Lakeside Imagers

Code of Ethics and Business Conduct

We are committed to the highest ethical standards. We expect our employees to act ethically and honestly in all dealings with all of our stakeholders, including, but not limited to shareholders, customers, families, employees, communities, vendors and suppliers, government entities, and competitors.

Legal Issues

Employees must know and obey all laws, including but not limited to antitrust laws and regulations.

Employees will follow all company and legal requirements with regard to document retention, recording and reporting information, and records management. You must report and record all information accurately and honestly at all times. Failure to follow these regulations can have legal and tax implications for the company and for the employee.

Environment

We are committed to providing a safe and healthy work environment for all of our employees. We will not tolerate any form of harassment, either verbal or physical. We are committed to protecting the natural environment and will be good stewards of the resources we use.

Conflict of Interests

Employees should avoid situations in which there is a conflict between their personal lives and the interests of this company. If you're in doubt as to whether some action might violate this statement, you are encouraged to write a disclosure of any such activity and seek management approval before engaging in that activity.

Entertainment

Employees are allowed to build goodwill with customers and potential customers through the use of business gifts and entertainment. However, these should not viewed by others as extravagant, should not be used to unduly influence their decisions, should never be illegal, should never be a bribe or kickback, and should never be such that it would embarrass the company if the facts are disclosed.

Gifts

Employees should not seek or accept gifts or entertainment from a vendor or supplier without a true business purpose. However, an employee can accept small gifts or favors, with a market value of less than $25, from any supplier or vendor, as long as accepting said gift will not unduly influence the employee's decisions. Employees can never accept a cash gift or cash-equivalent gift card, however. Employees can never accept any fee or commission for referring customers to third party vendors.

Employees can not seek or accept any personal loan (except from conventional loans at stated rates of interest from established lending firms) from any supplier or vendor.

Employees shall not accept any gift, favor, or entertainment from any competitor.

Employees should not seek donations from suppliers or contractors to fund any social functions or company events.

Honesty

We never misrepresent our company or our products. Where silence could be misleading, it is the employee's responsibility to disclose significant information.

You are expected to be honest in all statements to anyone. If you believe someone has misunderstood you, it is your responsibility to correct that misunderstanding at once.

Competition

Employees can gather legitimate competitive intelligence but must do so in an ethical and legal manner. It is okay to ask customers to provide us with a competitor's proposal, but we will never encourage a customer to violate an agreement of nondisclosure.

Employees should not share information from their former employees if that information is considered proprietary.

Employees can never assist a competitor in any way, including serving as an employee, consultant, or as a member of the competitor's board of directors.

Privacy

We will maintain the privacy of our customers and not share information with anyone else without proper authorization and for legitimate business reasons connected with our firm.

Company Assets

Employees will protect any company assets (including intellectual property) from theft, loss, and misuse. Company assets can never be used for the employee's personal benefit and can not be sold or given away without proper written authorization.

Contributions

Employees will not make any contribution of company funds or services to any political party or candidate without the written approval of corporate headquarters.

Leaving Company

If you leave the company for any reason, including retirement, you must return all company property and you can not disclose or use any company information. Also, anything you created (e.g., software, processes, products) while you worked for our company remains the property of our company.

You are encouraged to report any violations of this code to Mary Parkhurst, Senior Vice President of Compliance.

Lakeside Imagers

Legal Issues in Selling

There are many legal issues that salespeople must be aware of. The following is a partial list of such issues. There is some overlap in the issues provided.

Antitrust laws in the U.S. require fair competition. It is against the law to work with a competitor to fix prices, or to divide customers, territories or markets. Indications that such activity is occurring has been found to include discussing with competitors pricing, terms and conditions of sale, marketing plans, costs of production, and so forth.

Interfering with any contract between a competitor and a customer of the competitor.

Gathering competitive intelligence using theft, black market purchases, blackmail, threats, eavesdropping using electronic means, illegal entry, and so forth.

Using inside information for trading, or tipping others to trade. Inside information can include many aspects including but not limited to financial forecasts or earnings, information about the loss of a significant customer, information about acquiring a new large customer, planned mergers or acquisitions, changes in management that are planned but have not been announced, information about new products or inventions that have not been announced, and so forth.

Participating in an international boycott that the U.S. government does not sanction.

The export of products to specific countries and entities that are restricted by U.S. law.

Failure to follow economic sanction regulations that apply to doing business with certain countries or entities.

Misrepresentation of information (lying, not providing full disclosure to buyers for potentially dangerous products like prescription drugs).

Defaming a competitor (making unfair or untrue statements).

Forcing a buyer to engage in reciprocity.

Forcing a buyer to accept a tying agreement (buy one product but only if you buy another one also).

Interfering with competitors (tampering with products, confusing a competitor's market research, stealing from them at a trade show).

Forcing resale price maintenance.

Unjustified price discrimination.

Violating privacy laws (giving information about a customer to someone else).

Violating do-not-call laws.

Subordination (paying bribes to officials).

Mishandling of funds or compensation (e.g., real estate salesperson unlawfully paying compensation, mishandling trust funds).

Fraud in a licensed capacity (e.g., acting as a security dealer without proper endorsements).

Failure to follow specific industry laws or regulations (e.g., not filing proper reports or disclosure statements for real estate salespeople, not having doctors sign for samples of prescription drugs).

Failure to disclose income.

Restraint of trade (forcing a customer to stop carrying a competitor's product).

Shipping unordered goods or shipping larger quantities than customers ordered.

Substituting goods from those ordered or failing to fill an order within a reasonable time.

Using spiffs (commissions or payments to customer's salespeople) without the customer's knowledge.

Pressuring someone to buy something through coercion or intimidation.

Giving gifts or money to an official or an employee of a governmental entity if doing so could be reasonably construed as having a connection with your company.