Exhibit - 14
PUBLIC STORAGE, INC.
CODE OF ETHICS FOR SENIOR FINANCIAL OFFICERS
1. Scope and Purpose
This Code of Ethics for Senior Financial Officers applies to the
Company's principal executive officer, principal financial officer, and
principal accounting officer or controller, or persons performing similar
functions (each a "Senior Financial Officer"). This Code is designed to promote
(1) honest and ethical conduct, (2) avoidance of conflicts of interests, (3)
full, fair, accurate, timely and understandable disclosure and (4) compliance
with applicable governmental laws, rules and regulations. Each Senior Financial
Officer must conduct himself or herself in accordance with this Code and must
seek to avoid even the appearance of improper behavior. Senior Financial
Officers should also refer to and abide by the Company's Standards of Business
Conduct, which are in addition to this Code. 2. Honest and Ethical Conduct
2. Honest and Ethical Conduct
Each Senior Financial Officer must always conduct him/herself in an
honest and ethical manner. Each Senior Financial Officer must act with the
highest standards of personal and professional integrity and not tolerate others
who, attempt to deceive, or evade responsibility for actions. All actual or
apparent conflicts of interest between personal and professional relationships
must be handled honestly, ethically and in accordance with the policies
specified in this Code. 3. Compliance with Laws, Rules and Regulations
3. Compliance with Laws, Rules and Regulations
Compliance with applicable governmental laws, rules and regulations,
both in letter and in spirit, is one of the foundations on which this Company's
ethical policies are built. Each Senior Financial Officer must understand and
take responsibility for complying with the governmental laws, rules and
regulations of the cities, states and countries in which the Company operates.
For example, it is critical that Senior Financial Officers understand the
governmental laws, rules and regulations applicable to disclosures the Company
is required to make in its periodic reports and otherwise. Although a Senior
Financial Officer may not know the details of all these laws, rules and
regulations, it is important that he or she know enough to determine when to
seek advice from the general counsel or other appropriate personnel. 4. Rules to
Promote Full, Fair, Accurate, Timely and Understandable Disclosure
4. Rules to Promote Full, Fair, Accurate, timely and Understandable
Disclosure
Each Senior Financial Officer must take the following steps to ensure
full, fair, accurate, timely and understandable disclosure in reports and
documents that the Company files with the Securities and Exchange Commission and
in other public communications made by the Company:
1. Carefully review drafts of reports and documents the Company is
required to file with the SEC before they are filed and Company
press releases or other public communications before they are
released to the public, with particular focus on disclosures each
Senior Financial Officer does not understand or agree with and on
information known to the officer that is not reflected in the
report, document, press release or public communication.
Exhibit 14
2. Meet with the disclosure committee, members of senior management not
on the committee, division heads, accounting staff and others
involved in the disclosure process to discuss their comments on the
draft report, document, press release or public communication.
3. Establish and maintain disclosure controls and procedures that
ensure that material information is included in each report,
document, press release or public communication in a timely fashion.
4. Consult with the Audit Committee of the Company's Board of Directors
on a regular basis to determine whether they have identified any
weaknesses or concerns with respect to internal controls.
5. When relevant, confirm that neither the Company's internal auditors
nor its outside accountants are aware of any material misstatements
or omissions in the draft report or document, or have any concerns
about the management's discussion and analysis section of a report.
6. Bring to the attention of the disclosure committee and/or Audit
Committee matters that the Senior Financial Officer feels could
compromise the integrity of the Company's financial reports.
7. Always act with the highest standards of personal and professional
integrity; do not tolerate others who attempt to deceive, or to
evade responsibility for their actions.
5. Reporting Violations of the Code
Any Senior Financial Officer who becomes aware of any violation of the
Code must promptly bring the violation to the attention of the Audit Committee
of the Board of Directors.
6. Compliance with the Code
Each Senior Financial Officer will be held accountable for adherence to
this Code. A violator of this Code will be subject to disciplinary action, up to
and including a discharge from the Company and, where appropriate, civil
liability and criminal prosecution.
7. Waiver of the Code
Any waiver of this Code may be made only by the independent directors
on the Board of Directors or by an authorized committee of the Board of
Directors comprised solely of independent directors, and will be disclosed as
required by law or SEC regulations.
8. Acknowledgement
Senior Financial Officers are required to sign a form acknowledging
that they have received, read, and agree to comply with the Code of Ethics for
Senior Financial Officers.
[As adopted by the Board of Directors of Public Storage, Inc.]
Exhibit 14