PURPOSE: Company associates will maintain the highest ethical standards in the conduct of Company affairs. Intent of this policy is that each associate will conduct the Company’s business with integrity and comply with all applicable laws in a manner that excludes considerations of personal advantage or gain.
The following is a summary of the Company’s policy with respect to (1) gifts, favors, entertainment and payments given or received by Company associates, (2) potential conflicts of interest and (3) certain other matters:
GENERAL POLICY APPLICATION:
Gifts, Favors, and Payments by the Company: Gifts, favors, and payments may be given to others at Company expense, if they meet all of the following criteria:
1. They are consistent with accepted business practices
2. They are of sufficiently limited value and in a form that will not be construed as a bribe or payoff
3. They are not in violation of applicable law and generally accepted ethical standards; and
4. Public disclosure of the facts will not embarrass the Company
Payments, commissions or other compensation to or for the benefit of associates of customers (or their family members or associates)not required by written contract are contrary to Company policy.
Gifts, Favors, Entertainment and Payments Received by Company Associates:
1. Associates shall not seek or accept for themselves or others any gifts, favors, entertainment, payments without a legitimate business purpose nor shall they seek or accept personal loans other than conventional loans at market rates from lending institutions) from any persons or business organizations that do or seek to do business with or is a competitor of the Company. In the application of this policy:
a. Associates may accept for themselves and members of their families common courtesies usually associated with customary business practices. These include but are not limited to:
Lunch and/or dinner with vendors sometimes including spouses as long as the invitation is extended by the vendor.
Gifts of small value from vendors such as calendars, pens, pads, knives, etc.
Tickets to events (such as sports, arts, etc.) are acceptable if offered by the vendor and the vendor accompanies the associate to the event. These are not to be solicited by the company associate and must be approved by the appropriate company officer.
Overnight outings are acceptable under the condition that individuals from either other companies or the vendor are in attendance. The associate must have prior approval from the appropriate company officer.
The receipt of alcoholic beverages is discouraged.
Gifts of perishable items usually given during the holidays such as hams, cookies, nuts, etc., are acceptable.
b. A strict standard is expected with respect to gifts, services, discounts, entertainment or considerations of any kind from suppliers
Day outings such as golf, fishing, and hunting are acceptable with prior approval from the appropriate company official. The vendor must be in attendance and participation by the associate’s family members is not acceptable.
Use of vendor’s facilities (vacation homes, etc.) by associates or families for personal use is prohibited. In the event the vendor is present for the duration of the visit such a situation is acceptable as long as it is only once per year and for limited duration, i.e. a long weekend. The associate must have prior approval from the appropriate company officer.
It is never permissible to accept a gift in cash or cash equivalent such as stocks or other forms of marketable securities of any amount.
2. Management associates should not accept gifts from those under their supervision of more than limited value.
Conflicts of Interest:
Associates should avoid any situation which involves or may involve a conflict between their personal interest and the interest of the Company. As in all other facets of their duties, associates dealing with customers, suppliers, contractors, competitors or any person doing or seeking to do business with the company are to act in the best interest of the company. Each associate shall make prompt and full disclosure in writing to their manager of any potential situation which may involve a conflict of interest. Such conflicts include:
1. Ownership by associate or by a member of their family of a significant interest in any outside enterprise which does or seeks to do business with or is a competitor of the company.
2. Serving as a director, officer, partner, consultant, or in a managerial or technical capacity with an outside enterprise which does or is seeking to do business with or is a competitor of the company. Exceptions to this can be approved by the Chief Executive Officer of Wall 18 .
3. Acting as a broker, finder, go-between or otherwise for the benefit of a third party in transactions involving or potentially involving the Company or its interests.
4. Any other arrangements or circumstances, including family or other personal relationships, which might dissuade the associate from acting in the best interest of the company.
The revelation or use of any confidential product information, data on decisions, plans, or any other information which might be contrary to the interest of the Company without prior authorization, is prohibited. The misuse, unauthorized access to, or mishandling of confidential information, particularly personnel information, is strictly prohibited and will subject an associate to the Discipline Policy up to and including immediate discharge.
Any violation of this policy will subject the associate to Administrative disciplinary action or immediate discharge. Any Company associate having knowledge of any violation of the policy shall promptly report such violation to the appropriate level of management. Each vice president and company officer of Wall 18 is responsible for compliance in their area of responsibility. When questions arise concerning any aspect of this policy, contact the corporate Vice President Human Resources.
Social media guidelines
Introduction: The attached lays out our policy in detail, but here is a brief overview. The guidelines are simple:
Use good judgment.
Remember that almost nothing you post is truly private.
Remember that you are a professional.
If you want to remember only one thing about social media, it’s this:
When you publish on Twitter, Facebook, or other platforms, you are not sharing something with a few “friends” or “followers.” You are stepping up to a microphone and making public statements that will be recorded forever and potentially broadcast to everyone on earth.
Most people won’t be listening when you first make your remarks or share your pictures or videos. But some will. And if you should ever happen to say or post something particularly provocative or newsworthy or offensive or shocking, millions of others will immediately tune in.
Importantly, it doesn’t matter what you meant or what you were thinking when you hit “publish.” What matters is what people think you meant. Perception is reality. So use good judgment.
Understand Social Media: In the rapidly expanding world of electronic communication, social media can mean many things. Social media includes all means of communicating or posting information or content of any sort on the Internet, including to your own or someone else’s web log or blog, journal or diary, personal website, social networking or affinity web site (e.g., Twitter, Facebook, LinkedIn, MySpace, Instagram, YouTube and wikis), web bulletin board or a chat room, whether or not associated or affiliated with the Company, as well as any other form of electronic communication.
Know and respect Company policies: Please make sure that you are familiar and comply with this policy and all of the policies in the Employee Handbook, to ensure that your postings are consistent with these policies. Inappropriate postings that may include discriminatory remarks, harassment, and threats of violence or similar inappropriate or unlawful content will not be tolerated and may subject you to disciplinary action up to and including termination of employment.
Be careful what you post: You are personally responsible for what you post. Remember that anything you post may be public for a long time, even if you try to modify or remove it later. The Company disclaims any responsibility or liability for any errors, omissions, loss, or damages claimed or incurred due to any of your electronic communications.
Speak for yourself, not the Company: Your postings should reflect your personal point of view, not that of the Company. If, however, you post about the Company or any of its business contacts, you must clearly identify yourself as a Company employee and be sure to include a prominent disclaimer stating that the views being expressed are your own, not those of the Company.
Be respectful and professional: Always be fair and courteous. If you decide to post complaints or criticisms, avoid using statements that reasonably could be viewed as malicious, obscene, threatening or intimidating, that disparage your co-workers or business contacts or that might constitute harassment or bullying. Examples of such conduct include offensive posts meant to intentionally harm someone’s reputation or posts that could contribute to a hostile work environment on the basis of any characteristic protected by law or Company policy. Please be professional and respectful of others in your communications, show consideration for others’ privacy and refrain from posting statements, photographs, video or audio that are false, misleading, obscene, defamatory, threatening, harassing, fraudulent, discriminatory, or invasive of the privacy of others. Note, however, that this policy is not intended to preclude or dissuade employees from engaging in activities protected by state or federal law, including the National Labor Relations Act such as discussing wages, benefits or terms and conditions of employment, including discussions regarding forming, joining or supporting labor unions, raising complaints about working conditions or other legally protected activities.
Be honest and accurate: Make sure you are always honest and accurate when posting information or news, and if you make a mistake, correct it quickly. Be open about any previous posts you have altered.
Respect laws and confidentiality: Respect copyright, trademark, privacy, financial disclosure, regulatory and all other laws. Do not disclose confidential or sensitive information about the Company, other individuals or business contacts that may have been obtained through your position with the Company, unless you have the right to do so and are taking into account intellectual property and privacy concerns. For example, ask permission before posting someone’s photograph, article, or music in a social network or publishing in a blog a conversation that was meant to be private. In accessing or using a social media site, comply with the legal terms or code of conduct governing such site.
Report your concerns: If you feel that an employee of the Company has engaged in conduct that may violate this policy, please discuss your concerns with Human Resources. The Company prohibits retaliation against any employee for reporting concerns under this policy or for cooperating in an investigation.
Wall 18 , as at most journalistic organizations, we have a strong policy against plagiarism.
Reporters must seek both sides of the story by providing an opportunity for those subject to negative accusations with an opportunity to respond. Reporters seek to convey accusations in detail and allow a fulsome response.