Code of Behavior and Conduct

MTM’s Code of Behavior and Conduct:

MTM and its Team Members must, always, comply with all applicable laws and regulations. MTM will not condone the activities of Team Members who achieve results through unethical business dealings or violation of the law. This includes any payments for illegal acts, indirect contributions, rebates, and bribery. MTM does not permit any activity that fails to stand up to the closest possible public scrutiny.

All business conduct should be well above any minimum standards required by law. Accordingly, Team Members must ensure that their actions cannot be interpreted as being, in any way, in contravention of the laws and regulations governing MTM’s operations. Team Members uncertain about the application or interpretation of any legal requirements should refer the matter to their supervisor, the Corporate Ethics Officer, or an appointed designee, who, if necessary, should seek MTM’s legal counsel.

General Team Member Conduct:

MTM expects its Team Members to conduct themselves in a businesslike and professional manner always when representing or acting on MTM’s behalf.

Drinking, gambling, fighting, swearing, and similar unprofessional activities are strictly prohibited while on the job.

Team Members must not engage in sexual harassment or conduct themselves in a way that could be construed as such, for example, by using inappropriate language, keeping, or posting inappropriate materials in their work area, accessing inappropriate materials on their computer, and/or any inappropriate or unwanted touching.

Conflicts of Interest:

MTM expects that Team Members will perform their duties conscientiously, honestly, and in accordance with the best interests of MTM. Team Members must not use their position, or the knowledge gained because of their positions for private or personal advantage. Regardless of the circumstances, if Team Members sense that a course of action they have pursued, or are presently pursuing, or are contemplating pursuing may involve them in a conflict of interest with their employer, they should immediately communicate all the facts to their manager.

Outside Activities, Employment, and Directorships:

All Team Members share a solemn responsibility to promote MTM’s in good public standing, especially at the community level. Their readiness to help with religious, charitable, educational, and civic activities brings credit to MTM, and is greatly encouraged. Team Members must, however, avoid acquiring any business interest or participating in any other activity outside MTM that would, or would appear to:

• Create an excessive demand upon their time and attention, thus depriving the Company of their best efforts on the job
• Create a conflict of interest - an obligation, interest, or distraction - that may interfere with the independent exercise of judgment in MTM’s best interest.

Relationships with Clients and Suppliers:

Team Members should avoid investing in or acquiring a financial interest for their own accounts in any business Company that has a contractual relationship with MTM, or that provides goods or services, or both, to MTM if such investment or interest could influence or create the impression of influencing their decisions in the performance of their duties on behalf of MTM.

Gifts, Entertainment, and Favors:

Team Members must not accept entertainment, gifts, or personal favors that could, in any way, influence, or appear to influence, business decisions in favor of any person or Company with whom or with which MTM has, or is likely to have, business dealings. Similarly, Team Members must not accept any other preferential treatment under these circumstances because their positions with MTM might be inclined to, or be perceived to, place them under obligation to return the preferential treatment.

Kickbacks and Secret Commissions:

Regarding MTM’s business activities, Team Members may not receive payment or compensation of any kind, except as authorized under MTM’s business and payroll policies. MTM strictly prohibits the acceptance of kickbacks and secret commissions from suppliers or others. Any breach of this rule will fully result in immediate termination and prosecution of the law.

Company Funds and Other Assets:

Team Members who have access to Company funds in any form must follow the prescribed procedures for recording, handling, and protecting money as detailed in MTM’s policies and procedures or other explanatory materials, or both. MTM imposes strict standards to prevent fraud and dishonesty. If Team Members become aware of any evidence of fraud and dishonesty, they should immediately advise their supervisor or seek appropriate legal guidance so that MTM can promptly investigate the matter further.

When a Team Member’s position requires spending company funds or incurring any reimbursable personal expenses, that individual must use good judgment on MTM’s behalf to ensure that good value is received for every expenditure. Company funds and all other assets of MTM are purposed for MTM only and not for personal benefit. This includes the personal use of company assets, such as computers.

Company Records and Communications:

Accurate and reliable records of many kinds are necessary to meet MTM’s legal and financial obligations and to manage the affairs of MTM. Company books and records must reflect in an accurate and timely manner all business transactions. The Team Members responsible for accounting and recordkeeping must fully disclose and record all assets, liabilities, or both, and must exercise diligence in enforcing these requirements. Team Members must not make or engage in any false record or communication of any kind, whether internal or external, including but not limited to:

• False expense, attendance, production, financial, or similar reports and statements
• False advertising, deceptive marketing practices, or other misleading representations

Dealing with Outside People and Organizations:

Team Members must take care to separate their personal roles from their company positions when communicating on matters not involving Company business. Team Members must not use Company identification, stationery, supplies, and equipment for personal or political matters. When communicating publicly on matters that involve Company business, Team Members must not presume to speak for MTM on any topic, unless they are certain that the views they express are those of MTM, and it is MTM’s desire that such views be publicly disseminated. When dealing with anyone outside MTM, including public officials, Team Members must take care not to compromise the integrity or damage the reputation of either MTM, or any outside individual, business, or government body.

Prompt Communications:

In all matters relevant to clients, suppliers, government authorities, the public and others in MTM, all Team Members must make every effort to achieve complete, accurate, and timely communications - responding promptly and courteously to all proper requests for information and to all complaints.

Privacy and Confidentiality:

When handling financial and personal information about clients or others with whom MTM has dealings, observe the following principles:

• Collect, use, and retain only the personal information necessary for MTM’s business. Whenever possible, obtain any relevant information directly from the person concerned. Use only reputable and reliable sources to supplement this information.
• Retain information only for as long as necessary or as required by law. Protect the physical security of this information.
• Limit internal access to personal information to those with a legitimate business reason for seeking that information. Use only personal information for the purposes for which it was originally obtained. Obtain the consent of the person concerned before externally disclosing any personal information, unless legal process or contractual obligation provides otherwise