Conflict of Interest
Every employee shall avoid situations where private interest interferes in any way with the Company’s interests and disclose the facts to his/her assigned manager.
The Company recognizes that business entertainment and gifts are meant to create goodwill and sound working relationships, not to gain unfair advantage with customers or suppliers. Employees will not offer, give, or accept a cash gift under any circumstances. Employees and their family members may offer, give or accept a non-cash or in-kind gift or entertainment if it is:
- Consistent with customary business practices
- Is not excessive in value (operating company president and controller will make this determination consulting with FCTG management as required)
- Does not violate any laws, rules or regulations.
No gifts of any value shall be given to:
- A foreign government or political party
- An officer or employee of a foreign government, department or agency
- A public international organization
- Any company that is owned or controlled, in whole or in part, by a foreign government
Control and Use of Assets
- Theft, carelessness and waste of Company assets should be avoided.
- The Company’s property may not be used for personal benefit or other improper purposes.
- Employees are responsible for Company property and funds over which they have control.
- The E-Mail system is owned and controlled by the Company and its use shall be limited to those employees who have obtained the employer’s express authorization. In no event shall the E-mail system be used for uses prohibited by law, such as pornography.
Directors, officers, and employees are prohibited from personally competing with the Company directly or indirectly.
Reporting of Potentially Dangerous Conditions
- The Company does not permit violence or threatening behavior in its workplace.
- All employees must report to work free from alcohol or illegal drugs.
- Illegal drugs in the workplace are prohibited.
Discrimination and Harassment
The Company provides equal opportunity in all aspects of employment and does not tolerate unlawful discrimination or harassment of any kind. Derogatory comments based on racial or ethnic characteristics, unwelcome sexual advances and similar behavior are prohibited.
The Company via its employees must:
- Make full, fair, accurate, timely and understandable disclosure in reports, filings and information provided to public accounting firms and to the Company’s internal auditors
- Make and keep books, records, and accounts that accurately, fairly, and in accordance with GAAP accounting requirements reflect our transactions
- Maintain internal accounting controls that meet or exceed legal requirements
- Maintain correct and complete tax records
- Submit correct and complete tax reports to all appropriate taxing authorities
- Comply with all other applicable laws, rules, and regulations.
Violation of Code or Law
- If an employee reasonably believes that the Company’s policies as set forth in this Code, or any law, rule or regulation, is being violated, the employee should immediately notify his/her manager or the Vice President of Human Resources of Forest City Trading Group, LLC.
- Employees should bring to the Company’s attention any questionable accounting or auditing matters.
- The Company will not retaliate against an officer, director or employee who in good faith reports any existing or potential violation of any law, rule, or regulation or of this Code.