REPORTING VIOLATIONS

All employees are responsible for compliance with these rules, standards and principles. In the area   of ethics, legality and propriety, each employee has an obligation to the company that transcends   normal reporting relationships. Employees should be alert to possible violations of the code   anywhere in the company and are encouraged to report such violations promptly. Reports should   be made to the employee’s supervisor, the appropriate security, audit, or legal department personnel,   or elsewhere as the circumstance dictates.

Employees will also be expected to cooperate in an investigation of violations. In addition, any employee who is convicted of a felony, whether related to these rules or not, should also report that fact. All cases of questionable activity involving the code or other potentially improper actions will be reviewed for appropriate action, discipline, or corrective steps. Whenever possible, the company will keep confidential the identity of employees about or against whom allegations of violations are brought, unless or until it has been determined that a violation has occurred.

Similarly, whenever possible, the company will keep confidential the identity of anyone reporting a possible violation. Reprisal against any employee who has, in good faith, reported a violation or suspected violation is strictly prohibited. All employees are required to notify the company within five (5) days of any conviction of any criminal statute violation occurring on the job. In addition, any employee who is convicted of a felony, whether related to these rules or not, should report that fact.