This policy, in the interest of transparency, was intended to help protect the interest of the company and its directors, officers, employees, and consultants from unfounded accusations, or from accusations that your personal interests are compromising the integrity of your business-related actions and decisions.

The disclosure also provides an opportunity for you and your immediate superior to: 1. discuss your external activities and relationships that are or could be perceived to be conflicts of interest; and 2. develop remedial action or establish appropriate controls so that an actual conflict of interest will be avoided.