Corporate Fraud Handbook, 5th Edition

APPENDIXSample Code of Business Ethics and Conduct

INTRODUCTION

This code of ethics reaffirms the importance of high standards of business conduct. Adherence to this code by all employees is the only sure way we can merit the confidence and support of the public.

This code has been prepared as a working guide and not as a technical legal document. Thus, emphasis is on brevity and readability rather than providing an all‐inclusive answer to specific questions. For example, the term “employee” is used in its broadest sense and refers to every officer and employee of the company and its subsidiaries. The word “law” refers to laws, regulations, orders, etc.

In observance of this code, as in other business conduct, there is no substitute for common sense. Each employee should apply this code with common sense and the attitude of seeking full compliance with the letter and spirit of the rules presented.

It is incumbent on you, as an employee of the company, to perform satisfactorily and to follow our policies and comply with our rules as they are issued or modified from time to time.

These policies and rules are necessary to effectively manage the business and meet the ever‐changing needs of the marketplace. Good performance and compliance with business rules lead to success. Both are crucial since our ability to provide you with career opportunities depends totally on our success in the marketplace. Nonetheless, changes in our economy, our markets, and our technology are inevitable. ...