This Code of Business Conduct and Ethics supersedes all previous versions of the Doc.com Code of Business Conduct and Ethics, which are hereby null and void.
The Code of Business Conduct and Ethics (“Code”) is a cornerstone of Doc.com, Inc’s Compliance Program. At Doc.com, Inc, we believe that ethical standards must guide our interactions with colleagues, clients, providers, suppliers, vendors, and everyone with whom we do business.
The Code applies to all employees, board members, and authorized representatives of Doc.com, Inc. It also governs the conduct of vendors, suppliers, and independent contractors working with us.
This document outlines the principles that define our business ethics and the relevant laws and regulations applicable to Doc.com, Inc's operations, both domestically and internationally. Each individual has a responsibility to adhere to the policies outlined in the Code and to seek guidance when uncertain about the appropriateness of a decision or action. To address the complexity of certain topics covered in the Code, we will provide further support through training, Compliance Program Policies and Procedures, the Employee Handbook, and guidance from supervisors, Human Resources, and the Legal Department. Always remain vigilant and sensitive to situations that might result in unethical, improper, or illegal behavior.
The Code is designed to encourage thoughtful reflection on how our actions align with Doc.com, Inc’s values and standards. By upholding these principles, we collectively protect the reputation and success of our organization.
Thank you for your dedication to our core values.
Charles Nader,
Chief Executive Officer
The Code of Business Conduct and Ethics (the “Code”) is a cornerstone of Doc.com Inc.’s commitment to maintaining the highest standards of ethical conduct. Adopted by the Board of Directors, this Code applies to all individuals working for or on behalf of Doc.com Inc. and its subsidiaries, including directors, officers, full-time, part-time, temporary employees, and independent contractors (collectively referred to as “Employees”). It is designed to guide decision-making, and while it does not supersede applicable laws, it underscores the Company’s commitment to maintaining integrity in all aspects of its operations.
At Doc.com Inc., we expect each Employee to exercise good judgment, uphold ethical standards, and demonstrate integrity in their professional conduct. All Employees are responsible for reading, understanding, and complying with the Code. Managers, in particular, have an enhanced responsibility to lead with integrity, guiding their teams and ensuring compliance. Employees are encouraged to consult with their managers or other designated resources should any uncertainties arise regarding the application of the Code.
It is important to note that this Code does not constitute an employment contract, nor does it alter the at-will employment relationship. Employees who fail to adhere to the principles outlined herein, or who refuse to cooperate in investigations, will face disciplinary actions, including the potential termination of employment.
This Code is built upon several foundational principles that reflect the Company’s core values:
Doc.com Inc. is committed to conducting its business operations with the highest level of integrity and transparency, ensuring full compliance with all applicable laws, regulations, and rules in every jurisdiction where we operate globally. Any violation of applicable laws, Company policies, or engagement in unethical conduct is strictly prohibited.
Every Employee holds a fiduciary responsibility to act in the best interests of Doc.com Inc., safeguarding its assets, including confidential information and trade secrets. Employees must avoid any actual or perceived conflicts of interest and refrain from engaging in decisions or actions that would result in personal gain at the Company’s expense.
Doc.com Inc. values the contributions of each Employee and fosters a work environment based on mutual respect, tolerance, and fairness. Embracing diversity not only enriches our organizational culture but also drives innovation and enhances the quality of service provided to our clients. Discrimination or harassment of any kind will not be tolerated.
Outstanding customer service is a key priority for Doc.com Inc. We are committed to delivering exceptional experiences by treating customers, clients, members, and suppliers with honesty, respect, and fairness, thereby fulfilling our obligations and promises.
Doc.com Inc. is dedicated to maintaining an ethical business environment, where employees are encouraged to stand up for what is right. Any Employee who observes or becomes aware of a potential violation of laws or the Code must report it. The Company will not tolerate retaliation against anyone who, in good faith, reports concerns or assists in an investigation, and disciplinary action will be taken as necessary, including termination of employment or contract.
At Doc.com Inc., we recognize that Corporate Social Responsibility (CSR) is integral to our business model and long-term sustainability. By incorporating sustainable development practices into our operations, we contribute positively to environmental, social, and economic factors. A robust CSR strategy allows us to demonstrate corporate citizenship, enhancing the Company’s reputation and fostering trust with our stakeholders. The core of our responsibility as a business is to give back to society, just as society supports our growth.
Doc.com Inc. is committed to adhering to global standards and criteria related to Environmental, Social, and Governance (ESG) efforts. Our Company is part of a broader ecosystem composed of people, organizations, and the environment. ESG concerns are crucial for investors and stakeholders and form a significant part of our operational strategy. Specifically:
Our environmental initiatives are designed to minimize the Company’s impact on the planet. This includes addressing climate change, reducing pollution, combating deforestation, and lowering greenhouse gas emissions. We are committed to adopting eco-friendly practices such as enhancing energy efficiency, implementing waste reduction strategies, and promoting sustainable water usage.
The social aspect of ESG encompasses a range of initiatives aimed at improving human capital and societal impact. This includes fostering diversity, equity, and inclusion, ensuring compliance with labor standards, and addressing ethics and workplace justice. We prioritize fair wages and benefits, promote workplace diversity, and maintain positive stakeholder and community relations.
Governance within the ESG framework ensures robust oversight of the Company’s practices. This includes maintaining a well-structured and diverse board, ensuring executive compensation aligns with performance, and upholding transparency in political contributions and lobbying efforts. We are committed to preventing bribery and corruption through stringent compliance measures.
Doc.com Inc. understands the critical importance of preserving the natural environment. We actively promote sustainability through waste reduction, eco-friendly waste disposal practices, and responsible chemical usage. Our commitment to environmental stewardship ensures that we follow best practices to protect the planet for future generations.
Doc.com Inc. is firmly committed to upholding human rights, including equal opportunity for all employees. We adhere to fair labor practices and will ensure that none of our activities, directly or indirectly, contribute to the violation of human rights, such as forced labor, in any country where we operate.
Doc.com Inc. is dedicated to making a positive impact on the communities where we operate. We actively support community investment and educational programs that promote cultural and economic development, both locally and globally. The Company may provide resources and financial assistance to nonprofit organizations and initiatives that align with our values, thereby fostering the growth and well-being of diverse communities.
Doc.com Inc. is committed to the continuous growth of our workforce through investment in learning and development programs. These initiatives are designed to enhance the skills and capabilities of our employees, empowering them to thrive in a dynamic business environment and contribute to the Company’s success.
At Doc.com Inc., we view diversity, equity, and inclusion as fundamental drivers of innovation, creativity, and business performance. Our commitment to DEI helps us build stronger relationships with our diverse members, clients, partners, suppliers, and communities. We are dedicated to fostering a high-performing, inclusive culture that encourages diverse perspectives, promotes innovative solutions, and attracts top talent from all backgrounds. By creating an environment where everyone feels valued and empowered, we are able to enhance our collective performance and support business growth.
Doc.com Inc. is resolutely opposed to corruption in all its forms, including bribery, extortion, and any unethical practices that undermine the integrity of our operations. We maintain strict policies to ensure that all our dealings are transparent, honest, and in full compliance with applicable laws and regulations.
Doc.com Inc. is committed to complying with local and international laws governing environmental, social, and governance (ESG) practices. We will adhere to all applicable regulations in each jurisdiction where we operate, ensuring that our operations align with both legal requirements and our ethical standards.
Here’s a refined version of the "Responsible Artificial Intelligence" section, maintaining a formal, corporate tone:
Responsible AI (RAI) refers to the practice of using artificial intelligence technologies in a manner that prioritizes ethical principles and values. By aligning our AI practices with these guiding principles, Doc.com Inc. aims to harness the full potential of AI while minimizing its associated risks.
Doc.com Inc.'s RAI program is built upon the following core principles:
Doc.com Inc. is committed to designing and deploying AI systems that are accountable to people, ensuring that these systems remain under appropriate human oversight and control at all times.
We will actively work to design AI systems that are fair and free from bias, ensuring that no unjust impacts are made on individuals or communities. This includes addressing biases related to sensitive characteristics such as race, ethnicity, gender, nationality, income, sexual orientation, ability, and political or religious beliefs.
Doc.com Inc. will ensure that our AI systems are transparent and provide stakeholders with clear and understandable explanations of model behaviors. We are committed to creating systems that facilitate meaningful stakeholder feedback, fostering trust and clarity in AI decision-making processes.
We will assess and continually monitor the performance of our AI systems to ensure they meet their intended purposes effectively. Moreover, we will implement measures to minimize and address any harmful or unintended consequences that may arise from the use of these systems.
Doc.com Inc. will ensure that AI systems are designed in accordance with our privacy-by-design principles and our stringent privacy and security policies. We are committed to protecting the privacy and confidentiality of data used by our AI systems, ensuring that all data handling practices meet or exceed applicable legal and ethical standards.
Doc.com Inc. will comply with all applicable laws and regulations governing the development and deployment of AI technologies, both domestically and internationally. As AI regulations continue to evolve, we remain dedicated to ensuring that our practices remain in full compliance with emerging legal frameworks.
As a publicly traded company, Doc.com Inc. is committed to upholding the highest standards of legal and ethical conduct in all aspects of its operations. Using material, non-public information—whether related to the Company or other publicly traded entities—to trade in securities, or providing such information to others (commonly referred to as "tipping"), is strictly prohibited by law. This type of behavior is illegal and can result in serious legal and regulatory consequences.
Any non-public information related to Doc.com Inc. should be regarded as inside information and must never be used for personal financial gain or to benefit others. All employees are required to familiarize themselves with, and adhere to, the Doc.com Inc. Insider Trading Compliance Policy. Copies of this policy are distributed to all employees and can be accessed through the Legal Department or Doc.com Inc.’s intranet site.
If you have any questions about your ability to buy or sell securities, or about any situation that may present a conflict of interest, you should immediately contact the Legal Department for guidance.
While employed by Doc.com Inc., you will have access to various types of confidential information. You are responsible for using and disclosing this information only in accordance with applicable laws, contractual obligations, and the Company’s policies.
Upon joining Doc.com Inc., you agreed to maintain the confidentiality of the Company’s proprietary information. Proprietary information includes any non-public information that the Company considers confidential and that could be valuable to competitors, investors, or could harm the Company, its customers, or its suppliers if disclosed. This encompasses, but is not limited to, business plans, research, project strategies, records, databases, customer, employee, and supplier lists, as well as any unpublished financial or pricing information.
Employees must also maintain the confidentiality of any trade secrets of the Company, as defined by applicable trade secret laws.
Proprietary information and trade secrets represent valuable assets to Doc.com Inc. Protecting this information is critical to the Company’s ongoing success and ability to compete. Unauthorized use or distribution of proprietary information violates Company policy and may be illegal, potentially leading to legal consequences and disciplinary action. Therefore, you must protect all proprietary information in strict confidence unless authorized for disclosure by the Company in writing or required by law.
This obligation continues after your employment ends, and you must return all proprietary information upon leaving the Company, retaining no copies.
Employees must also protect the proprietary information of other organizations with which Doc.com Inc. works.
Certain applicable laws may offer immunity in specific circumstances, such as when trade secrets are disclosed as part of a sealed litigation or reported to a government agency, provided the disclosure is necessary.
When you started your employment with Doc.com Inc., you agreed to assign ownership of any work created during your employment to the Company. This work—referred to as "work product"—includes documents, procedures, technologies, research, programming code, marketing plans, and business strategies. Doc.com Inc. retains all rights to the intellectual property developed by employees, including trade secrets, patents, trademarks, and copyrights.
Protecting intellectual property is distinct from protecting proprietary information. Proprietary information is safeguarded by non-disclosure and registration with the relevant authorities, whereas intellectual property is protected through proper use of trademarks, patents, copyrights, and by adhering to the Company’s branding guidelines. Additionally, employees must ensure that any consultants or third parties engaged to work for the Company sign non-disclosure agreements and recognize the Company’s existing intellectual property rights.
Doc.com Inc. respects the intellectual property of others. Employees may not use third-party copyrighted materials, such as photographs, without appropriate permission.
For any questions regarding the protection of Doc.com Inc.'s intellectual property, please contact the Legal Department.
Doc.com Inc. believes in fair and free competition and will not use confidential information about competitors to gain an unfair advantage. Employees are expected to gather competitive intelligence ethically and legally. Bringing proprietary information from a former employer when joining Doc.com Inc. is strictly prohibited. Employees must never obtain competitive information through deception, theft, or unauthorized means. If you are uncertain about whether a practice is acceptable, please consult the Legal Department.
Doc.com Inc. is committed to respecting employees’ privacy and safeguarding their personal information, including contact details, family information, health records, compensation, performance data, and Social Security numbers. Personal information will only be accessed by authorized personnel and used for legitimate business purposes. The Company will not disclose personal information to outside organizations unless permitted by law or in connection with administering Company benefits programs.
As part of our business, Doc.com Inc. handles significant amounts of personal and health-related information concerning our members, clients, and service providers. The privacy and security of this information are protected by law worldwide. Personal and health information ill only be used or disclosed for purposes related to delivering our services, as permitted by law. Employees are required to follow Doc.com Inc.'s privacy and security policies regarding the use and disclosure of personal and health information. Unauthorized disclosures should be reported immediately.
Doc.com Inc. requires that all business transactions be conducted at arm's length—impartially, objectively, and free from outside influence. A conflict of interest arises when you or a family member have a personal interest that interferes with, or even appears to interfere with, the interests of Doc.com Inc. A conflict can occur when an employee's actions or interests hinder their ability to perform their job duties objectively and effectively. It may also arise when an employee or their family members receive improper personal benefits due to the employee's position within the Company. Both actual and potential conflicts of interest must be addressed, as they can adversely impact Doc.com Inc.'s reputation and perceived integrity.
Employees are expected to always act in the best interests of Doc.com Inc. and must not use their position for personal gain or to benefit others. Employees should avoid situations that create, or appear to create, a conflict between their personal interests and those of the Company.
While no list can cover every situation where a conflict of interest may arise, the following examples highlight scenarios that warrant special attention.
Business meals and events are often used to strengthen relationships and are common in business settings. Such meals or events (including, but not limited to, beverages, meals, recreation, and tickets) must have a specific, legitimate business purpose and should be reasonable, avoiding extravagant or non-customary practices. The presence of both an employee and a representative of the third party (e.g., a client) is required. Employees may accept offers of business meals and events, provided they are appropriately documented, and may extend similar offers to third parties, as long as they are not excessive.
A gift is any item of value provided to an employee by a third party (e.g., a client) or by an employee to a third party, such as personal discounts or event tickets. Gifts can be a customary part of business relationships but may be prohibited in certain cases or jurisdictions. If in doubt, employees should seek guidance from the Legal or Compliance Department.
Under no circumstances should a gift be accepted or offered if its intent is to influence the recipient or if it could be perceived as such. Gifts should never be accepted or given in the following situations:
Gifts of substantial value or personal discounts obtained through an employee's position are likely to be perceived as an attempt to influence and are prohibited. Employees must obtain prior approval from the Chief Executive Officer for any gift exchange with third parties.
There are specific laws governing interactions with government officials and employees. Doc.com Inc. prohibits offering or accepting anything of value, including meals or beverages, from government officials or employees. Employees must comply with local laws regarding acceptable practices in such interactions.
If you wish to take a second job or provide services for another organization (e.g., as a director, advisor, or in a similar role), it must not conflict with your responsibilities at Doc.com Inc. Secondary employment should not interfere with your duties or create a conflict of interest, such as with a competitor, customer, or supplier.
Employees must seek prior approval from their manager, Human Resources business partner, and the Compliance team before pursuing secondary employment. Any potential conflicts with a Doc.com Inc. partner, competitor, client, or supplier must be reported to the Chief Executive Officer before beginning secondary employment.
Doc.com Inc. supports professional development and encourages employees to participate in boards of directors or similar organizations. However, such participation must not conflict with or provide any advantage to Doc.com Inc.'s interests. Employees must disclose any board involvement with partners, competitors, clients, or suppliers of Doc.com Inc. to the Chief Executive Officer for approval before engaging in such activities.
Employees may not take, or direct to a third party, any business opportunity that is developed through the use of Doc.com Inc.’s property, information, or relationships, or as a result of their position with the Company. Employees may not exploit corporate property, information, or their position for personal gain or to compete against Doc.com Inc., such as by entering the same line of business or engaging in competing transactions.
Employees may invest in companies that compete with, do business with, or negotiate to do business with Doc.com Inc., subject to the Doc.com Inc. Insider Trading Compliance Policy and applicable laws. However, substantial investments in competitors, partners, or vendors may present a conflict of interest.
Generally, the following types of investments do not create a conflict of interest:
The following financial interests and activities are prohibited:
Employees must disclose any material transactions that could reasonably create a conflict of interest, including investments of more than 1% in a company competing with, doing business with, or negotiating to do business with Doc.com Inc.
Employees are required to report any potential conflicts of interest. Upon receiving such reports, the Chief Executive Officer will evaluate whether a conflict exists, determine if it can be eliminated or mitigated, and communicate the decision to the employee. The Chief Executive Officer will inform the Board of Directors of all reports.
Conflicts of interest involving the Chief Executive Officer, Chief Financial Officer, or any director will be reviewed by the Board of Directors. If any transaction constituting a conflict is reviewed by the Audit Committee. Feel Free to send any compliance related queries to Compliance@doc.com.
At Doc.com Inc, we value mutual respect and the power of teamwork to achieve collective success. Fostering a positive work environment where all individuals feel valued is essential to our growth and continued success. To this end, we are committed to treating our colleagues, clients, members, and partners with fairness and respect, upholding the values that define our organization and protect our reputation in the communities we serve.
Doc.com Inc recognizes and celebrates the unique contributions of every team member. We are dedicated to cultivating an inclusive and professional workplace grounded in respect and acceptance. Embracing diversity enriches our collective perspectives, fosters innovation, and enhances our ability to deliver effective solutions for our clients and members. We are resolute in maintaining a workplace free from discrimination and harassment, promoting an atmosphere where everyone feels safe and respected.
Doc.com Inc enforces a strict zero-tolerance policy against any form of harassment or discrimination. This policy applies to all employees, contractors, consultants, and others representing the company in their interactions with colleagues, clients, guests, and stakeholders.
Discrimination or harassment based on characteristics protected by applicable law—including but not limited to age, ancestry, race, color, religious creed (including religious dress and grooming), disability, marital status, medical condition, genetic information, military or veteran status, national origin, sex (including pregnancy, childbirth, breastfeeding, and related medical conditions), gender identity, gender expression, sexual orientation, and other protected statuses—will not be tolerated.
Harassment includes verbal, physical, or visual behavior that demeans or targets individuals based on personal attributes or protected statuses. Such behavior is unacceptable if it:
The following are examples of behaviors prohibited under this policy:
Doc.com Inc is committed to addressing and preventing any behavior that undermines a respectful and supportive work environment. Employees are encouraged to report violations and can trust that concerns will be handled promptly and fairly.
Doc.com Inc maintains a strict zero-tolerance stance against sexual harassment and addresses all complaints with the utmost seriousness. Allegations will be promptly investigated, and appropriate action will be taken to eliminate the misconduct and implement corrective measures, which may include termination of employment.
This summary outlines key points from Doc.com Inc’s Sexual Harassment and Other Unlawful Harassment Policy. For comprehensive details, including definitions, procedures, and remedies, employees should refer to the full policy document.
Sexual harassment encompasses unwelcome sexual advances, requests for sexual favors, and other verbal or physical conduct of a sexual nature when:
While not exhaustive, the following are examples of behavior that may constitute sexual harassment if unwelcome:
Employees who believe they have experienced or witnessed unlawful harassment, discrimination, or sexual harassment must report the issue to ensure it is addressed. Reports can be made to:
Reports should include as much detail as possible to aid the investigation and can be made orally or in writing. Retaliation against individuals who report incidents or cooperate in investigations is strictly prohibited and will not be tolerated.
Human Resources, the Compliance Department, or the Legal Department will handle investigations of harassment or discrimination allegations. Investigations will be conducted promptly and impartially, maintaining confidentiality to the extent practicable and permissible under the law. If inappropriate conduct is substantiated, corrective action will be taken, up to and including dismissal.
In addition to internal complaint procedures, employees may file formal complaints with governmental agencies, as allowed by local laws. Doc.com Inc will provide contact information for relevant agencies as required.
To maintain a professional and conflict-free workplace, Doc.com Inc prohibits personal romantic relationships where one employee has authority, power, or control over the other. This includes:
Such relationships must be disclosed to Human Resources by the person in the position of authority. Failure to disclose may result in disciplinary action. Human Resources will take steps to ensure compliance with this policy.
Doc.com Inc is committed to a safe work environment and has a zero-tolerance policy for violence, threats, and the possession of weapons on company premises. Employees must report any threats or suspicious activity to management, Human Resources, or security immediately. Investigations will be thorough and confidential to the extent feasible.
The use of drugs or alcohol that impairs workplace safety or productivity is strictly prohibited. Consumption of alcohol at company-sponsored events is allowed only in moderation and must not affect behavior, performance, or safety.
Doc.com Inc complies with all applicable environmental and workplace safety laws and prioritizes the well-being of employees, the community, and the environment. Employees share the responsibility of maintaining a safe and sustainable workplace.
By adhering to these policies, Doc.com Inc strives to foster a respectful, safe, and professional work environment for all employees.
Employees are expected to act with integrity, fairness, and ethical behavior in all business dealings.
Employees must compete fairly, avoiding unethical or illegal practices. Misrepresentation, collusion, or unfair dealings with customers, suppliers, or competitors are prohibited.
Company records and public disclosures must be accurate, complete, and transparent. Employees must report concerns about inaccurate records or misleading statements to the Legal Department.
Employees are responsible for safeguarding Company assets, using them efficiently, and reporting theft, misuse, or loss.
Corporate funds and resources must not be used for political contributions where prohibited.
Personal political activities must remain separate from the Company, and contributions should comply with legal disclosure requirements.
While Doc.com Inc supports community projects, personal charitable activities must not be represented as Company-sponsored unless approved.
Doc.com Inc maintains positive relationships with government entities and complies with their requests. Employees must contact the Legal Department before responding to government inquiries and cooperate with investigations. Destroying or falsifying information related to investigations is prohibited.
Doc.com Inc complies with all Medicare and Medicaid rules, with a focus on detecting and preventing fraud, waste, and abuse.
Employees must ensure all claims are accurate and report any suspected fraud, waste, or abuse to the Chief Executive Officer.
To ensure compliance, Doc.com Inc conducts regular checks on Employees, physicians, and contractors to verify they are not excluded from participating in Federal healthcare programs.
Doc.com Inc requires all Employees to act ethically and avoid corrupt or illegal business practices. Employees must not offer or accept bribes, expensive gifts, or any form of payment to influence business outcomes, in compliance with laws like the U.S. Foreign Corrupt Practices Act and U.K. Bribery Act.
Key points:
Violations: May result in disciplinary actions, civil penalties, or criminal liability.
Doc.com Inc upholds free and open competition. Employees must not engage in:
Violations: May lead to fines, jail time, or civil liability.
Employees must adhere to all anti-money laundering and anti-terrorism financing laws. Key requirements:
Questions or unusual terms must be referred to the Chief Financial Officer (e.g., cash payments, personal account transfers).
Doc.com Inc conducts international transactions with integrity and in compliance with export controls, economic sanctions, and embargo laws. Employees involved in international activities must:
All agreements with third parties must be formalized in approved written contracts.
This Code applies equally to all Employees. The Chief Executive Officer, under the supervision of the Board of Directors, oversees its enforcement. Doc.com Inc is committed to fostering a culture of accountability and providing resources to ensure compliance.
Concerns involving the Officers should be reported to the Board of Directors. Concerns related to accounting, internal accounting controls, or auditing matters should be reported to the Audit Committee of the Board of Directors. Reports to this committee may be made through the Doc.com Inc Ethics Hotline.
Interested parties may also communicate directly with the Company’s non-employee directors using the contact information provided in the Company’s annual proxy statement. These reports can also be submitted through the Doc.com Inc Compliance@doc.com and will be appropriately routed to the relevant manager, supervisor, or director.
Employees are encouraged to consider their manager and department director as primary resources for guidance regarding compliance with this Code, Doc.com Inc policies, and applicable laws and regulations. If you have any questions about how these apply to your role, you should reach out to your manager or department director.
However, Employees should not attempt to investigate or ask another individual to investigate an ethical issue or suspected violation of the Code. Managers are expected to report such issues through one of the channels outlined above and encourage Employees to do the same. Managers must ensure that Employees raising compliance concerns are not subjected to any form of retaliation.
Doc.com Inc is committed to adhering to all applicable laws and regulations. Open communication of concerns and issues by Employees without fear of retribution, disciplinary action, harassment, or retaliation is essential for the effective implementation of this Code and compliance with applicable laws and regulations.
Doc.com Inc maintains a strict non-retaliation policy. Harassment, retaliation, discrimination, or any adverse action against an Employee who:
Employees who report a violation in good faith will be treated with dignity and respect. Retaliation against any Employee who reports an issue, provides information, or assists in an investigation will itself be treated as a violation of this Code and subject to disciplinary action, up to and including termination.
Important Note: This policy does not shield Employees from the consequences of making reports in bad faith. Disciplinary action may be taken against any Employee who:
This Code will be strictly enforced across the Company. Violations will be dealt with promptly and may result in corrective measures or disciplinary actions, including termination or removal from office.
Employees who:
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