Code of Conduct
The Code of Conduct outlines expected behaviors for all NPCC employees. NPCC will conduct its business fairly in an ethical and proper manner, and in full compliance with all applicable laws and regulations. In conducting its business, integrity must underlie all NPCC relationships, including those with clients, business partners, shareholders, competitors, communities, governments and among employees. The highest standards of ethical business conduct are required of NPCC employees in the performance of their company responsibilities. Employees must not engage in conduct or activity that may raise questions as to the company's honesty, reputation or otherwise cause embarrassment to the Company.
Employees will ensure that:
- They do not engage in any activity that may create a conflict of interest for the company or for themselves individually of interest for the company or for themselves individually.
- They do not take advantage of their NPCC position to seek personal gain through the inappropriate use of NPCC or non-public information or abuse of their position. This includes not engaging in insider trading
- They will follow all restrictions on use and disclosure of information. This includes following all requirements for protecting NPCC information and ensuring that non-NPCC proprietary information is used and disclosed only as authorized by the owner of the information or as otherwise permitted by law.
- They observe that fair dealing is the foundation for all of NPCC transactions and interactions.
- They will protect all NPCC, customer, subcontractors and vendors assets and use them only for appropriate approved activities.
- Without exception, they will comply with all applicable laws, rules and regulations.
- They will promptly report any illegal or unethical conduct to Legal Advisor and/or Chief Audit Executive.
Every employee has the responsibility to ask questions, seek guidance and report suspected violations of this Code of Business Conduct. Retaliation against employees who come forward to raise genuine concerns will not be tolerated.
AQEEL A. MADHI
APRIL 30, 2007