LHM Code of Conduct | Page 28

22 Section 6 : Our Relationship with Government / Law

Section 6 : Our Relationship with Government / Law

We obey all laws that apply to the Company . It is our policy to go beyond the letter of the law and to comply with its spirit . Always consult with the Company ’ s Legal Department whenever you are in doubt . It ’ s always better to be safe than sorry .
We comply with all applicable laws .
The Company is committed to full compliance with applicable laws , rules , and regulations . We never knowingly or intentionally violate this commitment . When you think a conflict exists between the way we conduct business and any applicable law , rule , or regulation , or if you have a question concerning the legality of your conduct or another employee ’ s conduct , you should consult with your Legal Department .
We comply with anti-bribery laws .
We have zero tolerance regarding bribery and corruption in all forms , as this is contrary to our values and business standards . The rule is simple — don ’ t bribe or accept a bribe from anyone , anytime , for any reason .
You should be careful when giving gifts and paying for meals , entertainment , or other business courtesies on behalf of the Company . We want to avoid the possibility that the gift , entertainment , or business courtesy could be perceived as a bribe , so it ’ s always best to provide such business courtesies infrequently and , when we do , to keep their value moderate .
There are additional considerations when entertaining or providing gifts to government employees and elected officials . Please consult with Larry H . Miller Management Corporation ’ s Chief Government Relations Officer for specific information .
If you think a conflict exists between the way we conduct business and any applicable law , rule , or regulation , or if you have a question concerning the legality of your conduct or another employee ’ s conduct , consult with your Legal Department .