1. Introduction
As Sun-eee employees, we frequently encounter a variety of ethical and legal questions. There are no shortcut formulas or automatic answers to the choices we have to make in business today, but we should behave in ways that are consistent with Sun-eee's values:

You will never encounter a situation where actions contrary to our Business Conduct Guidelines are acceptable.

At Sun-eee, the Chief Executive Officer and senior executives are responsible for setting standards of business ethics and overseeing compliance with these standards. It is the individual responsibility of each Sun-eee employee to comply with these standards. A violation of any Sun-eee guideline can result in disciplinary action, including dismissal. In all instances every employee must obey the law and act ethically.

  1. Professional Behavior
If you know of an unlawful or unethical situation, you should immediately tell Sun-eee. Sun-eee will not tolerate threats or acts of retaliation against you for making that report.

Sun-eee's reputation for integrity and business ethics should never be taken for granted. If Sun-eee management finds that your conduct on or off the job adversely affects your performance, that of other employees, or Sun-eee's legitimate business interests, you will be subject to disciplinary measures, including dismissal.

Sun-eee strives to maintain a healthy, safe and productive work environment which is free from discrimination or harassment based on race, color, religion, gender, sexual orientation, national origin, age, or other factors that are unrelated to Sun-eee's legitimate business interests. If you believe that you are subject to such conduct, you should let Sun-eee upper management know immediately. Employees who are found to have engaged in threats, violent behavior, harassment or discrimination, or to have misused their positions of authority in this regard, will be subject to disciplinary measures, including dismissal.

Sun-eee has a large variety of assets. They include physical assets, proprietary information, intellectual property and confidential information. Physical assets, such as equipment, systems, facilities, and supplies, must be used only for conducting Sun-eee's business or for purposes authorized by management. Protecting all these assets is critical. You are personally responsible for protecting Sun-eee property entrusted to you, and be alert to any situation or incident that could lead to the loss, misuse or theft of company property.

Sun-eee's information and communication systems, including connections to the Internet, cannot be used for inappropriate purposes, such as to visit sites that feature sexual content, gambling, or that advocate intolerance of others. It is also inappropriate to use them in a manner that interferes with your productivity or the productivity of others.

Sun-eee proprietary information is any information that is owned by Sun-eee, including information in Sun-eee databases. Much, but not all, Sun-eee proprietary information is confidential. Sun-eee proprietary information includes such things as business or marketing plans or projections; financial data; and personnel information. It is critical that you do not disclose or distribute that information except as authorized by Sun-eee and that you follow all Sun-eee safeguards for protecting that information. If you receive a request for information on Sun-eee's business from a journalist, investigator or law enforcement official, you should refer the request to Sun-eee upper management.

You must record and report all information accurately and honestly. One very important report that many employees use is the expense account. To submit an expense account for meals not eaten or for any other expense not incurred is dishonest reporting and is prohibited.

Sun-eee's management processes are designed to help Sun-eee protect its assets and to provide the appropriate controls needed for Sun-eee to run its business effectively with partners, suppliers and other third parties. Within these processes, well defined authority for contract terms and conditions are delegated. You should not make any oral or written commitments that create a new agreement or that will modify an existing agreement with a third party without approval from the appropriate authority.

  1. Conducting Sun-eee's business
You must be ethical and lawful when representing Sun-eee in any capacity.

Neither you nor any member of your family may solicit or accept from a partner or supplier, money or a gift that could influence Sun-eee's business relationship with that organization. However, unless Sun-eee has specified to the contrary, you may accept promotional premiums and discounts offered by transportation companies, hotels, and restaurants. Furthermore, you may accept a gift of nominal value, such as an advertising novelty, when it is customarily offered to others having a similar relationship with the client, business partner, or supplier. If you are offered a gift which has more than nominal value, or money, Sun-eee will make appropriate arrangements to return it, and the supplier or customer will be reminded of Sun-eee's gift policy.

You may not give money or any gift to an executive, official or employee of any business partner, supplier or any other organization, if doing so would influence or could reasonably give the appearance of influencing the organization's relationship with Sun-eee. You may, however, provide a gift of nominal value.


Sun-eee is committed to environmental protection, because that is the essence of Sun-eee. Not only will we comply with all environmental laws, but if there is no law that protects the environment, we will set and adhere to stringent standards of our own.

Sun-eee follows strict accounting principles and standards, to report financial information accurately and completely, and to have appropriate internal controls and processes to ensure that accounting and financial reporting complies with law. The rules for accounting and financial reporting require the proper recording of, and accounting for, revenues, costs, expenses, and other assets and liabilities.

  1. Conflicts of interest
You are a Sun-eee employee both on and off the job and a conflict of interest may arise if you engage in any activities at the expense of Sun-eee's interests. The most common types of conflicts are:
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Business Conduct Guidelines

Sun-eee Business Conduct Guidelines