About
- Corporate Profile
- Story
- Board of Directors
- Management
- Committee Resolutions
Corporate Profile
Franklin Access (NASDAQ: FKWL) is a leading provider of integrated wireless solutions utilizing the latest in 4G LTE and 5G technologies, including mobile hotspots, routers, CPEs (Customer Premise Equipment), and various trackers. Our integrated software subscription services provide users with remote capabilities, including mobile device management (MDM) and software-defined wide area networking (SD-WAN).
We have majority ownership in Franklin Technology Inc. (“FTI”), a research and development company in Seoul, South Korea. FTI primarily provides design and development services for our wireless products.
Our products are marketed and sold directly to wireless operators and indirectly through strategic partners and distributors. Our global customer base extends primarily from the United States to countries in Europe, the Middle East, Africa (“EMEA”), and Asia.
Franklin Access
Our Story
Founded in 1981 as a supplier of computer components, the company began a journey of innovation, which later included early pioneering work with Voice over Internet Protocol (VoIP) technology.
More recently, Franklin Wireless was the first company to introduce a wireless broadband USB modem to the North American market and was the first company to develop and commercially deploy a dual-mode USB modem anywhere in the world.
Today, Franklin Wireless continues its rich history of innovation, striving to bring to market the most versatile, reliable, feature-rich, and cost-effective wireless solutions for its diverse customer base, which includes wireless carriers, OEMs, distributors, and consumers.
Board of Directors
Franklin Access(FWC) is led by a Board of Directors with the experience, insight, and vision to move forward as a global leader in the wireless industry.
Gary Nelson
Chairman of the Board
Gary Nelson has been a director since September 2003. Mr. Nelson was an early investor in Franklin Telecommunications Corp. in the 1980’s and served as a director from 2001 up until the Company’s merger with Accetio Inc. in September 2003, at which time the Company was renamed Franklin Wireless Corp. Following the merger, Mr. Nelson became a director and ultimately Chairman of the Board of Franklin Wireless Corp. He was co-founder and President of Churchill Mortgage Corporation, an income property mortgage banking firm based in Los Angeles, California, which was a loan correspondent for major life insurance companies and other financial institutions. In addition, Mr. Nelson was the Chief Operating Officer of Churchill Mortgage Capital, which is the loan origination arm of Churchill Mortgage Corporation. Mr. Nelson’s prior experience includes various marketing positions with Control Data Corporation and design engineering positions with North American Aviation where he worked on the Apollo Project. He holds a B.S. in Mechanical Engineering from Kansas State University and an MBA from the University of Southern California.
OC Kim
President
OC Kim has been our President and a director since September 2003. Prior to joining Franklin Wireless, Mr. Kim was the CEO and President of Accetio Inc., a company he founded in April 2001 that developed cell phones and modules for the telecommunications industry. In September 2003, Accetio Inc. merged with Franklin Telecommunications Corp. and was renamed Franklin Wireless. Prior to this, Mr. Kim was the Chief Operating Officer of Axesstel Inc., a pioneering developer of CDMA Wireless Local Loop Products. Before joining Axesstel, he was the president of the U.S. sales office for Kolon Data Communications Co., Ltd., one of Korea’s most prominent technology conglomerates. While at Kolon Data Communications, Mr. Kim helped introduce the first generation of CDMA phones to the Korean market through his work with Qualcomm Personal Electronics (QPE), a joint venture between Qualcomm Incorporated and Sony Electronics Inc. He has more than 23 years of experience in sales, marketing, and operations management in the telecommunications and information systems industries. He earned a B.A. from Sogang University in Korea.
Jonathan Chee
Director
Johnathan Chee has been a director since September 2009. He is an attorney and has owned the Law Offices of Johnathan Chee, in Niles, Illinois, since August 2007. Mr. Chee has represented clients in various business dealings and negotiations with Ameritech, SBC, Sprint, and several wireless carriers in Latin America. Between 1998 and 2007, he served as an attorney with the C&S Law Group, P.C., in Glenview, Illinois. He holds a B.A. from the University of Illinois-Chicago and a J.D. from IIT Chicago-Kent College of Law. He is a member of the Illinois Bar Association.
Heidy Chow
Director
Heidy Chow is a Certified Public Accountant and an experienced finance and accounting executive whose client base includes several IT companies. Ms. Chow is an Assurance Partner of The Pun Group, LLP and has over fifteen (15) years of combined experience in auditing, consulting and finance. Ms. Chow’s career in public accounting was spent primarily with the National firms of RSM US and Ernst & Young, and regional firms where she has specialized in corporate accounting and auditing services. She supervises engagement teams in areas of designing and planning audits following the AICPA Generally Accepted Auditing Standards and Public Company Accounting Oversight Board (PCAOB) standards. In addition, she often serves as Contract Chief Financial Officer for privately held small and middle market companies. She holds a B.S. in Accounting from California State Polytechnic University, Pomona.
Kristina Kim
Director
Kristina Kim has been a director since January 2021. Ms. Kim is a Business lawyer, and her practice focuses on international and cross border investment, trade, tax, and corporate matters, with a special attention to compliance with regulations regarding supply chain security, customs regulations compliance, tariffs and duties, and international trade agreements. Ms. Kim received her B.A. from University of California, Santa Barbara, and earned her law degree from the University of San Diego, School of Law. Ms. Kim served as General Counsel and Vice President for Samsung Electronics, the world-renowned electronics manufacturer, at its subsidiaries Samsung International, Inc., based in San Diego, California, and Samsung Mexicana, S.A. de C.V., based in Tijuana, Mexico, from 2004 to 2018. She practiced as of Counsel with the law firm of Seltzer Caplan McMahon Vitek from 2019 to 2020, with an emphasis on International Trade and Cross-Border practice.
Franklin Access
Social Responsibility
Franklin Wireless is committed to business practices that not only maximize shareholders’ value but also conduct themselves in a manner beneficial to the community locally and abroad. Franklin Access statement policies and practices are aimed at promoting the well-being of society and the environment.
Many companies throughout the nation, both large and small, are reducing the production of global warming pollutants through programs that provide economic and quality of life benefits, such as reduced energy bills, green space preservation, air quality improvements, reduced traffic congestion through energy conservation, and new energy.
Franklin Wireless Corporation and its subsidiaries will endeavor to adopt all policies and/or procedures that will benefit in the reduction of our use of natural resources and thereby aid in the reduction of our emission(s) of greenhouse gases.
Franklin Wireless Corporation and its subsidiaries acknowledge and respect the principles contained in the Universal Declaration of Human Rights. Franklin Wireless Corporation and its subsidiaries acceptance of the Universal Declaration of Human Rights reflect the Company’s commitment to conduct its business in a manner consistent with these principles and to protect human rights within the Company’s sphere of influence.
Franklin Wireless Corporation and its subsidiaries will demonstrate global leadership in responsible workplace practices, and endeavor to conduct its business operations in a manner that is free from complicity in human rights abuses. All Company employees are required to obey the law and comply with specific standards relating to legal obligations in the countries we do business in. The Company’s values and culture embody a commitment to ethical business practices and good corporate citizenship.
Franklin Wireless Corporation and its subsidiaries recognize our responsibilities under the United States Health and Safety at Work Act of 1974 and those of the countries in which we do business, along with other relevant safety legislation regarding the health and safety of our employees, as well as contractors and others who conduct business with Franklin Wireless Corporation.
The Company will provide such information, training, supervision, plant and equipment as necessary, to identify, eliminate or control hazards and risks in the workplace. Adequate resources will be provided for this purpose.
All employees and contractors are expected to cooperate with the Company in carrying out this policy and must ensure that their work, so far as is reasonably practicable, is carried out without risk to themselves or others. This policy will be reviewed on an annual basis to reflect any changes in legislation.
Franklin Wireless Corporation and its subsidiaries’ policies require that its business be conducted with honesty and integrity, and in full compliance with all applicable laws in all counties we do business in. Franklin Wireless Corporation, policies establish clear ethical standards and guidelines for how we do business and establish accountability. As a matter of policy, ethics, and business conduct guidelines are incorporated into our Company handbooks.
Historically, Franklin Wireless has been a responsible vendor when it comes to how the design, development and manufacturing of our products impact the use of our natural resources. Franklin Wireless is also exploring ways to decrease our carbon footprint through effective control of our office environment, and product design, as well as working with our customers to meet their requirements and drive all of these different initiatives and requirements through to our R&D center and our subcontractors.
Franklin Wireless’ main concern is our ecological footprint and how it may affect climate change. The company is in the process of setting future goals for reducing our ecological footprint through responsible product design and manufacturing with an eye on conservation, and reduction of greenhouse emissions and waste. Franklin Wireless has reviewed our use of natural resources and we have set goals to reduce our use of electricity and water consumption in our buildings.
Franklin Wireless is committed to maintaining adherence to all applicable laws governing our business, including local regulations for waste and air emissions. Franklin Wireless Corporation and its subsidiaries will endeavor to adopt all policies and/or procedures that will benefit in the reduction of our use of natural resources and thereby aid in the reduction of our emission(s) of greenhouse gases.
Conflict Minerals refers to minerals (tin, tantalum, tungsten and gold) mined in the eastern provinces of the Democratic Republic of the Congo and in the adjoining countries where revenues may be directly or indirectly financing armed groups engaged in civil war resulting in serious social and environmental abuses.
While we do not source these minerals directly, they may exist in the components of the products we sell. We are therefore committed to working with our suppliers to ensure that they responsibly source the materials and components used in manufacturing our products. We expect suppliers to establish their due diligence program to achieve conflict-free supply chains. Franklin Wireless is committed to ethical practices and compliance with all applicable laws and regulations.
Management
OC Kim
President
OC Kim has been our President and a director since September 2003. Prior to joining Franklin Wireless, Mr. Kim was the CEO and President of Accetio Inc., a company he founded in April 2001 that developed cell phones and modules for the telecommunications industry. In September 2003, Accetio Inc. merged with Franklin Telecommunications Corp. and was renamed Franklin Wireless. Prior to this, Mr. Kim was the Chief Operating Officer of Axesstel Inc., a pioneering developer of CDMA Wireless Local Loop Products. Before joining Axesstel, he was the president of the U.S. sales office for Kolon Data Communications Co., Ltd., one of Korea’s most prominent technology conglomerates. While at Kolon Data Communications, Mr. Kim helped introduce the first generation of CDMA phones to the Korean market through his work with Qualcomm Personal Electronics (QPE), a joint venture between Qualcomm Incorporated and Sony Electronics Inc. He has more than 23 years of experience in sales, marketing, and operations management in the telecommunications and information systems industries. He earned a B.A. from Sogang University in Korea.
David Lee
Senior Vice President of Sales - Global Carrier Business
David Lee has been the Franklin Wireless Senior Vice President of Sales since 2008. Mr. Lee has 17 years of upper-level management experience in telecommunications, including experience in the cellular telephone business in the U.S. and South America. In addition, he is in charge of the global carrier business at Franklin Wireless. Prior to joining the Company, he served as Director of Sales and Marketing for RMG Wireless. Mr. Lee graduated with a B.A. degree in accounting from Bradley University.
Bill Bauer
General Counsel / Director of Strategic Planning / Interim CFO
Bill has served as General Counsel and Director of Strategic Planning since January 2020. Prior to joining Franklin, Bill served as in-house legal counsel and as a senior executive across various industries in California and Texas. Bill also founded a successful technology company in Texas handling complex data hosting and data forensic operations for class action litigation. Bill has over 15 years of experience in the Software as a Service industry with an extensive history of building and expanding complex recurring revenue operations. Bill holds an MBA from San Diego State University and a Juris Doctorate from California Western School of Law. Bill is also a member of both the California and Texas State Bars.
John F. Parks
Director of Human Resources and Operations
A Human Resource, Operations, and Administrative Management professional with over 20 years of experience in high technology and telecommunication foreign-based companies, start-up operations, day-to-day operations, and human resource management at each assignment. Degree - Loyola University of Chicago, MBA - Illinois Benedictine University
Jeff Ward
Director of Program Management
Jeff came to Franklin Wireless in 2016. An experienced veteran in wireless communications and the telecom field for over 25 years. Specializes in bringing new and emerging products and services to market. Manages account relationships to maintain current lines of business and new opportunities. Creates new strategies that solve business challenges and generate new revenue streams. Jeff graduated with a degree in Computer technologies from the Electronics Institute in KCMO.
Mukund Halthore
Director of IoT
Mukund Halthore has been revitalizing IoT, MDM software solutions and sales at Franklin Wireless. Mr. Halthore has over 20 years of experience in bringing IoT software solutions to market using cellular networks across the Americas. Before joining Franklin, he founded a successful M2M company, Hetrogenous Inc., and served as Vice President of Infospectrum. Mr. Halthore attended Bangalore University and California State University at Northridge and has co-authored and holds multiple patents.
Franklin Access
Diversity, Equity & Inclusion Policy
Franklin Wireless Corp Diversity, Equity & Inclusion Policy
Franklin Wireless Corp is a company where we seek to foster diverse and inclusive teams, managers, and leaders to promote innovations that will power the future. We measure and track our progress to ensure our programs and policies are having a meaningful effect on our workforce.
We expect employees to embrace these values to ensure that Franklin Wirelesses’ work environment is inclusive and respectful, as well as free of harassment, discrimination, and retaliation.
Our Policies Prohibiting Discrimination, Harassment and Retaliation Franklin Wireless Corp prohibits harassment and discrimination based upon race, color, ancestry, national origin, religion, sex/gender, gender identity and/or expression, sexual orientation, age, physical disability, mental disability, veteran or military status, genetic information, pregnancy, medical condition, marital status, or any other basis prohibited by law. Franklin Wireless Corp is committed to providing equal employment opportunities for qualified individuals in all personnel practices, including recruitment, advertising, hiring, upgrading, placement, promotion, demotion, transfer, layoff, termination, and rehiring; all forms of compensation and benefits; job assignments, job classification; and any other term, condition, or privilege of employment.
Franklin Wireless Corp also prohibits retaliation against any individual who in good faith opposes, or reports known or suspected harassment or discrimination or lawfully initiates or assists in any investigation or in any action or proceeding resulting from a harassment, discrimination, or retaliation allegation. Any employee who feels that they have observed or experienced any conduct that may violate these policies is encouraged to promptly bring it to the attention of Human Resources, Legal. Employees who violate our policies prohibiting discrimination, harassment, or retaliation will be subject to appropriate disciplinary action.
Preventing Harassment Franklin Wireless Corp requires all who manage, supervise, or direct the work of others (as determined by Human Resources) to complete at least two hours of preventing harassment training every two years. We also require all non-managerial employees to complete at least one hour of preventing harassment training every two years, to create an inclusive work environment.
Reasonable Accommodation the Company engages in the interactive process to provide reasonable accommodations to employees and applicants with disabilities to permit them to perform the essential functions of their job. The Company also makes reasonable accommodations for religious practices and observances.
Committee Resolutions
Nominating Committee
WHEREAS, this Board of Directors has determined to establish a Nominating Committee in compliance with the rules established under the Securities Exchange Act of 1934, according to a Nominating Committee Charter;
WHEREAS, this corporation is planning to seek listing of its Common Stock on the Nasdaq Capital Market, which requires the adoption of a new Nominating Committee Charter;
NOW, THEREFORE, BE IT RESOLVED, that the Nominating Committee Charter, in the form submitted to the Board of Directors, be, and the same hereby is, approved and adopted, to be effective as of the date of adoption of this resolution;
RESOLVED FURTHER, that the following members of the Board of Directors are hereby appointed to serve on the Nominating Committee, at the pleasure of the Board: Gary Nelson Johnathan Chee
RESOLVED FURTHER, that each member of the Nominating Committee shall serve as such until (i) such member is removed by the Board, or (ii) such member no longer serves on the Board of Directors of the Company; in the event, any member of the Nominating Committee shall resign or cease to be a director of this corporation, the vacancy thus caused shall be filled by the Board; and
RESOLVED FURTHER, that two members of the Nominating Committee shall constitute a quorum for the transaction of business;
RESOLVED FURTHER, that the officers of this corporation are, and each acting alone is, hereby authorized to do and perform any such acts, including the execution of any documents and certificates, as such officers shall deem necessary or advisable, to carry out the purposes and intent of the foregoing resolutions.
Audit Committee
WHEREAS, this Board of Directors has previously established an Audit Committee in compliance with the rules established under the Securities Exchange Act of 1934, according to an Audit Committee Charter;
WHEREAS, this corporation is planning to seek listing of its Common Stock on the Nasdaq Capital Market, which requires the adoption of a new Audit Committee Charter;
NOW, THEREFORE, BE IT RESOLVED, that the Audit Committee Charter, in the form submitted to the Board of Directors, be, and the same hereby is, approved and adopted, to be effective as of the date of adoption of this resolution;
RESOLVED FURTHER, that the following members of the Board of Directors are hereby appointed to serve on the Audit Committee, at the pleasure of the Board:
Heidy Chow, Chair
Gary Nelson
Johnathan Chee
RESOLVED FURTHER, that each member of the Audit Committee shall serve as such until (i) such member is removed by the Board, or (ii) such member no longer serves on the Board of Directors of the Company; in the event, any member of the Audit Committee shall resign or cease to be a director of this corporation, the vacancy thus caused shall be filled by the Board; and
RESOLVED FURTHER, that two members of the Audit Committee shall constitute a quorum for the transaction of business;
RESOLVED FURTHER, that the officers of this corporation are, and each acting alone is, hereby authorized to do and perform all such acts, including the execution of all documents and certificates, as such officers shall deem necessary or advisable, to carry out the purposes and intent of the foregoing resolutions.
Compensation Committee
WHEREAS, this Board of Directors has previously established a Compensation Committee; according to a Compensation Committee Charter;
WHEREAS, this corporation is planning to seek listing of its Common Stock on the Nasdaq Capital Market, which requires the adoption of a new Compensation Committee Charter;
NOW, THEREFORE, BE IT RESOLVED, that the Compensation Committee Charter, in the form submitted to the Board of Directors, be, and the same hereby is, approved and adopted, to be effective as of the date of adoption of this resolution;
RESOLVED FURTHER, that the following members of the Board of Directors are hereby appointed to serve on the Compensation Committee, at the pleasure of the Board:
Gary Nelson, Chair.
Johnathan Chee
RESOLVED FURTHER, that each member of the Compensation Committee shall serve as such until (i) such member is removed by the Board, or (ii) such member no longer serves on the Board of Directors of the Company; in the event any member of the Audit Committee shall resign or cease to be a director of this corporation, the vacancy thus caused shall be filled by the Board; and
RESOLVED FURTHER, that two members of the Compensation Committee shall constitute a quorum for the transaction of business;
RESOLVED FURTHER, that the officers of this corporation are, and each acting alone is, hereby authorized to do and perform all such acts, including the execution of all documents and certificates, as such officers shall deem necessary or advisable, to carry out the purposes and intent of the foregoing resolutions.
Code of Ethics
The Board of Directors of Franklin (the “Company”) has adopted this Code of Ethics for all Franklin Wireless Corporation employees regardless of their position within the Company.
This Code has been reasonably designed to deter wrongdoing and to promote:
- Honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships.
- Full, fair, accurate, timely, and understandable disclosure in reports and documents that are filed with the Securities and Exchange Commission and in other public communications.
- Compliance with applicable governmental laws, rules and regulations.
- The prompt internal reporting to an appropriate person or persons identified in this Code of violations of this Code; and Accountability for adherence to this Code.
I. Honest and Ethical Conduct
The Company Officers are expected to act and perform their duties ethically and honestly. Honest conduct is considered to be conduct that is free from fraud or deception. Ethical conduct is considered to be conduct conforming to accepted professional standards of conduct. Ethical conduct includes the ethical handling of actual or apparent conflicts of interest between personal and professional relationships, as discussed below
II. Conflicts of Interest
A conflict of interest exists where the interests or benefits of one person or entity conflict or appear to conflict with the interests or benefits of the Company. While it is not possible to describe every situation in which a conflict of interest may arise, Company Officers must never use or attempt to use their position with Company to obtain improper personal benefits. Any Company Officer who is aware of a conflict of interest, or is concerned that a conflict might develop, is required to discuss the matter with a higher level of management or the Chief Financial Officer promptly. Company Officers may, in addition to speaking with the Chief Financial Officer, also discuss the matter with any member of the Audit Committee of the Board of Directors.
III. Disclosure
Company Officers are responsible for ensuring that the disclosure in the Company’s periodic reports is full and accurate. In doing so, they should take such action as is reasonably appropriate to (i) establish and comply with disclosure controls and procedures and accounting and financial controls that are designed to ensure that material information relating to Company is made known to them; (ii) confirm that the Company’s periodic reports comply with the requirements of the Securities Exchange Act of 1934; and (iii) ensure that information contained in the Company's periodic reports fairly presents in all material respects its financial condition and results of operations.
Company Officers may not knowingly (i) make materially false or misleading entries in its financial statements or records; (ii) fail to correct materially false and misleading financial statements or records; (iii) sign a document containing materially false and misleading information; or (iv)falsely respond, or fail to respond, to specific inquiries of its independent auditors or legal counsel.
IV. Internal Reporting
Company Officers shall take all appropriate action to stop any known misconduct by fellow Company Officers that violate this Code. To this end, Company Officers should report any known or suspected misconduct to the Chief Financial Officer or to the Chair of the Company’s Audit Committee.
V. Accountability
Company Officers shall take all appropriate action to stop any known misconduct by fellow Company Officers that violate this Code. To this end, Company Officers should report any known or suspected misconduct to the Chief Financial Officer or to the Chair of the Company’s Audit Committee.
VI. Waivers and Amendments of the Code
The Company is committed to continuously reviewing and updating its policies and procedures. Therefore, this Code is subject to modification. Any amendment or waiver of any provision of this Code must be approved in writing by the Board of Directors and promptly disclosed pursuant to applicable laws and regulations.
Commitment to our Operations and Business Activity
The company is committed to conducting its operations and business activities in a safe, healthy, and productive manner, protecting the environment, and conserving natural resources. The company employees are expected to keep themselves and those with whom they work safe by performing all work in compliance with applicable health, safety, and environmental laws and regulations.
We also ensure our colleagues are safe by reporting suspicious or concerning circumstances to the Human Resources. This includes employees or non-employees behaving in a manner that is suspicious or potentially dangerous, visitors inside our facilities without an escort, any personal threats or threatening behaviors, and other illegal or inappropriate activities. To maintain a safe, secure, and healthy work environment, we must never: • Intimidate, harass, or threaten anyone – directly or indirectly. • Commit acts of violence as prohibited by our Workplace Violence Policy. • Possess weapons of any kind on The company property, including Company parking areas. • Violate Company policies that prohibit the unlawful use, distribution, possession, or sale of alcohol, drugs, or other controlled substances
Our Success
The company’s success is based upon our technical leadership. As such, it is imperative that we protect confidential information, whether it’s information about our Company, our customers, our employees, or third-party information that has been entrusted to us.
We take proper precautions to protect confidential information. • We do not share inappropriately. We do not disclose or distribute confidential information unless necessary for business purposes. Before disclosing information that may be confidential to others – whether oral, visual, or written – we must ensure that written confidentiality obligations approved by the Legal Department are in place (such as a written Non-Disclosure Agreement (NDA)). • We use information responsibly. We use this information only to perform our job duties and to further the Company’s interests.
We pay attention to the details by guarding our Company passwords. • We watch where we talk. We do not discuss confidential information in places where others could overhear it, such as around family members or roommates, or in public locations, such as restaurants, coffee shops, a trade show, or in an airplane, train, or elevator.
We exercise care when deciding whether to receive confidential information. Before entering an NDA with a third party, we should consider whether it is possible to accomplish the business purpose without receiving confidential information. For example, by not receiving confidential information, we lessen the risk that the Company is accused of misusing that information.
We respect obligations we assume in NDAs. We comply with the letter and spirit of confidentiality obligations.
Conflict of Interest
These can occur when a personal interest or activity (like a gift, a personal relationship, vendor relationship, or outside business activity) influences – or appears to influence – our ability to use good judgment or make business decision(s) in the Company’s best interests. They erode trust, may put the Company at risk, and could damage its reputation. At the company, each of us is expected to be transparent, avoid situations that may present actual, potential, and/or perceived conflicts, and ensure that we are always acting in the best interest of the Company. Lead the Way We are each responsible for actively avoiding any situation in which a conflict of interest might arise. While conflicts of interest come in a variety of formats and scenarios, there are some common situations that we should all know how to manage. Gifts, Entertainment, and Hospitality We should never give or accept gifts, or anything else of value, if it could appear to influence our judgment or any business decision improperly. In general, we should not solicit gifts and may not accept gifts of more than nominal value. Perishable gifts or marketing materials with a company logo are generally not considered improper. An infrequent meal may be accepted or given if it is held at an appropriate location and is not excessive, and where the purpose of the meal is secondary to a business meeting or to enhance business relationships. The giver of the gift should not expect anything in return. Our employees are to consult with Human Resources and Legal for more guidance on giving and receiving gifts.
As a general rule, any cash or cash equivalent benefit that is offered to you by a company business partner or a vendor that is pursuing The company’s business is prohibited under our Conflicts of Interest Policy
Insider trading happens when a person or entity trades in a security (e.g., purchase/sale of stock, options, puts, calls) while in possession of “material nonpublic information.” Material non-public information is information about a company that is not available to the investing public and is likely to influence a reasonable investor’s decision to buy or sell securities of that company. Both positive and negative information may be material. Insider trading is illegal, unethical, and violates our Insider Trading Policy and this Code.
We operate within the law wherever we do business, and we are each responsible for ensuring that the Company abides by applicable laws.
