​Table of Contents

Purpose......................................................................................................................... 1

Ethics Policy................................................................................................................... 2

Build Trust and Credibility............................................................................................. 2

respect for the Individual.............................................................................................. 2

A Culture of Open and Honest Communication................................................................. 3

Tone At The Top.......................................................................................................... 3

Uphold The Law.......................................................................................................... 3

Avoid Conflict of Interest.................................................................................................. 4

Conflict of Interest....................................................................................................... 4

Accurate Reporting and Integrity........................................................................................ 5

Corporate Recordkeeping............................................................................................. 5

Use of Company Resources........................................................................................... 6

 

 

Purpose

This policy serves to outline the ethical principles that govern decisions and behavior at Extreme Converting. In this policy, Extreme Converting employees will find clear guidelines on how to conduct themselves professionally, as well as specific guidance for handling issues like harassment, safety, and conflicts of interest. Integrity, high ethical standards of business conduct and responsibility form the basis of Extreme Converting’s operations.

Extreme Converting employee is comfortable and accorded due respect in the workplace, and proper benefits made available to them for their work. This policy also provides guidance on addressing complaints, problems, and grievances you may have as an employee, and how to solve them appropriately.

The policy applies to every employee, officer, and director of Extreme Converting its subsidiaries and affiliates worldwide, as well as third parties acting on behalf of Extreme Converting.

 

For Extreme Converting employees, officers, and directors, violations of this Policy may lead to disciplinary action, up to and including termination of employment.

 

Any employee with knowledge or suspicion of violations of this Policy must report his/her concerns (as allowed by local law) to the CEO and to the Legal Counsel.

 

Ethics Policy

Our employee recruitment policy describes our process for attracting and selecting external job candidates. This policy applies to all employees who are involved in hiring for our company and refers to all potential job candidates. Extreme Converting welcomes individuals who bring new perspectives to our teams.

Build Trust and Credibility

The success of our business is dependent on the trust and confidence we earn from our employees, customers, and shareholders. We gain credibility by adhering to our commitments, displaying honesty and integrity, and reaching company goals solely through honorable conduct.

When considering any action, it is wise to ask: Will this build trust and credibility for Extreme Converting Will it help create a working environment in which Extreme Converting can succeed over the long term? Is the commitment I am making one I can follow through with? The only way we will maximize trust and credibility is by answering “yes” to those questions and by working every day to build our trust and credibility.

respect for the Individual

Extreme Converting is committed to creating such an environment because it brings out the full potential in each of us, which, in turn, contributes directly to our business success.

 

Extreme Converting is an equal opportunity employer and is committed to providing a workplace that is free of discrimination of all types and from abusive, offensive or harassing behavior. Any employee who feels harassed or discriminated against should report the incident to his or her manager or to human resources.

 

Extreme Converting will not tolerate discrimination, harassment or any behavior or language that is abusive, offensive or unwelcome. All employees are also expected to support an inclusive workplace at all times.

 

A Culture of Open and Honest Communication

At Extreme Converting everyone should feel comfortable to speak his or her mind, particularly with respect to ethics concerns. Managers have a responsibility to create an open and supportive environment where employees feel comfortable raising such questions.

Extreme Converting  will investigate all reported instances of questionable or unethical behavior. In every instance where improper behavior is found to have occurred, the company will take appropriate action. Extreme Converting will not tolerate retaliation against employees who raise genuine ethics concerns in good faith.

If applicable, insert your company’s reporting hotline or reporting system here.

 

Tone At The Top

Management has the added responsibility for demonstrating, through their actions, the importance of this Code. In any business, ethical behavior does not simply happen; it is the product of clear and direct communication of behavioral expectations, modeled from the top and demonstrated by example. Again, ultimately, our actions are what matters.

To make our Code work, managers must be responsible for promptly addressing ethical questions or concerns raised by employees and for taking the appropriate steps to deal with such issues. Managers should not consider employees’ ethics concerns as threats or challenges to their authority, but rather as another encouraged form of business communication. At Extreme Converting we want the ethics dialogue to become a natural part of daily work.

 

Uphold The Law

Extreme Converting’s commitment to integrity begins with complying with laws, rules and regulations where we do business. Further, each of us must have an understanding of the company policies, laws, rules and regulations that apply to our specific roles. If ever unsure of whether a contemplated action is permitted by law or Extreme Converting policy, seek the advice from the Human Resource Team. We are responsible for preventing violations of law and for speaking up if we see possible violations.

Because of the nature of our business, some legal requirements warrant specific mention here.

Insert any applicable industry-specific laws here

 

PROPRIETARY INFORMATION

We will not acquire or seek to acquire improper means of a competitor’s trade secrets or other proprietary or confidential information. We will not engage in unauthorized use, copying, distribution or alteration of software or other intellectual property.

 

SELECTIVE DISCLOSURE

We will not selectively disclose (whether in one-on-one or small discussions, meetings, presentations, proposals or otherwise) any material nonpublic information with respect to Extreme Converting its securities, business operations, plans, financial condition, results of operations or any development plan. We should be particularly vigilant when making presentations or proposals to customers to ensure that our presentations do not contain material nonpublic information.

 

Avoid Conflict of Interest

Conflict of Interest

We must avoid any relationship or activity that might impair, or even appear to impair, our ability to make objective and fair decisions when performing our jobs. At times, we may be faced with situations where the business actions we take on behalf of [Extreme Converting may conflict with our own personal or family interests. We owe a duty to Extreme Converting to advance its legitimate interests when the opportunity to do so arises. We must never use Extreme Converting property or information for personal gain or personally take for ourselves any opportunity that is discovered through our position with Extreme Converting.

Here are some other ways in which conflicts of interest could arise:

• Being employed (you or a close family member) by, or acting as a consultant to, a competitor or potential competitor, supplier or contractor, regardless of the nature of the employment, while you are employed with Extreme Converting.

• Hiring or supervising family members or closely related persons.

• Serving as a board member for an outside commercial company or organization.

• Owning or having a substantial interest in a competitor, supplier or contractor.

• Having a personal interest, financial interest or potential gain in any Extreme Converting transaction.

• Placing company business with a firm owned or controlled by a Extreme Converting employee or his or her family.

• Accepting gifts, discounts, favors or services from a customer/potential customer, competitor or supplier, unless equally available to all Extreme Converting employees.

Determining whether a conflict of interest exists is not always easy to do. Employees with a conflict-of-interest question should seek advice from management or the HR Department.

 

Accurate Reporting and Integrity

Accurate Public Disclosures

All disclosures made in financial reports and public documents should be full, fair, accurate, timely and understandable. This obligation applies to all employees, including all financial executives, with any responsibility for the preparation for such reports, including drafting, reviewing and signing or certifying the information contained therein. No business goal of any kind is ever an excuse for misrepresenting facts or falsifying records.

Employees should inform Executive Management and the HR Department if they learn that information in any filing or public communication was untrue or misleading at the time it was made or if subsequent information would affect a similar future filing or public communication.

Corporate Record keeping

We create, retain and dispose of our company records as part of our normal course of business in compliance with all Extreme Converting  policies and guidelines, as well as all regulatory and legal requirements.

All corporate records must be true, accurate and complete, and company data must be promptly and accurately entered in our books in accordance with Extreme Converting’s and other applicable accounting principles.

We must not improperly influence, manipulate or mislead any unauthorized audit, nor interfere with any auditor engaged to perform an internal independent audit of Extreme Converting books, records, processes or internal controls.

Use of Company Resources

Company resources, including time, material, equipment and information, are provided for company business use. Nonetheless, occasional personal use is permissible as long as it does not affect job performance or cause a disruption to the workplace.

 

Employees and all who represent Extreme Converting are trusted to behave responsibly and use good judgment to conserve company resources. Managers are responsible for the resources assigned to their departments and are empowered to resolve issues concerning their proper use.

 

Generally, we will not use company equipment such as computers, copiers and fax machines in the conduct of an outside business or in support of any religious, political or other outside daily activity, except for company-requested support to nonprofit organizations. We will not solicit contributions nor distribute non-work-related materials during work hours.

 

In order to protect the interests of the Extreme Converting network and our fellow employees, Extreme Converting reserves the right to monitor or review all data and information contained on an employee’s company-issued computer or electronic device, the use of the Internet or Extreme Converting’s intranet. We will not tolerate the use of company resources to create, access, store, print, solicit or send any materials that are harassing, threatening, abusive, sexually explicit, or otherwise offensive or inappropriate.

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