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termination of an employee's employment, for any reason, or, at any time upon request, the <br />employee shall promptly deliver (and will not keep in his or her possession, recreate or deliver to <br />anyone else) any company property. Employees must return (and not retain copies) all of <br />company property contained on any of employees personal equipment (i.e. on home or <br />personal computer or other equipment). Nothing in this policy is intended in anyway to <br />interfere with, coerce, or restrain any employee from exercising his or her rights under any State <br />or Federal labor law, including the National Labor Relations Act. <br />21. CONFIDENTIALITY <br />All records and files of the Company are the property of the Company and considered <br />confidential. No employee is authorized to copy or disclose any file or record. Confidential <br />information includes all letters or any other information concerning deals with customers, <br />customer lists, payroll or personnel records of past or present employees, financial records of the <br />Company, all records pertaining to purchases from vendors or suppliers, correspondence and <br />agreements with manufacturers or distributors, and documents concerning operating <br />procedures of the Company. All company employees are responsible for safeguarding sensitive <br />Company information. Unless otherwise identified by management, employees must assume <br />that all such information is confidential. Employees who have access to confidential information <br />are required to sign a confidentiality agreement as a condition of employment. Any employee <br />who discloses trade secrets or confidential business information will be subject to disciplinary <br />action up to and including termination. The Company reserves the right to avail itself of all <br />remedies under the law. Nothing in this policy is intended in any way to interfere with, coerce, or <br />restrain any employee from exercising his or her rights under any State or Federal labor law, <br />including the National Labor Relations Act, <br />22. ETHICAL BEHAVIOR <br />The reputation of our Company is a direct reflection of the business conduct of all employees. To <br />protect and enhance our reputation, all employees are required to follow the highest standard <br />of conduct in all business contacts and relationships. <br />The following is a summary of the Company's policy regarding business ethics: <br />22.1. Gifts, favors, and payments may be given to others at Company expense, only if they <br />are consistent with accepted business practices, they are of sufficiently limited value and in a <br />form that will not be construed as a bribe or payoff, they are not in violation of applicable law <br />and generally accepted ethical standards; and public disclosure of the facts will not in any way <br />impede on the Company's excellent reputation. <br />22.2. Payments, commissions or other compensation to or for the benefit of associates of <br />customers (or their family members or associates) not required by written contract are contrary <br />to Company policy. <br />22.3. Employees shall not seek or accept for themselves or others any gifts, favors, <br />entertainment, payments without a legitimate business purpose nor shall they seek or accept <br />personal loans (other than conventional loans at market rates from lending institutions) from any <br />persons or business organizations that do or seek to do business with or is a competitor of the <br />Company. <br />37 <br />