II. STATEMENT OF CORE VALUES SEKO is committed to creating a positive and fulfilling work environment. To this end, all employees are expected to uphold SEKO’s Core Values of Respect, Customer Focus, Integrity, Teamwork, and Work Hard - Play Hard. Acting with integrity, professionalism, and honesty are the driving forces behind SEKO’s success. SEKO has always conducted business in an ethical manner and has treated employees, customers, vendors, communities and all other stakeholders fairly. From the very beginning, SEKO has been committed to conducting its business ethically and by “doing right” by our employees, customers, vendors, suppliers, stockholders, committees and all other stakeholders. SEKO shares the responsibility for protecting and advancing SEKO’s reputation. Simply put, our ethics and values are the driving force behind our business strategies and activities. As a global organization with headquarters in the United States, SEKO must comply with the applicable laws and regulations of every jurisdiction - both in the United States, as well as in all other countries where SEKO operates. All employees and all other parties affiliated with SEKO, are charged with the responsibility of acquiring sufficient knowledge of laws and regulations relating to his/her duties in order to recognize potential non-compliance issues or violations of the Code of Conduct, and to know when to seek advice from SEKO Corporate Ethics or Legal Counsel. All managers of SEKO employees are responsible for ensuring that their employees are in compliance with the local laws and regulations that apply to their area of responsibility. IV. PRINCIPLES OF CONDUCT: a. Confidentiality and Privacy Confidentiality is one of the cornerstones of our organization and is how we measure our ethics. SEKO has confidential information that must not be revealed to outside parties. Our client lists, knowledge, techniques, written materials and other information relative to business plans and strategies, financial information, suppliers, and employee or personnel information are examples of confidential information that cannot be disclosed to an unauthorized person. This obligation not to disclose confidential information extends beyond your term of employment with SEKO. Upon termination of employment or upon the request of SEKO, employees shall return to SEKO all confidential information and other property of III. COMPLIANCE WITH LAWS, RULES, AND REGULATIONS
SEKO or its clients (and any copies thereof) in the employee’s possession. Should you leave SEKO for any reason, your obligation not to disclose such confidential information continues. b. Conflicts of Interest A conflict of interest exists when a person’s private interest interferes in any way with the interest of the Company. Employees and all other parties who are working on SEKO’s behalf are prohibited frommaking decisions in the course of employment or in their representation of SEKO that would allow them to give preference or favor to a customer in exchange for anything of personal benefit to themselves or their friends and families. Making these types of decisions could interfere with an employee’s ability to make judgments solely in SEKO’s best interest. Furthermore, employees, officers, and directors are prohibited from taking corporate opportunities and misappropriating those opportunities for themselves or for another third party without SEKO’s consent. Moreover, no employee or party affiliated with SEKO may use corporate property or information for personal gain and no employee may compete with SEKO directly or indirectly during their employment with the Company. Employees and all affiliates owe a duty to SEKO to advance SEKO’s interest when the opportunity to do so arises. c. Bribes, Gifts, Entertainment, etc. Employees and all other parties affiliated with SEKO are expressly prohibited from offering or soliciting, directly or indirectly, any special treatment or favor in return for anything of economic value or the promise or expectation of future value or gain. This prohibition also prevents employees and all other parties from giving economic and non-economic benefits to the employees, or customers of suppliers and all other parties from whom SEKO solicits business.
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