Section 06: Conflicts of Interest

Employees shall avoid outside employment, activities, investments, and other interests that involve obligations, which may compete with or be in conflict with the interests of the company. A conflict of interest can arise in dealings with anyone that AAA IMPORTS transacts business; i.e., customers, clients, owners, buyers, suppliers, banks, insurance companies, and people in other organizations with whom we contact and make agreements .

Conflicts of interest should be avoided and may include the following examples:

•  Working for any group mentioned above for personal gain.

•  Engaging in a part-time activity for profit or gain in any field in which the company is engaged.

•  Borrowing from, or lending money to, individuals representing organizations with which business dealings are conducted.

PERSONAL CONDUCT

The company expects that all of its employees will conduct themselves with the pride and respect associated with their positions, fellow employees, customers, his/her supervisor and the company. Employees should always use good judgment and discretion in carrying out the company's business. Employees of AAA IMPORTS should always use the highest standards of ethical conduct.

Improper conduct by and between employees and/or by and between employees and business associates on the company's premises or adversely affecting company work will not be tolerated. Any employee demonstrating improper conduct will be subject to disciplinary action including termination of employment.

CONFIDENTIALITY

AAA IMPORTS is engaged in a business, which requires that a strict code of confidentiality of information be maintained. No employee will store information outside of the company (either in written or electronic form) about any matter pertaining to the conduct of the company's business. No information regarding the purchase prices of AAA IMPORTS shall be given to any customer, competitor, other or vendor. No information regarding selling prices to one customer or vendor shall be given to another customer or vendor.

Do not discuss selling prices of products with vendors. This is delegated to top management personnel. Likewise, conversations regarding prices, service, problems, gossip, etc. about one vendor to another is only for the discretion of top management personnel. Lack of discretion in these matters is looked upon as a very serious matter. Any employee failing to abide by this policy will be subject to disciplinary action including immediate termination of employment.

In addition, idle gossip or dissemination of confidential information within the company, such as personnel information, financial information, etc. will subject the responsible employee to disciplinary action or possible termination of employment.

Employees at AAA IMPORTS will learn the business of importing and shipping product in from a foreign country. This information is considered valuable and unique to the sales area of AAA IMPORTS. In the event that an employee leaves the employ of AAA IMPORTS, he/she shall not compete nor participate in a business of similar nature – importing and shipping of products into the USA from a foreign country.

Company policy strictly forbids providing prospective employers with reference information on past workers. All requests for references must be forwarded to Personnel Department. Personnel Department will then provide the dates of employment and last title held.

The employee is required to sign a Confidentiality Agreement and a Non-Compete Agreement (back of Employee Handbook) in accord with the section.

BRIBES, KICK-BACKS AND OTHER ILLEGAL PAYMENTS

Bribes, kickbacks and other illegal payments to or from any individual with whom we conduct business in any form and for any purpose are prohibited.

Certain types of rebates to the company from suppliers (but not to or from an individual employee) are legitimate to correct commercial inequity if done within government trade regulations.

PATENTS AND COPYRIGHTS

Any patent or copyright developed by an employee in conjunction with and/or as a result of his/her employment with AAA IMPORTS is the property of the company. Any information pertaining to such patent or copyright must remain on company premises.

ACCEPTING GIFTS

Normally a gift to an individual from an outside source is considered the property of the company unless management makes an exception. It is the policy of AAA IMPORTS that no employee shall receive any gift, excessive or unusual entertainment, loan, or other favor (valued in excess of $5) from any outside source (including customers and suppliers) without approval from management. Any employee who fails to abide by this policy will be subject to disciplinary action including immediate termination of employment.