LHM Code of Conduct | Page 12

6 Section 1 : Our Expectations and Values and Guiding Principles
We know the Code applies to all of us .
The Company ’ s reputation for acting ethically and responsibly is built one decision at a time , every day , by each of us . Every employee is expected to uphold the Code of Conduct . It is your responsibility to know and comply with the policies that apply to the work you do and the decisions you make . The Code cannot cover every possible situation , but it should be considered as a foundational tool for when you have questions or face dilemmas where the right choice is not clear .
Responsibilities as Employees Responsibilities as Leaders
Every employee has the responsibility to :
• Always act in accordance with applicable laws , this Code , and any Company policies , procedures , guidelines , and work rules
• Avoid any activity that might be illegal or unethical
• Seek a full understanding of compliance requirements , risks , and key controls that apply to your role . No one is expected to know every policy word for word , but you should understand the policies that apply to your role
• When you have questions , seek assistance from the many resources that are available to you . ( Refer to Section 9 in this Code of Conduct for a list of resources )
• Promptly report potential or actual violations of the law , any Company policy , or the Code , as well as any request by another to violate a law , or any Company policy , or the Code
• Promptly report any issue that you believe has not been appropriately resolved , even if it means raising it with another available resource
• Cooperate completely and honestly with the Company investigators
In addition to their responsibilities as employees , Leaders have a responsibility to lead by example . Leaders must be positive role models to inspire others to follow Company Policy , the Code , and to conduct business according to the highest standards of ethical and professional behavior .
Leaders have additional responsibilities to :
• Lead by example and behave as a model for all employees
• Provide education and tools that promote employee understanding and compliance
• Create an ethical culture that promotes compliance , encourages employees to raise their questions and concerns , and prohibits retaliation
• Promptly address employee concerns of wrongdoing
• Recognize and reward employees who adhere to and promote legal , compliant , and ethical behavior
Retaliation , retribution , or harassment against any employee who , in good faith , asks any question or raises any concern regarding unethical behavior or compliance responsibilities is against the Company policy and is prohibited .