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| About UMD - Code of Conduct |
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As Compliance Officer, I have a special responsibility to review ethical and legal compliance issues within the Company. It is my responsibility to ensure that appropriate procedures, with respect to ethics and legal matters, are in place and enforced throughout our Company.
The Code introduces you to the Compliance Program and my compliance function. One of these functions is to make myself, and the other Compliance staff, available to all as a resource for providing guidance on the program’s standards, policies and procedures. Additionally, the Company has a reporting system that allows you, as employees, to report on a confidential basis any occurrences of misconduct within the Company, without fear of retribution.
This Code was created to meet the needs of our Company, ensure compliance with applicable laws and regulations and provide employees with clear requirements for appropriate behavior.
You are required to familiarize yourself with the standards, policies and procedures of the Code of Conduct and Compliance Program. It is imperative that you understand how these standards, policies and procedures relate to you.
If at any time you have any questions regarding the Code of Conduct and Compliance Program, please do not hesitate to discuss them with your supervisor or manager or you can contact a member of the Compliance staff to discuss your concerns with him or her. You may also call the Company’s confidential compliance hotline at 1-800-798-1453. There will be no retaliation for good faith reports to the hotline.
Disciplinary action for Code violations range from a verbal reprimand up to and including termination. If you are aware, or become aware, of a potential or actual violation of the Code, you must report it to management or a member of the Compliance staff as soon as possible. Failure to report a violation of the Code will subject you to disciplinary action.
In my role as Compliance Officer, I am proud to contribute to a process that will ensure that our business practices maintain the highest level of integrity. You have my commitment that the company and I will remain active participants to improve the ways in which we do business.
Kenneth J. Sodaro
Vice President, General Counsel
& Corporate Secretary |
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