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Code of Ethics

Integrity is at the center of all we do

General Standards of Ethical Behavior

We honor our agreements, deliver on our promises, and do the right thing for employees, clients and partners.

Promote the best interests of the Company at all times, conduct their personal and professional affairs in a way that avoids both real and apparent conflicts of interest between their interests and the interests of the Company, and refrain from engaging in any activity that would compromise their professional ethics or otherwise prejudice their ability to carry out their duties to the Company.
Communicate and report financial information in a manner that facilitates the highest degree of clarity of content and meaning so that readers and users will be able to quickly and accurately determine the significance and consequence of that information.
Encourage open communication and full disclosure of financial information by providing a well understood process by which management is kept informed of financial information of importance, including any departures from sound policy, practice, and accounting norms.
Ensure that all relevant staff members understand the Company’s open communication and full disclosure standards and processes.
Refrain from disclosing confidential information acquired in the course of their work except where authorized, unless legally obligated to do so. Inform subordinates, as appropriate, regarding the confidentiality of information acquired in the course of their work and monitor them as needed, to ensure that they maintain that confidentiality.
Refrain from using or appearing to use confidential information acquired in the course of their work for unethical or illegal advantage, either personally or indirectly through others.

Compliance with Laws

Directors, officers and employees of the Company must respect and follow the laws, rules and regulations of the local, state and federal governments.

If any such law, rule or regulation conflicts with a policy in this Code, you must comply with the applicable law, rule or regulation; however, if a local customer or policy conflicts with this Code, you must comply with the Code.

Standards Regarding Financial Records and Reporting

Establish appropriate systems and procedures to ensure that business transactions are recorded on the Company’s books in accordance with Generally Accepted Accounting Principles, established company policy, and appropriate regulatory pronouncements and guidelines.
Establish appropriate policies and procedures for the protection and retention of accounting records and information as required by applicable law, regulation or regulatory guidelines.
Establish and administer financial accounting controls that are appropriate to ensure the integrity of the financial reporting process and the availability of timely, relevant information for the safe, sound and profitable operation of the Company.
Completely disclose all relevant information reasonably expected to be needed by the Company’s internal and external auditors for the full, complete, and successful discharge of their duties and responsibilities. Compliance with Laws Directors, officers and employees of the Company must respect and follow the laws, rules and regulations of the local, state and federal governments. If any such law, rule or regulation conflicts with a policy in this Code, you must comply with the applicable law, rule or regulation; however, if a local customer or policy conflicts with this Code, you must comply with the Code.

Policy Principles

The principles or standards described below reiterate Pomeroy’s
commitment to diversity and inclusion, focused on three main areas:
attracting, retaining, and developing a diverse employee population;
fostering and procuring a work environment where employees are treated
with respect and their differences are valued; and seeking, creating and
maintaining mutually beneficial business relationships with diverse service
providers.