FairPoint Communications 2004 Annual Report Download - page 488

professional relationships under applicable accounting rules and the Securities and Exchange Commission’s (the “ SEC”) rules and regulations. Any dealings
with a related party must be conducted in such a way as to avoid preferential treatment and assure that the terms obtained by the Company are no less
favorable than could be obtained from unrelated parties on an arm’s-length basis.
Conflicts of interest or the material nature of a transaction or relationship may not always be clear-cut; if questions arise, you
should consult with the Legal Department before entering into, developing or continuing a transaction that could reasonably be expected to give rise to a conflict
of interest.
(e) 
Because other conflicts of interest may arise, it would be impractical to attempt to list all possible situations. Any employee,
officer or director who becomes aware of a conflict of interest or a potential conflict of interest should bring it to the attention of a supervisor, manager or other
appropriate personnel or consult the guidelines described in Section 16 of this Code.
3. 
Employees, officers and directors who have access to confidential information are not permitted to use or share that information for stock
trading purposes or for any other purpose except the conduct of our business. All non-public information about the Company should be considered
confidential information. To use non-public information about the Company or any other company for personal financial benefit or to “tip” others who might
make an investment decision on the basis of this information is not only unethical but also illegal. Please refer to the Company’s Insider Trading Policy. The
purpose of such policy is to inform you of your legal responsibilities to make clear to you that the misuse of sensitive information is contrary to Company
policies and to set forth procedures with respect to trading in the Company’s securities.
4. 
The Company is committed to providing full, fair, accurate, timely and understandable disclosure in the periodic reports and other
information it files with or submits to the SEC and in other public communications, such as press releases, earnings conference calls and industry
conferences, made by the Company. In meeting such standards for disclosure, the Company’s executive officers and directors shall at all times strive to
comply with the Company’s disclosure obligations and, as necessary, appropriately consider and balance the need or desirability for confidentiality with
respect to non-public negotiations or other business developments. The Company’s CEO and CFO are responsible for establishing effective disclosure
controls and procedures and internal controls over financial reporting within the meaning of applicable SEC rules and regulations. The Company expects the
CEO and CFO to take a leadership role in implementing such controls and procedures and to position the Company to comply with its disclosure obligations
and otherwise meet the foregoing standards for public disclosure.
No employee, officer or director should interfere with, hinder or obstruct the Company’s efforts to meet the standards for public disclosure
set forth above.
5. 
Employees, officers and directors are prohibited from exploiting for their own personal gain opportunities that are discovered through the
use of corporate property, information or position unless the opportunity is fully disclosed to the Board and the Board declines to pursue such opportunity.
No employee, officer or director may use corporate property, information, or position for improper personal gain, and no employee may compete with the
Company directly or indirectly. Employees, officers and directors owe a duty to the Company to advance the Company’s legitimate interest when the
opportunity to do so arises.