MWF Employee Handbook

2.6 Fraud, Dishonesty & Misrepresentation

present problems. If an employee has any question whether an action or proposed course of conduct would create a conflict of interest, they should immediately contact the Human Resources Department to obtain advice on the issue before engaging in any such activity. The purpose of this policy is to protect employees from any conflict of interest that may arise. Nothing in this policy is intended to or shall be construed to prohibit employees from engaging in lawful, concerted protected activity within the meaning of the National Labor Relations Act. A violation of this policy will result in immediate and appropriate discipline up to and including immediate termination. Outside Employment Employees are permitted to engage in outside work or to hold other jobs, subject to certain restrictions as outlined below.

No employee or candidate may ever falsify any application, medical history record, paperwork, investigative questionnaires, or any other document. Any employee found to have engaged in resume fraud or who made material representations or omissions on any Company documents will be subject to disciplinary action, including immediate termination of employment. If you observe any such violations, please report them to your supervisor or the Human Resources Department.

2.7 Conflict of Interest & Outside Employment General

Midwest Fastener Corp. expects its employees to conduct business according to the highest ethical standards of conduct. Employees are expected to devote their best efforts to the interests of the Company. Business dealings appearing to create a conflict between the interests of the Company and an employee are unacceptable. The Company recognizes the right of employees to engage in activities outside of their employment that are of a private nature and unrelated to the business. However, the employee must disclose any possible conflicts so that the Company may assess and prevent potential conflicts of interest from arising. A potential or actual conflict of interest occurs whenever an employee can influence a decision that may result in personal gain for the employee or an immediate family member (i.e., spouse or significant other, children, parents, siblings) as a result of the Company’s business dealings. Employees must refrain from any activity or have a financial interest inconsistent with the Company’s best interest and from activities, investments, or associations that compete with the Company or interfere with one’s judgment concerning the Company’s best interest. Although it is not possible to specify every action that might create a conflict of interest, this policy sets forth the ones that most frequently

Outside work activities are not allowed when they

• Pevent the employee from fully performing work for which they are employed at the Company, including overtime assignments. • Involve organizations doing or seeking to do business with the

Company, including actual or potential vendors or customers. • Involve the performance of any services for customers on nonworking time that are normally performed by the Company (such prohibition extends to the unauthorized use of any of the Company’s tools, equipment and/or confidential information); or • Violate provisions of law or the Company’s policies or rules. Midwest Fastener Corp. employees may be required to work beyond their normally scheduled hours. Employees must perform this work when requested. In cases of conflict with any outside activity, the employee’s obligations to the Company must be given priority. Employees are hired and continue in Midwest Fastener Corp.’s

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800-444-7313 •

800-388-9798 •

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