Code of Coduct

Organizational Code of Conduct

The Company and its employees must, at all times, comply with all applicable laws and regulations. The Organization will not condone the activities of employees who
achieve results through violation of the law or unethical business dealings. This includes any payments for illegal acts, indirect contributions, rebates, and bribery. The
Organization does not permit any activity that fails to stand the closest possible public scrutiny.

All business conduct should be well above the minimum standards required by law. Accordingly, employees must ensure that their actions cannot be interpreted as being, in any way, in contravention of the laws and regulations governing the Organization’s operations.

General Employee Conduct

The company expects its employees to conduct themselves in a business-like manner. Drinking, gambling, fighting, swearing, and similar unprofessional activities are strictly prohibited while on the job. Employees must not engage in sexual harassment, or conduct themselves in a way that could be construed as such, for example, by using inappropriate language, keeping or posting inappropriate materials in their work area, or accessing inappropriate materials inside the buses.

Conflicts of Interest

The company expects that employees will perform their duties conscientiously, honestly, and in accordance with the best interests of the company. Employees must not use their positions or the knowledge gained as a result of their positions for private or personal advantage.

Regardless of the circumstances, if employees sense that a course of action they have pursued, or are presently pursuing, or are contemplating pursuing may involve them in a conflict of interest with their employer, they should immediately communicate all the facts to their supervisor.

Outside Activities, Employment and Directorships

All employees share a serious responsibility for the company’s good public relations, especially at the community level. Their readiness to help with religious, charitable, educational, and civic activities brings credit to the company and is encouraged. Employees must, however, avoid acquiring any business interest or participating in any other activity outside the company that would, or would appear to:

• Create an excessive demand upon their time and attention, thus depriving the Organization of their best efforts on the job.
• Create a conflict of interest – an obligation, interest, or distraction – that may interfere with the independent exercise of judgment in the Organization’s best interest.

Organization Records and Communications

Accurate and reliable records of many kinds are necessary to meet the company’s legal and financial obligations and to manage the affairs of the Organization. The company’s books and records must reflect in an accurate and timely manner all business transactions. The employees responsible for accounting and recordkeeping must fully disclose and record all assets, liabilities, or both, and must exercise diligence in enforcing these requirements.

Employees must not make or engage in any false record or communication of any kind, whether internal or external, including but not limited to:

• False expense, attendance, production, financial, or similar reports and statements
• False advertising, deceptive marketing practices, or other misleading representations

Dealing with Outside People and Organizations

Employees must take care to separate their personal roles from their company’s positions when communicating on matters not involving Organization business.

Employees must not use organization identification, stationery, supplies, and equipment for personal or political matters. When communicating publicly on matters that involve Organization business, employees must not presume to speak for the Organization on any topic, unless they are certain that the views they express are those of the Organization, and it is the Organization’s desire that such views be publicly disseminated. When dealing with anyone outside the Organization, including public officials, employees must take care not to compromise the integrity or damage the reputation of either the company, or any outside individual, business, or government body.

Prompt Communications

In all matters relevant to customers, suppliers, government authorities, the public and others in the Organization, all employees must make every effort to achieve complete, accurate, and timely communications – responding promptly and courteously to all proper requests for information and to all complaints

Privacy and Confidentiality

When handling financial and personal information about customers or others with whom the Organization has dealings, observe the following principles:

• Collect, use, and retain only the personal information necessary for the Organization’s business. Whenever possible, obtain any relevant information directly from the person concerned. Use only reputable and reliable sources to supplement this information.
• Retain information only for as long as necessary or as required by law. Protect the physical security of this information.
• Limit internal access to personal information to those with a legitimate business reason for seeking that information. Use only personal information for the purposes for which it was originally obtained. Obtain the consent of the person concerned before externally disclosing any personal information, unless legal process or contractual obligation provides otherwise.