Inventory Management

Protecting Company Assets

Keys to Compliance By efficiently using our assets for business related purposes, we can deliver our products and services with responsible pricing. Both tangible and intangible assets have been acquired through the hard work and investment of many stakeholders. We need to protect our assets and ensure their efficient and proper use.

Don't appropriate, borrow or loan Company property without permission Misappropriating our property or converting it to personal use for yourself or another is regarded as outright theft and can result in termination. Employees are prohibited from taking for themselves, personally, opportunities that are discovered through the use of the Company's property or information. An employee's paid working time is also a Company asset which should not be put to personal use without proper authorization.

Follow all security regulations Rules pertaining to security of facilities, material, information, and equipment may sometimes seem burdensome, but they are necessary.. Do not fail to secure sensitive information or easily transportable tools and equipment when you are done with them. Do not neglect fire and other safety precautions.

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Use of Technology Resources

Keys to

Question: I have received an offensive e-mail message. What should I do? Answer: Ask the sender to stop transmitting offensive e-mails to you and advise the Human Resource Manager and your Department Manager. If the sender is an Insurance Services employee and he or she persists in sending offensive material, you should promptly report this to your manager, or to Human Resources. If sender is from outside PSBA, contact the IT Department so that future message from this source can be blocked. Government Relations and Political Activities

Keys to Compliance Employees must conduct themselves in a manner to avoid any dealing that might be perceived as an attempt to inappropriately influence a public official in the performance of his or her official duties.

Federal and state government officials may rely upon the accuracy of verbal and written statements made by Insurance Services and its employees. It is a violation of the law for any employee to knowingly make a false and misleading statement to a government official or auditor. In every instance, we need to provide accurate and complete statements to the government.

Know and obey the law We must understand all applicable laws and regulations including, without limitation, employment, discrimination, and insurance laws. We need to follow the law, both in letter and in spirit.

Don't use Company money for political contribution Under federal and most state statutes, it is unlawful and prohibited for Insurance Services or any employee to use Company funds to make any direct or indirect contributions (financial or in-kind) to parties, candidates, or lawful Political Action Committees.

Keep personal political activities separate from Company's business Seeking or holding any public office may give rise to situations where an employee's obligation to the community and obligation to the Company may conflict. In such situations, employees should avoid participating in decisions, whether as Company employees or public officeholders, which present such conflicts.

Question: I strongly support a candidate for office in the upcoming election. May I hand out campaign literature on the job? Answer: No. Distribution of such materials during work time or in work areas is an unacceptable use of company property and time and could create the mistaken impression that Insurance Services is endorsing a particular candidate.

Question: May I make personal political contributions? Answer: Yes. Personal political contributions are not prohibited. This is a matter of personal choice.

< back next >Ethics Compliance

Keys to Compliance Management has an important and elevated role in corporate governance. In this capacity, such persons have been empowered to ensure that stakeholders' interests are appropriately balanced, protected and preserved. It is their responsibility to not only communicate and train employees in the ethical values and requirements outlined in this Code, but to lead by example.

In this regard, employees have parallel responsibilities to act in compliance with this Code, to maintain high business ethics standards, and to propagate a work environment of trust and respect, of which employees and stakeholders can be proud.

Report ethics and business integrity violations Employees are obligated to report known or suspected ethics or business integrity violations. Reports may be made to your immediate supervisor. This is the typical reporting avenue, but if you do not feel it is comfortable or appropriate in a given situation, a report may be made to a higher level in the departments' management structure. Reports can also be made to:

■President of SBIC

■Human Resources

The identity of those reporting suspected violations will be kept confidential to the maximum extent possible, though the release of certain limited information may be required to serve the purposes of this Code. There will be no retaliation against any employee for reporting a suspected violation. Additionally, you may use our 3 rd Party Fraud Hot Line to report any suspected business integrity or fraud allegations anonymously. The toll free number is 1-800-670-3523 or through the internet at https://www.compliance-helpline.com/SBICofPA.jsp .

Cooperate with Code of Business Ethics and Conduct investigations and auditors

Employees have a duty to cooperate fully with ethics investigations and audits. You should answer questions posed by investigators or auditors truthfully and to the best of your ability. Depending on the matter being audited or investigated, those assigned to the task may include personnel with the requisite skills or experience, such as Human Resources, Management, or other outside personnel.

Where an audit or investigation reveals the need to take corrective measures, employees have an obligation to cooperate in implementing changes in systems, practices, or procedures to avoid future problems. However,