All of Resource’s books, records, accounts and financial statements must be maintained in reasonable detail, must appropriately reflect Resource’s transactions and must conform both to applicable legal requirements and to Resource’s system of internal controls. Unrecorded or “off the books” funds or assets should not be maintained unless permitted by applicable law or regulation.
Business records and communications often become public, and all Employees should avoid exaggeration, derogatory remarks, guesswork, or inappropriate characterizations of people and companies that can be misunderstood. This applies equally to e-mail, internal memos, and formal reports.
Employees must maintain the confidentiality of confidential information entrusted to them by Resource, except when disclosure is authorized by Resource’s counsel or required by laws or regulations. Confidential information includes all non-public information that might be of use to competitors, or harmful to Resource or its customers, if disclosed. It also includes information that Resource’s tenants, or parties with whom Resource has investing or lending arrangements have entrusted to it. The obligation to preserve confidential information continues even after employment ends.
| 10. | Protection and Proper Use of Resource Assets |
All Employees should endeavor to protect Resource’s assets and ensure their efficient use. Theft, carelessness, and waste have a direct impact on Resource’s profitability. Any suspected incident of fraud or theft should be immediately reported for investigation. Resource equipment should not be used for non-Resource business, though incidental personal use may be permitted.
The obligation of Employees to protect Resource’s assets includes its proprietary information. Proprietary information includes intellectual property such as trade secrets as well as business, marketing and service plans, databases, records, salary information and any unpublished financial data and reports. Unauthorized use or distribution of this information would violate Resource policy. It could also be illegal and result in civil or even criminal penalties.
| 11. | Payments to Government Personnel |
The U.S. government has a number of laws and regulations regarding business gratuities which may be accepted by U.S. government personnel. The promise, offer or delivery to an official or Employee of the U.S. government of a gift, favor or other gratuity in violation of these rules would not only violate Resource policy but could also be a criminal offense. State and local governments, as well as foreign governments, may have similar rules. Resource’s counsel can provide guidance to you in this area. In addition, the U.S. Foreign Corrupt Practices Act prohibits giving anything of value, directly or indirectly, to officials of foreign governments or foreign political candidates in order to obtain or retain business. It is strictly prohibited to make illegal payments to government officials of any country.
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