Fraud and Theft

The Company encourages you to think like an owner—making decisions that reflect accountability, stewardship, and long-term value. This mindset extends to how the Company uses its resources, including financial assets.

You must treat Company funds with the same care and consideration you would apply to your own, ensuring every expense, including travel, is necessary, reasonable, and aligned with the Company’s business objectives. It is critical to ensure Company funds are used responsibly and solely for legitimate business purposes that support the Company’s objectives. In addition, you must ensure external expenditures of any Company funds—such as providing financial and product support to organizations and causes or supporting the Company’s position in the political process—are appropriately approved according to our internal guidelines. Responsible use of resources helps the Company maintain trust, operate efficiently, and invest in what matters most.

In addition, the Company is committed to maintaining a culture of integrity, accountability, and trust. Fraud and theft are serious violations of our values and policies. The Company has zero tolerance for any form of dishonest or unlawful behavior, including misappropriation of assets, falsification of records, and misuse of Company resources.

The Company actively works to prevent, detect, and respond to fraud and theft through strong internal controls, training, and clear reporting mechanisms. You play a role in safeguarding our organization, and the Company expects all of us and Covered Parties to uphold the highest standards of ethical conduct. By acting with integrity and ownership, the Company strengthens its culture and contributes to the sustainable success of the organization.