Page 41 - NWF November Updates
P. 41

RECEIVING OR PROVIDING TRAVEL OR ENTERTAINMENT: No employee or close relative shall
           accept from, or offer to, any individual who has an interest in an issue, matter or transaction in
           which NWF has an interest, any transportation, meal, lodging, entertainment or similar item or

           benefit with a value of more than $100 annually.


          ACCEPTING BEQUESTS OR LEGACIES: Employees or their close relatives shall not accept a
           bequest or legacy from any individual who has an interest in an issue, matter or transaction in
           which NWF has an interest unless the bequest of legacy is from a close relative.


          EMPLOYMENT OF CLOSE RELATIVES: No employee will be placed in a division where the

           employee and a close relative will have the same supervisor or manager. Likewise, no
           employee will be placed in a position where he or she will report, either directly or indirectly,
           to close relative.


          COMPETING WITH NWF: No employee or close relative shall prevent or hinder NWF from

            lawfully competing with others or divert business or personnel from NWF.

          No employee or close relative shall: (1) enter into a partnership or any joint venture with any
           individual who has an interest in an issue, matter or transaction in which NWF has an interest;
           (2) receive a commission from another party on an NWF transaction; (3) be employed by or

           advise a business or organization which competes with NWF; or (4) otherwise profit, directly
           or indirectly from a transaction with NWF. In addition no employee or close relative shall take
           for him or herself an opportunity which belongs to NWF or purchase or acquire any real
           estate, stock, security or other property of any kind which he or she knows, through his or her
            capacity as an employee or close relative, is presently being considered for purchase or

            acquisition by NWF, except a security publicly traded in a recognized market.


           FEES FOR ADVISORY SERVICES: No employee or close relative shall accept any fee or other
            consideration for advising or consulting services provided to any individual who has an
            interest in an issue, matter or transaction in which NWF has an interest except reasonable fees
            paid to the individual in connection with his or her service as a director or trustee of such
            business or organization. OUTSIDE DIRECTORSHIPS: No NWF employee shall serve as a

            director or trustee of any other corporation or organization which has an interest in a matter,
            issue or transaction in which NWF also has an interest without disclosing that fact and first
            obtaining approval unless the organization is a religious, civic, professional, educational,
            social, residential, recreational or other organization of a similar purpose, in which case prior
            approval is not required. NWF staff who serve on advisory committees are not required to
            disclose this relationship as the opportunity to influence a decision is at a significantly lower

            threshold.
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