Policy and Acknowledgment Ethics and Integrity

Policy and Acknowledgment Ethics and Integrity Employee conduct, actions, and dealings with others at work make a statement about our company and creates an “image” of our organization. We ask for your commitment to keep our image positive and that your conduct reflects professionalism, courtesy, and integrity at all times. The following topics outline our standards of ethical practice. This summary does not completely address all the ethical decisions you might face and is intended only as a guide. If you have questions about a particular situation, see your manager, or the Vice President of Human Resources. Full disclosure is always the best policy. PROTECTING COMPANY ASSETS Supplies, equipment, and information are company assets. Employees who have access to proprietary and confidential information must take every precaution to keep it confidential. CONFLICTS OF INTEREST The Larry H. Miller Group of Companies wishes to avoid conflicts of interest. An employee may hold other employment, so long as the employee is still able to effectively meet the performance standards of his or her position. Employees must disclose all outside employment to the Company in writing. If the Company determines that an employee’s outside work interferes with his/her performance or the ability to meet job requirements, the employee may be asked to terminate the outside employment if he/she wishes to remain employed. Additionally, an employee is required to obtain written approval from the General Manager before beginning any outside job that could create a potential conflict of interest. Please contact the General Manager if you have a financial interest in any outside entity, to ensure that none of these interests pose a conflict of interest with your employment. ACCEPTING GIFTS Employees cannot accept or solicit any benefit (gift) from a current or potential business vendor or supplier that might compromise or even appear to compromise his or her assessment of the vendor or supplier. If at any time you have information or knowledge involving either unethical or illegal behavior on the part of another employee, including individuals in more senior or supervisory positions, we encourage you to report this information promptly to your General Manager, or Human Resources. Once made aware, management will investigate all allegations promptly, objectively, and confidentially. The Larry H. Miller Group of Companies will take no adverse action against any employee for bringing these matters to its attention, and it will take reasonable steps to protect employees against retaliation and reprisal from other employees including an offending supervisor. Based on the results of the investigation, management will take appropriate corrective action. Employees having access to customer information are strictly prohibited from sharing, disclosing, intentionally viewing or accessing, or causing to be viewed or accessed any customer information to any person or entity. No form of customer information (verbal, written, or electronic) may be removed from an employee’s place of business. An employee who violates this policy is subject to disciplinary action, up to and including termination.

12/15/2015