As critical as each of the above areas are, they must be and are built and sustained from a strong foundation of ethics. The company has a formal Code of Ethics, created by the Board of Directors, which employees are required to read and acknowledge their understanding of. We use an on-line mechanism to train employees in key ethical areas on an annual basis.

The company maintains an 800 number through which any employee can anonymously report any incident they regard as an ethical violation. This is heavily promoted throughout our facilities and each call is immediately followed up on with a summary report to the Board of Directors.

A listing of the company's values (which were originally determined by an employee group) is integrated into key communications throughout the year from new employee orientation to an address our senior executives give to the entire company on an annual basis.

We have created a management function called Growth Development Leader, a role that select company personnel carry in addition to their job duties. There are approximately 125 Growth Development Leaders throughout our organization, including international locations, each with the responsibility of communicating with a specific group of people. These people meet with management approximately every six weeks for a two way dialogue, communicating company programs and concerns to these leaders who in turn share them with their groups, and bringing questions and concerns from their groups to the attention of management. Any ethics issue would be fully aired and shared through this group.

As a part of our philosophy of openness and honesty, we survey our entire workforce on an annual basis. A wide ranging survey that addresses interaction between employees and managers, the condition of the workplace and employee feelings about a wide range of programs, activities and benefits, the survey also asked specific questions on fairness, ethics, and how managers represent the company. The results of this survey are shared on an individual basis with managers and summary scores are tracked and shared with the entire workforce and the Board of Directors.