Business Conduct and Ethics

Kotn is a company that values ethical business practices. We’ve put together these policies, which apply to everyone at Kotn to ensure that we’re all operating with fairness and integrity.

CONFLICTS OF INTEREST

When you are in a situation in which competing loyalties could cause you to pursue a personal benefit for you, your friends or your family at the expense of Kotn, you may be faced with a conflict of interest.

Areas where conflicts of interest often arise:

  • Personal investments

  • Outside employment, advisory roles, board seats, and starting your own business

  • Business opportunities found through work

  • Inventions

  • Friends and relatives; co-worker relationships

  • Accepting gifts, entertainment and other business courtesies

Conflicts of interest are not always clear cut. To help determine whether you are faced with a potential conflict of interest, you must consult your supervisor and/or ask yourself:

  • Could this activity create an incentive for me, or be perceived by others to create an incentive for me, to benefit myself, my friends or my family, or an associated business at the expense of Kotn?

  • Could this activity negatively impact my ability to do my job at Kotn, or potentially harm Kotn or its reputation?

  • Could this activity negatively impact Kotn if it showed up on the front page of a newspaper or a blog?

If the answer to any of these questions is “yes,” the relationship or situation is likely to create a conflict of interest, and you must avoid it.

In each of these situations, the rule is the same. If you are considering entering into a situation that creates a conflict of interest, don’t. If you are in a situation that may create a conflict of interest, or the appearance of a conflict of interest, review the situation with management immediately. Finally, it’s important to understand that as circumstances change, a situation that previously didn’t present a conflict of interest may in time present one.

GRATUITY AND ENTERTAINMENT

Offering or receiving any gratuity or entertainment that might be perceived to unfairly influence a business relationship should be avoided.


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