Amendments to the CEO/Senior Financial Officers Code of Ethics
Revisions to our Chief Executive Officer/Senior Financial Officers Code of Ethics (the "Code") were approved by the Board of Directors on April 18, 2008. Significant changes to the prior version include the following:
- Relationship with Accountants and Auditors. The existing prohibition against providing an auditor with an inaccurate or misleading legal analysis was modified to prohibit "knowing" conduct.
- Application of Certain Provisions to Immediate Family Members and Affiliated Entities. A number of existing provisions of the Code (such as prohibitions against the Company making loans, and the prohibition against maintaining an interest in certain transactions with the Company) were explicitly extended to apply to members of the Covered Executive's immediate family and specified affiliated entities.
- Improper Inducements. The revisions removed exceptions to the provisions that prohibit Covered Executives from accepting gifts or anything of value from third parties doing business or seeking to do business with the Company. In addition, the Code now clarifies that the Covered Executives are also subject to the Gifts and Entertainment Policy of the Company's Code of Business Conduct and Ethics.
- Reporting Code Violations. The Code was updated to identify the current Chairman of the Audit Committee as an individual to whom violations may be reported and to provide an Internet option for providing anonymous notice of violations.
View the complete Chief Executive Officer/Senior Financial Officers Code of Ethics, including these new modifications.
