DNPA Code of Ethics

PURPOSE: At BrainTestMania, our team members are committed to maintaining the highest ethical standards in conducting company affairs. The aim of this policy is to ensure that every team member conducts business with integrity and adheres to all applicable laws, without seeking personal benefit.

Summary of Company Policy:

General Policy Application:

Gifts, Favors, and Payments by BrainTestMania: These may be offered to others if they:

Are in line with accepted business practices.

Have limited value and are not perceived as bribes.

Comply with applicable laws and ethical standards.

Would not embarrass the company if publicly disclosed.

Payments or compensation to associates of customers not in a written contract are against policy.

Gifts, Favors, Entertainment, and Payments Received by Team Members:

Team members should not seek or accept gifts, favors, entertainment, or payments without a legitimate business purpose.

Personal loans from entities doing business with BrainTestMania, except conventional loans from lending institutions, are discouraged.

Acceptable courtesies include:

Meals with vendors, occasionally including spouses.

Nominal gifts from vendors.

Event tickets if accompanied by the vendor, with approval from a company officer.

Overnight outings with other company or vendor representatives, with prior approval.

Perishable holiday gifts.

Stringent standards for gifts from suppliers.

Day outings like golf with vendors are acceptable with prior approval.

Use of vendor facilities for personal use is prohibited, except in limited circumstances.

Cash or equivalent gifts are never permissible.

Team members must avoid conflicts between personal interests and BrainTestMania’s interests.

Management should avoid accepting significant gifts from subordinates.

Conflicts of Interest:

Potential conflicts must be disclosed in writing to a manager.

Examples of conflicts include:

Significant interest in an enterprise doing business with BrainTestMania.

Holding positions in competing enterprises.

Acting as a broker or intermediary in transactions involving the company.

Any situation that might prevent acting in the company’s best interest.

Confidential Information:

Unauthorized disclosure or misuse of confidential information is prohibited.

Compliance:

Violations will result in disciplinary action, including possible discharge.

Violations must be reported to management.

Vice presidents and officers are responsible for compliance in their areas.

Social Media Guidelines:

Use sound judgment and remember the public nature of social media.

Understand that social media encompasses a wide range of online communication.

Adhere to company policies in social media activities.

Inappropriate postings may lead to disciplinary action.

You are personally responsible for your online content.