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disclosed  without   authorization  or   used   for  personal  gain.  Team  members  are
                   required to  follow all  procedures regarding collection, use,  and  disclosure of  personal
                   information as set out in this policy. Team members who disclose personal information,
                   contrary  to  this  policy  will  be  subject  to  disciplinary  measures,  up  to  and  including
                   discharge for cause.


                    TEAM MEMBER PERSONAL INFORMATION
                   Teams members should advise Human Resources of any changes in your home address,
                   telephone number, marital status, dependents, beneficiary, or persons to notify in case
                   of emergency. Personnel files are the property of Jim Peplinski Leasing and access to the
                   information they contain is restricted. Only supervisors and managers with a legitimate
                   reason to review information on file are  permitted access.   If  you resign, retire or  are
                   terminated, the company will retain your personnel file for seven years.

                   CONFLICTS OF INTEREST

                   Business Transactions:
                   Team members have an obligation to conduct business within guidelines that prohibit
                   actual  or  potential  conflicts  of  interest.   This  policy  establishes  only  the  framework
                   within which Jim Peplinski Leasing wishes to operate its business. The  purpose  of  these
                   guidelines  is  to  provide  general  direction  so  that  team  members  can  seek  further
                   clarification  on  issues  related  to  the  subject  of  acceptable  standards  of  operation.
                   Contact Human Resources for more information or if you have questions about conflicts
                   of interest.

                   Transactions with outside firms must be conducted within a framework established and
                   controlled  by  the  executive  level  of  Jim  Peplinski  Leasing.  Business  dealings  with
                   outside  firms  should  not  result  in  unusual  gains  for those firms. Unusual gain refers
                   to  bribes,  product  bonuses,  special  fringe  benefits,  unusual  price  breaks  and  other
                   windfalls designed to ultimately benefit either the outside client or service provider, or
                   any team member of the same, or  both.  Promotional  plans  that  could  be  interpreted
                   to  involve  unusual  gain require specific executive level approval.
                   No "presumption of guilt" is created by the mere existence of a relationship with outside
                   firms.    If team members are acting as Jim Peplinski Leasing representatives with clients
                   or service providers with whom they also have personal  or  other  business  relations,  it
                   is  imperative  that  they  disclose  to  an officer of the company, as soon as possible, the
                   existence  of  any  actual  or  potential  conflict  of  interest  so  that  safeguards  can  be
                   established to protect all parties.

                   With regard to the treatment of clients, limited business related entertainment, favors
                   or gifts may be offered to clients if the following criteria are met:

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