Employee Integrity & Loss Prevention Policy

Purpose

To protect the Company, its employees, and its assets from theft, embezzlement, fraud, and other dishonest or illegal acts, and to set out how such incidents are reported and investigated.

Policy

Theft, embezzlement, misappropriation of Company funds or property, and other dishonest or illegal acts ("integrity violations") will not be tolerated, regardless of the dollar amount involved or the employee's position or tenure.

Employees who engage in an integrity violation are subject to disciplinary action, up to and including termination, as well as civil liability and criminal prosecution where warranted.

An employee who becomes aware of a suspected integrity violation and fails to report it is also considered to have violated this policy, and is subject to the same range of consequences.

What this covers

Examples of conduct covered by this policy include, but are not limited to:

• Theft or misappropriation of Company funds, property, inventory, or information.
• Embezzlement or diversion of Company assets for personal benefit.
• Falsifying expense reports, timekeeping records, or other Company documents.
• Accepting kickbacks or unauthorized payments related to Company business.
• Knowingly assisting another person in any of the above.

Reporting

Any employee who discovers or reasonably suspects an integrity violation should report it immediately to their manager, Human Resources, or another appropriate member of management. Reports may also be made through any confidential ethics or compliance reporting channel the Company maintains.

The Company will not retaliate against anyone who reports a suspected violation in good faith, and retaliation is itself grounds for discipline.

Beyond this Company policy, employees who report suspected fraud or financial misconduct in good faith may also have legal whistleblower-retaliation protections under federal law, depending on the Company's structure and the nature of the report — for example, Section 806 of the Sarbanes-Oxley Act (as amended by the Dodd-Frank Act) for employees of publicly traded companies (and certain of their contractors and subcontractors) who report conduct they reasonably believe is securities fraud, mail or wire fraud, bank fraud, or a violation of SEC rules; the Dodd-Frank Act's separate SEC whistleblower-award and anti-retaliation provisions; and the False Claims Act's retaliation protections for reporting fraud against the government. These legal protections exist independent of this policy and are not a substitute for it — this policy's internal reporting channels and non-retaliation commitment apply regardless of whether a report also happens to be protected under one of these external statutes.

Investigation

Reports of suspected integrity violations will be reviewed promptly. Depending on the nature and severity of the allegation, an investigation may involve Human Resources, Finance/Internal Audit, Legal, and security/loss-prevention staff, and — where appropriate — law enforcement.

The Company reserves the right, at any time, to pursue civil recovery and/or refer a matter for criminal prosecution, independent of any internal disciplinary action taken.

Responsibilities

Role	Responsibility
All employees	Report suspected integrity violations promptly. Cooperate with any resulting investigation.
Managers	Ensure their teams understand this policy. Escalate reports promptly to Human Resources; do not investigate serious allegations on their own.
Human Resources / Finance / Legal	Coordinate the investigation, determine appropriate disciplinary action, and involve law enforcement where warranted.