SBIC Code of Business Ethics and Conduct
| Ethics Compliance | ||
| Keys to Compliance | Management has an important and elevated role in corporate governance. In this capacity, such persons have been empowered to ensure that stakeholders' interests are appropriately balanced, protected and preserved. It is their responsibility to not only communicate and train employees in the ethical values and requirements outlined in this Code, but to lead by example. In this regard, employees have parallel responsibilities to act in compliance with this Code, to maintain high business ethics standards, and to propagate a work environment of trust and respect, of which employees and stakeholders can be proud. |
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| Report ethics and business integrity violations | Employees are obligated to report known or suspected ethics or business integrity violations. Reports may be made to your immediate supervisor. This is the typical reporting avenue, but if you do not feel it is comfortable or appropriate in a given situation, a report may be made to a higher level in the departments' management structure. Reports can also be made to:
The identity of those reporting suspected violations will be kept confidential to the maximum extent possible, though the release of certain limited information may be required to serve the purposes of this Code. There will be no retaliation against any employee for reporting a suspected violation. Additionally, you may use our 3 rd Party Fraud Hot Line to report any suspected business integrity or fraud allegations anonymously. The toll free number is 1-800-670-3523 or through the internet at https://www.compliance-helpline.com/SBICofPA.jsp . |
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| Cooperate with Code of Business Ethics and Conduct investigations and auditors | Employees have a duty to cooperate fully with ethics investigations and audits. You should answer questions posed by investigators or auditors truthfully and to the best of your ability. Depending on the matter being audited or investigated, those assigned to the task may include personnel with the requisite skills or experience, such as Human Resources, Management, or other outside personnel. Where an audit or investigation reveals the need to take corrective measures, employees have an obligation to cooperate in implementing changes in systems, practices, or procedures to avoid future problems. However, it is a management obligation to determine, based on the facts and circumstances of each case, whether a Code of Business Ethics and Conduct infraction warrants disciplinary action. Such action may involve penalties up to and including termination of employment for serious, repeated, or multiple violations. |
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| Never cover up ethics violations | Concealing or covering up an ethics violation is itself a major violation of this Code. No employee is authorized or required to carry out any order or request to conceal or cover up an ethics violation. |
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