CORMETECH's Code of Business Conduct

CORMETECH, Inc. has the expectation that all officers, managers, and employees will follow the guidelines outlined in this policy as they relate to integrity, competitive interactions, and business conduct.


A. Conflicts of Interest

The following section describes activities that would be detrimental to CORMETECH and as a result, should be avoided:

1. Employees shall not be involved in any activity, including personal investment, which competes or is in conflict with or gives the appearance of conflict of interest with the business of CORMETECH, Inc. or our shareholders. Outside business interests require the prior approval of CORMETECH, Inc.
2. No employee shall be employed or have a direct or indirect significant financial interest in any company, other than its shareholders, which is engaged in the same or similar line of business as CORMETECH, Inc. Significant financial interest is one which is so substantial as to create a potential risk of interference of an individual's exercise of independent judgment in the best interest of the company.
3. No employee shall accept or request directly or indirectly any article of value from anyone connected with a company with which CORMETECH, Inc. is negotiating, contracting, or dealing with if the item in question may influence the individual in negotiating or dealing with their company. All employees are to advise their manager of any gifts received in respect of employment of CORMETECH.
4. No employee shall directly or indirectly give a gift or favor or engage in the entertainment of any person, firm, or nonaffiliated corporation negotiating, contracting or in any way dealing with CORMETECH, Inc. or likely to negotiate, contract or deal with CORMETECH, Inc., except as may be consistent with generally acceptable ethical standards and accepted business practices and not in violation of any applicable law.
5. No employee shall receive, in addition to a regular salary, fees or other compensation as fixed by CORMETECH, Inc., any money or thing of value, directly or indirectly, or through any substantial interest in any non-affiliated business of any sort, or through any personal relationship, for negotiating, procuring, recommending or aiding in any purchase, sale, or rental of property or any loan made by or to CORMETECH, Inc.
6. No employee of CORMETECH, Inc. shall, without proper authority, give or release to anyone not employed by CORMETECH, Inc. or its shareholder corporations, or to another employee who has no need for the information, data or proprietary information of a confidential nature concerning Cometech, Inc.


B. Business Conduct
This section details CORMETECH, Inc.'s performance expectation for employee business conduct:
1. Employees dealing with contractors, vendors, suppliers, consultants, customers, and other persons having business with CORMETECH, Inc. shall conduct such activities in the best interests of CORMETECH, Inc. without favor or preference.
2. No cash payments may be made to customers in the United States. No payments may be made outside the United States to secure preferential action. Expediting payments to secure the timely and correct completion of routine government action (e.g., processing visas, permits to do business) is permitted outside the United States only when lawful, and then only if it is unavoidable and made to facilitate the correct performance of a government representative's routine duties.
3. Other gifts and entertainment provided to governmental and commercial customers are limited to $25 in value. Exceptions to this rule include entertainment which is considered a routine part of conducting normal business interactions.
4. No political contribution shall be made by or on behalf of CORMETECH, Inc. or its shareholders to any political party, committee, officeholder or candidate for any public office within the United States or to any candidate or government official outside the United States which violates applicable laws. Employees are encouraged to engage in lawful political activity as they consider appropriate.
5. Employees in subordinate/supervisory relationships are not to exchange favors or gifts which could or appear to give rise to any obligation.
6. Employees are required to follow the provisions of the U.S. Foreign Corrupt Practices Act.