EST 310.2.3-08
Western Governors University

The APEX Company

BUSINESS ETHICS
CODE OF CONDUCT

TABLE OF CONTENTS

A. The APEX Company Ethics Program Introduction ……………………… 4
B. Standards and Procedures APEX Code of Conduct ………………………………………..…………. 5 C. Ethics Training Program New Employee Training ………………………………………..……….. 6 Current Employee Training …………………………………………….. 6
D. Compliance Systems Monitor ……………………………………………………………….… 6 Audit ………………………………………………………………......... 7 Reporting Misconduct ………………………………………………….. 8

E. Ethics Program Assessment Review …show more content…

Our objective auditing processes will report our compliance and noncompliance with our ethics program and determine whether or not APEX has reached its goals. All of our internal findings will be verified by an external auditing firm, Wecheckem Auditors, LLC. Wecheckem will generate a report that will be furnished to the Ethics Committee for publishing on the company’s intranet. This third party company will use the results of this report, responses from customers, and the ratings of the surveys to audit the employees of APEX compliance with our Code of Conduct, the company’s officers compliance with our Code of Conduct, and to assess the company an overall score from 1, non-compliant, to 10, excellent, on our ethical program. Reporting Misconduct
It is imperative that employees of APEX feel comfortable with bringing any issues and concerns to management’s attention. Ethical issues occurring with the staff should be communicated immediately. It is important to note APEX has a zero tolerance policy and any infractions of this code of ethics will be met with quick and decisive action. Any employee found to have violated this policy may be subject to disciplinary action, up to and including termination of employment.