We must avoid any relationship or activity that might impair, or even appear to impair, our ability to make objective and fair decisions when performing our jobs. At times, we may be faced with situations where the business actions we take on behalf of Thread may conflict with our own personal or family interests because of the course of action that is best for us personally may not also be the best course of action for Thread. We owe a duty to Thread to advance its legitimate interests when the opportunity to do so arises. We must never use Thread property or information for personal gain or personally take for ourselves any opportunity that is discovered through our position with Thread.

Determining whether a conflict of interest exists is not always easy to do. Employees with a conflict of interest question should seek advice from management. Before engaging in any activity, transaction or relationship that might give rise to a conflict of interest, employees must seek review from their managers or the Human Resources department.

Accepting Business Courtesies

Most business courtesies offered to us in the course of our employment are offered because of our positions at Thread. We should not feel any entitlement to accept and keep a business courtesy. Although we may not use our position to obtain business courtesies, and we must never ask for them, we may accept unsolicited business courtesies. Employees who award contracts or who can influence the allocation of business, who create specifications that result in the placement of business or who participate in negotiation of contracts must be particularly careful to avoid actions that create the appearance of favoritism or that may adversely affect the company’s reputation for impartiality and fair dealing. The prudent course is to refuse a courtesy from a supplier when Thread is involved in choosing or reconfirming a supplier or under circumstances that would create an impression that offering courtesies is the way to obtain Thread business.

Meals, Refreshments Entertainment and Gifts

We may accept occasional meals, refreshments, entertainment, gifts and similar business courtesies that are customary and conform to reasonable ethical practices of the marketplace, provided that:

•            They are not inappropriately lavish or excessive.

•             The courtesies are not frequent and do not reflect a pattern of frequent acceptance of courtesies from the 
same person or entity.

•             The courtesy does not create the appearance of an attempt to influence business decisions, such as 
accepting courtesies or entertainment from a supplier whose contract is expiring in the near future.

•             The employee accepting the business courtesy would not feel uncomfortable discussing the courtesy with 
his or her manager or co-worker or having the courtesies known by the public. 
Customary business entertainment is proper however, impropriety results when the value or cost is such that it could be interpreted as affecting an otherwise objective business decision. 
Employees with questions about accepting business courtesies should talk to their manager or the Human Resources department.
       
Offering Business Courtesies


•             Any employee who offers a business courtesy must assure that it cannot reasonably be interpreted as an attempt to gain an unfair business advantage or otherwise reflect negatively upon Thread. An employee may never use personal funds or resources to do something that cannot be done with Company resources. Accounting for business courtesies must be done in accordance with approved company procedures. 
Other than to our government customers, for whom special rules apply, we may provide non-monetary gifts (i.e., company logo apparel or similar promotional items) to our customers. Further, management may approve other courtesies, including meals, refreshments or entertainment of reasonable value, provided that:

•             The practice does not violate any law or regulation or the standards of conduct of the recipient’s organization.

•             The business courtesy is consistent with industry practice, is infrequent in nature and is not lavish.

•              The business courtesy is properly reflected on the books and records of Thread.