Outside Employment

Employees may accept work in addition to their work with the Company if:

• Such employment does not constitute a conflict of interest with the employee's duties;

• Such employment does not interfere with the employee's job with the Company;

• Such employment is not during the employee's regular working hours;

Employees shall notify their supervisor in writing of any outside employment and a decision made as to possible conflicts of interest. The notice and decision will be placed in the employee's personnel file.

No employee shall directly or indirectly maintain any outside business or financial interest, or engage in any outside business or financial activity, which conflicts with the interests of the Company or that interferes with his ability to discharge his duties fully.

All employees are required to disclose in writing to the Company any proprietary or financial interest they may have in any organization with which the Company does business in order that a determination is made as to whether a conflict of interest exists.

A conflict of interest is an activity that is actually opposed to, or that might be implied by anyone to be opposed to, the legitimate best interest of the Company. Such activities could make a broad list nearly impossible to compile. The ultimate responsibility, therefore, falls on each employee to determine his own ethical position within the framework of the definition of conflict of interest.

Some activities can be treated specifically; the following acts can be considered a conflict of interest:

• Releasing and/or using confidential information for personal gain;

• "Insider" trading;

• Utilizing an employee's position or confidential information gained there from in any business transaction or arrangement for financial gain for the employee or a member of immediate family;

• Asking for or accepting any gift or favor from any business organization or employee of such organization with which the employee performs work or makes decisions unless approved by Management. Any such gifts other than inexpensive advertising or promotional novelties should be returned to the sender;

• Giving any personal organization special treatment of any kind other than that normally given in similar situations;

• Representing or acting as an agent for any private interests in any transaction where the Company has a direct interest and where the employee has a direct interest and where the employee has any involvement through responsibilities as an employee of the Company;

• Employee or immediate family maintaining a financial or personal interest in any business entity for which the employee has substantial regulatory, enforcement or purchasing responsibilities.

Last Updated: 10.17.09