Ethics/Code Of Conduct

Effective Date: June 2, 2005

Policy

At Phoenix Energy Marketing, all employees will conduct themselves with honesty and
integrity, striving to provide all clients with the best service possible. Phoenix is dedicated to maintaining its reputation for excellence within the industry. All employees are encouraged to make decisions that are within the scope of their responsibility and authority, while working together with a sense of urgency to accomplish all goals.

General Principals and Standards

• All employees are to conduct themselves at all times with decorum, honesty, integrity, andin accordance with the highest ethical standards.

• In all aspects of their conduct, employees should conduct themselves in a manner that will reflect positively on Phoenix and on themselves.

• Everyone is to be treated fairly and with mutual respect.

• Except for receipt of Phoenix compensation and benefits, a position of employment with Phoenix is not to be used in any way that will result in the personal benefit of an employee or any other person.

• Conflicts of interest are to be avoided.

• Given the fact that the type of service provided by Phoenix is such that employees must remain impartial between business associates, including clients, employees MUST NOT receive inappropriate gifts from any business associates. If a client offers a gift, it must be discussed with a supervisor, the Human Resources department manager or an officer of Phoenix prior to acceptance any such gift. (Exceptions include: ordinary and customary tokens of nominal value, participation in a business lunch or other meal paid for by another party on an appropriate occasion and under appropriate circumstances or inclusion in entertainment for a group of persons where the presence of the employee is
  clearly appropriate and consistent with the Company's objectives.) Any inappropriate behaviour that may be construed as receiving bribes, gives the appearance of impropriety or is otherwise inappropriate will result in termination of employment.

• Unethical behaviour or the appearance of unethical behaviour will not be tolerated. This includes, but is not limited to:

  • Harassment of any form (e.g., sexual, physical, verbal)

  • Illegal activities

  • Substance abuse

  • Unauthorized use of Phoenix resources, including business relationships

  • Disclosure of confidential information

  • Disclosure of personal information

  • Disclosure of personal employee information

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