Organization Conflict of Interest

ETHICS POLICY

PURPOSE
To ensure the highest standards of ethical conduct are being met while performing company responsibilities as defined
in the Company’s Code of Conduct (Exhibit D). 

POLICY

All JMWA employees will conduct business in a fair, impartial, ethical and proper manner in accordance with the
Company’s Code of Conduct and in full compliance with all laws and regulations.  Integrity must underlie all
company relationships, including those with clients, community, and among employees.  Violations may result in
disciplinary actions, up to and including termination.

Employees should ask questions, seek guidance, or report suspected ethics violations to their JMWA supervisor or the
Director of Human Resources.  Retaliation against employees who come forward to raise concerns will not be
tolerated.  

RESPONSIBILITY
It is the Employee’s responsibility to:

Understand the company’s values and the business ethics program as described in the Company’s Code of
Conduct
Act with integrity and follow the guidelines set forth in the Code of Conduct
Ask questions or seek guidance when a questionable situation arises
Report any illegal or unethical conduct to JMWA supervisor or the Human Resources Department
Sign Acknowledgement of the Company’s Code of Conduct

It is the Supervisor’s responsibility to:

Implement programs which support company-wide ethics and business conduct

Monitor compliance with the company’s values and ethical business conduct guidelines as described in the
Company’s Code of Conduct
Create an open and honest environment in which employees feel comfortable bringing issues forward
Take appropriate and timely corrective action for conduct in violation of the ethics and business conduct
program

It is the Human Resources Department responsibility to:

Distribute the Code of Conduct Policy and maintain the signed acknowledgement form in the employee’s
personnel file
Develop an initial and refresher training syllabus
Provide ethics and business conduct training to employees
Track and notify employees and supervisors when ethics training needs to be conducted

PROCEDURE
All employees will be given a copy of the Code of Conduct.  Upon employment, new hires will receive the Code of
Conduct and training for complying with the Company’s ethics program by his/her JMWA supervisor.  All employees
will be required to participate in annual refresher training conducted by their JMWA supervisor or Human Resources. 
The trainer will issue certificates of completion at the end of each training to be kept in the employee’s file.

The Human Resources Department will develop a training syllabus and will monitor when employees need to
participate in annual refresher training.

If the employee has any questions, needs to seek guidance on an issue, or report suspected violation of the Code of

file:///C|/Documents%20and%20Settings/kkennon/Desktop/JMWA%20Ethics%20Policy.htm[10/5/2009 3:10:09 PM]

Organization Conflict of Interest

Conduct, the employee should contact the JMWA supervisor.  If the employee is not comfortable discussing the matter
with the supervisor, they should contact the Human Resources Department or any of the Corporate Officers. 
 

POC: Human Resources Department

file:///C|/Documents%20and%20Settings/kkennon/Desktop/JMWA%20Ethics%20Policy.htm[10/5/2009 3:10:09 PM]