Awareness Training

Orientation and Refresher:

All regular full- and part-time new employees receive an initial orientation to the Code of Ethics and Standards of Business Conduct.

Employees also receive an annual refresher to the Code of Ethics beginning their second year with the Company.

Ethics and Compliance Training

Online ethics and compliance training is mandatory for all exempt and certain non-exempt employees. Selected courses have been organized into two curricula (Government and Commercial), are assigned as follows:

• Senior Executives (SE) - 7 courses per year
• Senior Managers and Executives (SME) - 6 courses per year
• Team Leaders, Supervisors and Managers (TSM) - 4 courses per year
• All other exempt employees (AOE) - 3 courses per year
• All non-exempt employees - 2 courses per year

We electronically monitor completions of the training by all employees. 100% completions of the required courses is mandatory for all employees.

Offline

Offline training is for all regular full- and part-time employees who are not enrolled in online training. These are generally non-exempt employees. We select a new course each year. Course will be delivered by one of the following two methods:

• By Facilitator to employees who do not have computer and Internet access.
• By Self-Study Booklet to employees who do not have computer and Internet access and who cannot be trained in a group setting.