only be successfully investigated and ethical or legal standards enforced if all parties cooperate in the investigation. Therefore, for the successful completion of an investigation, you may have to agree to release your identity to the parties involved.