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Regulatory and Legal Inquiries
To safeguard the Company's legal rights, inquiries from
federal, state and local governmental authorities should be
immediately referred to the Company's Legal Department unless
you have been specifically authorized to respond to such inquiries.
Examples of governmental inquiries include requests for information,
investigation notices, subpoenas and search warrants.
THIRD PARTY RELATIONSHIPS ( more
information> )
Insider Trading
Directors, officers and employees of TriMas may, in the
course of performing their duties, come into possession of "material
non-public information" about TriMas or other companies
with whom we do business. "Material non-public information"
is defined as any information that would affect securities prices,
either positively or negatively, that is not generally available
to the investing public. This information is generally referred
to as "insider information." Buying or selling stocks
using "insider information" is referred to as "insider
trading." It is a violation of this Code and against the
law for employees to buy or sell debt or equity securities of
TriMas or any other company based on insider information or
to discuss such information with others who might buy or sell
such securities.
Conflicts of Interest
Employees should avoid any situation that does or may involve
a conflict between their personal interest and the interests
of the Company as a whole. In dealings with other Company employees,
current or potential customers, suppliers, contractors and competitors,
employees should act in the best interests of the Company as
a whole and not based on personal relationships or personal
advantage. Employees must scrupulously avoid even the appearance
of a conflict between personal interests and those of the Company.
Any outside activities, financial interests, relationships or
other situations that do or may involve a conflict of interest,
that may make it difficult for the employee to perform work
objectively and effectively, or that present even the appearance
of an impropriety, must be promptly disclosed in writing to
the employee's manager and Finance Department representative,
as well as to the Company Legal Department. Questions regarding
the Company's policies on conflicts of interest should be directed
to the Company Legal Department.
Corporate Opportunities
Employees are prohibited from taking for themselves personally
opportunities that are discovered through the use of Company
property, information or position without the consent of the
Company's Board of Directors. Employees owe a duty to the Company
to advance the Company's legitimate interests when the opportunity
to do so arises, and are prohibited from competing against the
Company. No employee may use Company property, information or
position for improper personal gain.
Fair Dealings in Supplier and Other Relationships
The Company selects its suppliers in a fair, equitable and
nondiscriminatory manner based upon appropriate criteria such
as quality, price, service, delivery, financial strength, capabilities,
terms and similar competitive factors. Many employees are involved
in purchasing activities even though not part of the Company's
purchasing function. In all instances when you are involved
in the purchasing process, you must be fair and objective and
never base your decisions on personal interest. Employees should
endeavor to deal fairly with the Company's customers, suppliers,
employees and competitors, and to not take unfair advantage
whether through improper manipulation, concealment, abuse of
privileged information, misrepresentation of material facts
or through some other unfair dealing practice.
Bribes and Kickbacks
Employees may not give, offer, solicit or receive, directly
or indirectly, any bribes, "kickbacks" or other thing
of value designed to influence or compromise the conduct of
the recipient. As such, employees shall not (i) pay bribes to
government officials to obtain favorable rulings, (ii) pay or
receive rebates or kickbacks for obtaining business for or from
the Company, (iii) pay or receive any money, gifts, loans, or
other things of value that may tend to influence business decisions
or compromise business judgment, or (iv) engage in any other
activity that would similarly degrade the reputation or integrity
of the Company.
Gifts, Favors, and Entertainment
The Company does not seek to gain any improper advantage
through the use of gifts, entertainment, gratuities and other
courtesies. Similarly, the Company does not want the impartial
judgment of its employees compromised through the receipt of
such courtesies. The giving or acceptance of cash, gifts of
more than nominal value, excessive entertainment, discounts
or other benefits other than those generally available to the
public or Company employees, and most loans from present or
prospective competitors, customers, suppliers, partners, licensees
or other outside concerns that do or seek to do business with
the Company, are prohibited. In addition, gifts, entertainment,
gratuities and other courtesies should be offered or accepted
only to the extent such are ordinary and customary, reasonable
in the context, not lavish as measured by reasonable standards
in the business community, properly reflected on the Company's
financial records, consistent with all applicable laws and policies
of the Company and could not reasonably be construed as a bribe
or payoff or perceived as influencing the employee's judgment
or impartiality.
Gifts to, or entertainment of, domestic and foreign government
officials and employees involve special rules, laws and regulations.
With very limited exceptions, any gift to or entertainment of
domestic and foreign government employees is prohibited. Permissible
hospitality of foreign government officials and employees is
set forth in the Company's Foreign Official Hospitality Guidelines.
Any permitted gift to, or entertainment of, foreign government
officials or employees must comply with the policies set forth
in the Company's Foreign Official Hospitality Guidelines and
Foreign Corrupt Practices Act Policy. As for gifts to or entertainment
of employees of the U.S.
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