CODE OF ETHICS

SRS Card, Inc.

 
This Code of Ethics sets out the minimum ethical standards for all Directors, Officers and employees of SRS Card, Inc. SRS Card is committed to enforcing these standards through effective internal systems reporting structures and SRS Card’s Always Honest Compliance Program. Violators will be subject to disciplinary action.


SRS Card’s Directors, Officers and Employees, in conducting the business of the company, will:

 

  1. Obey the law, including all applicable rules and regulations, and conduct themselves with honesty and integrity.
  3. Avoid engaging in any conduct where their personal interests interfere or appear to interfere with those of SRS Card.
  5. Advance the legitimate interests of SRS Card when the opportunity arises and avoid competing with SRS Card directly or indirectly or using SRS Card property, information, or their positions with SRS Card for improper personal gain.
  7. Respect the rights of and deal fairly with SRS Card’s customers, suppliers, competitors and employees.
  9. Not offer or accept bribes or kickbacks either directly or indirectly.
  11. Report to work in condition to perform their duties, free from the influence of alcohol or illegal drugs.
  13. Keep honest and accurate records and reports of company information.
  15. Make full, fair, accurate, timely and understandable disclosures in reports and documents that SRS Card provides to any Governmental authority and in all other public communications made by SRS Card.
  17. Respect the diversity of SRS Card’s employees and not engage in wrongful discrimination or harassment.
  19. Preserve the confidentiality of non-public company information and any other information entrusted to them in confidence by SRS Card or its customers, except when disclosure is authorized or is legally mandated.
  21. Not use or share confidential information for any purpose except to conduct SRS Card’s business.
  23. Protect SRS Card's assets and ensure their proper and efficient use, including property, equipment, products and other tangible assets, and proprietary information such as trade secrets, patents, trademarks, and copyrights, as well as business, marketing and service plans, engineering and manufacturing ideas, designs, databases, records, salary information and any unpublished financial data and reports.
  25. Maintain a safe and healthy workplace for all employees by following safety and healthy rules and practices and reporting accidents, injuries and unsafe equipment, practices or conditions.
  27. Promptly report concerns regarding accounting, auditing and internal controls matters on a confidential basis to the Chairman of the Board of Directors. Such reports will be investigated by SRS Card under the direction of the Board of Directors.
  29. Promptly report work-related activities by company personnel that violate the law, this Code and any other company policy. Reports of violations may be made to a Supervisor, the Compliance Officer, an Executive Officer of SRS
  30. Card or the Legal Department. Reports of violations by Executive Officers or senior financial personnel must be made to the Chairman of the Board of Directors.
  32. SRS Card does not permit retaliation of any kind for reports of misconduct made in good faith. If you have questions about this Code, SRS Card’s Compliance Programs or whether conduct may violate this Code, the law or a Compliance Program, you should consult with a Supervisor, the Compliance Officer, an Executive Officer of SRS Card, or the Legal Department.
  34. Waivers of this Code may be made only upon written request submitted to and approved by SRS Card’s Board of Directors. Changes in or waivers of the Code will be promptly disclosed as required by applicable law or regulation.