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Food Export Association of the Midwest USA
Accounting and Auditing Matters The unethical systematic recording and analysis of the business and financial transactions associated with generally accepted accounting practices. (Examples include: misstatement of revenues, misstatement of expenses, misstatement of assets, misapplications of GAAP principles, wrongful transactions.)
Conflict of Interest A conflict of interest is defined as a situation in which a person, such as a public official, an employee, or a professional, has a private or personal interest sufficient to appear to influence the objective exercise of his or her official duties. (Examples include: inappropriate vendor relations, bribery, misuse of confidential information, inappropriate customer relations)
Disclosure of Confidential Information Unauthorized and unlawful disclosure of corporately owned intellectual property or trade secrets, as well as employee, customer or consumer information, marketing and other corporate data bases, marketing plans, business proposals and strategies.
Discrimination or Harassment Food Export - Midwest & Food Export - Northeast prohibit discrimination on the basis of age, disability, national origin or ancestry, race, color, religion, creed, gender, sexual orientation, marital status, political affiliation, military status or membership in the military reserve or other protected status.
Falsification of Contracts, Reports or Records Falsification of records consists of altering, fabricating, falsifying, or forging all or any part of a document, contract or record for the purpose of gaining an advantage, or misrepresenting the value of the document, contract or record.
Fraud/Embezzlement The taking or obtaining by deception, of money or any other benefit from - when not entitled to the benefit or the attempt to do so; the intentional misrepresentation of financial position; the intentional misrepresentation of information leading to financial loss.
Gifts and Entertainment Refers to the inappropriate offering, solicitation or accepting of items of more than nominal value from vendors, customers or other third parties in a capacity as an employee of the Company.
Illegal Payments to US and Non-US Government Personnel The unlawful payment or benefit to any local, state or federal governmental official or employee or any other person, either in the US or in another county, if such payment or benefit is either prohibited by law or was made with the intent to influence or affect official action. (Examples include, but are not limited to, giving or promising to give money or any item, service, entertainment, meal, gift or transportation of value to a governmental official if prohibited by law or if the intent is to influence specific, official acts.)
Improper Supplier or Contractor Activity Supplier or contractor activity in violation of corporate policies and procedures; improper supplier or contractor selection based on personal gain, improper negotiation or diversion of contract awards.
Misconduct or Inappropriate Behavior Intentional wrongdoing; specifically: deliberate violation of a law or standard.
Perishable Agricultural Commodities Act (“PACA”) Concerns regarding compliance with provisions of the Perishable Agricultural Commodities Act (“PACA”), a United States federal statute that, along with comparable state laws, prohibits unfair, fraudulent or unethical business practices in connection with the importation, purchase or sale of perishable agricultural commodities in interstate and foreign commerce. (Examples: false or misleading statements in connection with any purchase, sale, consignment or other transaction involving perishable agricultural commodities; providing an accounting of sale or any other documents that do not truly and accurately reflect the details of the transaction; altering, forging or counterfeiting any inspection certificate issued under authority of the United States Department of Agriculture.)
Theft The act of stealing; specifically: the felonious taking and removing of personal property with intent to deprive the rightful owner of it.
Time Abuse Concerns about an employee or manager who is falsifying his/her work hours.
Unfair Trade Practices, Deception and Fraud Includes practices such as misrepresenting, creating misleading impressions, omitting important facts or making false claims about the Company's or its competitors' product or service offerings, as well as bribery and other similar exploitive or inequitable conduct.
Violation of Policy Willful or innocent actions that are in direct violation of company policy, procedures, code of conduct, and/or implied contractual responsibilities. (Examples include: non- disclosure agreements, hiring standards, safety, Internet usage, corporate guidelines)
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