Ethics and Disclosure Code
This code is designed to provide all employees of Tubefilter with guidelines for appropriate professional conduct. The central premise of this code is that Tubefilter’s reputation for quality products and services, for business integrity, and for the independence and integrity of our publications, services and products is the heart and soul of our enterprise.
Tubefilter may from time to time publish content which might present a conflict of interest. This content will always be identified. It is Tubefilter’s policy that all disclosures made by the Company should be accurate, complete, understandable to the reader and fairly present the Company’s financial and business interests in all material respects. Additionally, we work hard to ensure that:
- Our facts are accurate and fairly presented;
- Our analyses represent our best independent judgments rather than our preferences, or those of our sources, advertisers or information providers;
- Our opinions represent only our own editorial philosophies; and
- There are no hidden agendas in any of our journalistic undertakings.
Tubefilter may accept forms of cash advertising, sponsorship, and/or other forms of compensation. The compensation received will never influence the content, topics or stories published by Tubefilter. All advertising is in the form of advertisements generated by a third party ad network or by an internal sales team that does not participate in journalistic undertakings. All such advertisements will be identified as paid advertisements or sponsorships.
Tubefilter staff and employees are not compensated by any third party to provide opinion on products, services, shows, websites, or any other topic which we may cover. If we claim or appear to be experts on a certain topic, product, or service area, we will only endorse products or services that we believe, based on our expertise, are worthy of such endorsement. Any product claim, statistic, quote or other representation about a product or service should be verified with the manufacturer or provider.
Any and all information and other material obtained by a Tubefilter employee in connection with his or her employment is strictly the property of Tubefilter. Such information includes not only our own work and that of our colleagues, but also information relating to future activities, including as-yet-unpublished news, information and advertising, as well as schedules for publishing the same. Such material must never be disclosed to anyone outside Tubefilter, including friends and relatives. In no event should any information obtained in connection with Tubefilter employment be disclosed privately to anyone until such information has been made available to the public.
Business Relationships and Activities
Tubefilter employees must not use the Company’s assets, talents, information, technology, name or influence for their personal benefit or gain except as authorized by and in connection with their employment.
We recognize that Tubefilter cannot succeed if our customers do not succeed. It is our obligation to deliver our products and services in as timely a manner as possible, and with the highest possible levels of quality. Business dealings should be open and honest and transactions should be in the best interests of both Tubefilter and the customer.
To ensure this, Tubefilter employees should not offer or provide, to customers or prospective customers, directly or indirectly, any gift, entertainment or reimbursement of expenses of more than nominal value or that exceeds customary courtesies for that time and place. Nor should employees offer or provide, directly or indirectly, any material, equipment or services to any individual in a position to make or influence any business or governmental decision affecting Tubefilter.
Conversely, Tubefilter employees should not solicit or accept, directly or indirectly, any payment, loan, services, equipment or any other benefit or thing of value, or any gift, entertainment or reimbursement of expenses of more than nominal value or that exceeds customary courtesies for that time and place from suppliers or customers, or from any company, individual or institution that furnishes or seeks to furnish news, information, material, equipment, supplies or services to Tubefilter, or from anyone else with an actual or prospective business relationship with Tubefilter.
Tubefilter employees must remain scrupulously free from obligation to suppliers and vendors. Accordingly, employees should not requisition, order, approve or otherwise participate in the purchase of goods or services on behalf of Tubefilter from any person or entity if the employee or any member of the employee’s family or household has a substantial financial interest in the supplier or vendor.
Compliance with Law, Rules and Regulations
All employees must obey the applicable laws, rules and regulations of the United States. All employees of Tubefilter engaged in business outside of the United States must obey the applicable laws of countries in which they do business, and respect local culture and values while operating within the strictures of such laws and this code. All applicable trade agreements, including U.S. trade laws, must be honored and observed, including the U.S. Foreign Corrupt Practices Act, which generally makes it illegal to offer or give a bribe to a foreign official or candidate for foreign office, whether directly or through third parties such as consultants or agents.
Compliance with this Code
Tubefilter takes this code very seriously. All employees of Tubefilter are responsible for compliance with all aspects of this code. All new employees shall be required to read this code at the outset of their employment, and to attest in writing that they have done so; all Tubefilter employees shall be required, at the time this code is first promulgated, to read it and so attest. In the case of all members of senior management, and all news and advertising personnel, such written attestations shall be required once each year.
Waivers or Amendments
Any waivers of or amendments to this code that apply to the Company’s Chief Executive Officer, Principal Financial Officer or Controller may be made only by the Company’s Board of Directors or a committee of the Board. Any such waivers or amendments will be disclosed promptly as required by applicable law.
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