Code of Conduct

The Company is subject to a high degree of public visibility and is therefore concerned about (1) maintaining its good reputation, and (2) how its employees represent the Company in the community. This Code of Conduct defines the ethical and professional standards by which all employees should conduct their work and structure their relationship with the Company and other employees. Each employee is expected to observe the standard of conduct outlined in this Code. Circumstances not specifically covered by this Code of Conduct should be resolved in accordance with the general principles outlined herein. In any event, the Code of Conduct requires the written self-disclosure of any circumstance which the employee believes may lead to a violation of the Code.


It is expected that employees will conduct themselves in a professional, ethical manner at all times, avoid situations which may have questionable outward appearances reflecting adversely upon the Company or impair in any way the performance of their official responsibilities on the job, and refrain from using their position with or relationship to the Company for personal gain or to the detriment or embarrassment of the Company.


It is a condition of employment that the Company’s employees strictly comply with the principles and standards of conduct established by this policy. Employees who violate the Company’s code of conduct will be subject to discipline, up to and including immediate discharge.



Company employees are expected to perform their jobs for the benefit of the Company and must conduct all business in accordance with all laws, regulations and Company policies.



The Company is committed to maintaining a work environment that is free of discrimination. We will not tolerate any form of harassment or unlawful discrimination against our employees by anyone, including managers, supervisors, other employees, vendors, residents or others. This policy prohibits harassment or similar inappropriate conduct regardless of whether the conduct is a violation of the law.
Harassment consists of unwelcome conduct, whether verbal, physical or visual, that is based upon a person’s protected status, such as sex, race, religion, national origin, age, disability or other protected group status. Harassment includes conduct that demeans or shows hostility or aversion toward an individual because of his or her protected status or that of his or her relatives, friends, or associates.


Sexual harassment deserves special mention. Unwelcome sexual advances, requests for sexual favors, and other physical, verbal or visual conduct based on sex may constitute sexual harassment. This conduct is unlawful when (1) submission to the conduct is an explicit or implicit term or condition of employment; (2) submission to or rejection of the conduct is used as the basis for an employment decision, or (3) the conduct has the purpose or effect of unreasonably interfering with a person’s work performance or creating an intimidating, hostile or offensive work environment.


Sexual harassment in violation of this policy may include: sexually¬≠oriented verbal “kidding”, “teasing” or jokes; foul or obscene language or gestures; displays of foul or obscene printed or visual material, physical contact such as patting, pinching or brushing against another’s body, and demands for sexual favors. While such conduct often can be unlawful sexual harassment only if it is both unwelcome and either severe or pervasive, the Company nonetheless discourages any such conduct in the workplace, regardless of the circumstances and regardless of whether it is unlawful. Good judgment should prevail.


All employees should understand the importance of informing an individual whenever his or her behavior is unwelcome, offensive or inappropriate. If you feel that you have experienced or witnessed discrimination or harassment, you are to immediately notify a supervisor or manager. You may report the matter to any supervisor or manager with whom you feel comfortable discussing the problem. All reports and complaints will be promptly investigated and there will be no retaliation for making a report or for cooperating with an investigation. The Company will keep complaints and the result of its investigation confidential to the extent practicable.


If an investigation confirms that a violation of this policy has occurred, then appropriate corrective action, including discipline, will be taken. The Company may impose discipline for conduct which it finds to be inappropriate, without regard to whether the conduct constitutes a violation of the law.