CompUSA 2013 Annual Report Download - page 79

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Any gift offered or received (for any amount) must be reported to an employee’
s supervisor. In some circumstances, such person may be
required to return the gift with a letter explaining Company policy or, if a gift is perishable or impractical to return, such person may be required
to distribute it to employees or donate it to charity, with a letter of explanation to the donor. Any gift offered or received that is greater than $100
in value must be reported to Eric Lerner, the Company’s Chief Compliance Officer.
No gift, friendship, or other non
-business aspect of any relationship with any customer or supplier should affect a Company Representative’
s
obligation to deal with all customers, prospective customers and suppliers in a manner consistent with the best interests of the Company. Neither
a Company Representative nor any member of his/her family may have any financial or economic involvement with the Company or with any
customer or supplier of the Company (such as employment or an employment agreement, a business venture, a consulting or service agreement,
or an investment other than the ownership of the stock of a publicly traded company) without prior written disclosure to the Company and
approval by the Company’s Board of Directors or a Committee of the Board.
Company managers are prohibited from accepting gifts from subordinate employees unless not of excessive value.
Company Representatives are prohibited from (a) taking for themselves personally opportunities that are discovered through the use of Company
property, information or position; (b) using Company property, information, or position for personal gain; and (c) competing with the Company.
Company Representatives owe a duty to the Company to advance its legitimate interests when the opportunity to do so arises.
Company Representatives must guard against any misappropriation, misuse or waste of the Company’
s assets or corporate opportunities. This
includes, but is not limited to, trade secrets, intellectual property rights such as trademarks and patents, product sourcing information, strategic
plans, etc. Company Representatives will refrain from the use of Company property for personal use other than on an incidental basis. Company
Representatives will comply with internal controls and procedures of the Company that are intended to allow for better management and
protection of the Company’s assets. All Company Representatives should protect the Company’
s assets and ensure their efficient use. Theft,
carelessness and waste have a direct impact on the Company’
s profitability. All Company assets should be used for legitimate business purposes.
Company Representatives must maintain the confidentiality of information entrusted to them by the Company or its customers, except when
disclosure is authorized or legally mandated. Confidential information includes all non-
public information that might be of use to competitors or
harmful to the Company or its customers if disclosed.
3
4.
Corporate Opportunities:
5.
Protection and Proper Use of Company Assets:
6.
Confidentiality: