Attached files
FINANCE
CODE OF ETHICS
BUSINESS
CONDUCT
ILX
Resorts Incorporated subscribes to the highest principles of business
ethics. Our common goal must always be to maintain the Company’s
established reputation for absolute integrity. ILX does not seek
business success through illegal or unethical means, regardless of the
circumstances. Employees whose behavior is found to violate the
Company’s Code of Ethics will be subject to disciplinary action including, when
appropriate, termination.
As an ILX
employee, you are to follow the highest principles of business
ethics. While it is impossible to define every situation where
unethical business conduct may occur, the following are specifically to be
avoided:
· GRATUITIES
TO GOVERNMENT EMPLOYEES/OFFICIALS
In
accordance with government regulations, no ILX employee may offer a gratuity to
any government employee or official on behalf of, or in pursuance of, Company
business. Gratuities are defined as meals, drinks, gifts, expenses,
cash, or any other item of value including personal service. An offer
to provide, or the actual provision of, any form of gratuity to a government
employee or official will constitute grounds for immediate
termination. This policy does not prohibit offering discounts on
food, beverages or services to governmental employees at ILX facilities,
provided such discounts are offered uniformly to all such employees and do not
exceed discount rates offered to other non-governmental groups. The
term “gratuity” does not necessarily include the value or cost associated with
government employees’ or officials’ participation in or presence for meals,
meetings, conferences, seminars or other events, where such expenditures have
been approved by the Company’s senior management in connection with appropriate
interactions with such employees of officials concerning legitimate business,
political, legislative, and/or regulatory activities. The Company may
make exceptions to this policy when, in its sole discretion, it considers such
exceptions appropriate.
· GRATUITIES
TO/FROM CUSTOMERS AND SUPPLIERS
As an
employee of ILX, you may not offer to give, or accept a gratuity from a
customer, supplier or any other representative in the pursuit of business, or in
conjunction with the negotiation of business on behalf of
ILX. Expenses for meals as part of a seminar, convention, or business
meeting are not within the definition of gratuities for the purpose of this
policy. Invitations extended by a customer or supplier to participate
in any program or activity, such as a party or football game, should be referred
to your manager for approval on a case-by-case basis. This policy is
not intended to cover normal gratuities for resort employees for providing
service to guests (i.e., food and beverage services). Any violation
of this policy will constitute grounds for immediate termination. The
Company may make exceptions to this policy when, in its sole discretion, it
considers such exceptions appropriate.
· POLITICAL
ACTIVITIES
ILX
Resorts Incorporated, without reservation, accepts the basic democratic
principle that all employees are free to make their own individual decisions in
civic and political matters. The Company encourages its employees to
accept the personal responsibility of good citizenship, including
participation in civic and political activities. However, such
activities are to be carried on outside of normal working hours. No
political activities or solicitations may be carried on within Company
premises. For purposes of this policy, political activities are
defined as activities in support of, or in concert with, any individual
candidate (including employees who are or may be candidates) for political
office, or a political party, which seeks to influence the election of
candidates to federal, state or local offices. The term “political
activities or solicitations” does not necessarily include contacts with
government employees or officials at meals, meetings, conferences, seminars, or
other events, where such contact has been approved by the Company’s senior
management in connection with the Company’s expression of its own views
concerning matters that are the subject of business, political, legislative,
and/or regulatory discussion. Nor does this policy apply to political
activities or solicitations undertaken by the Company itself in connection with
its expression of such views. The Company may make exceptions to this
policy when, in its sole discretion, it considers such exceptions
appropriate.
RELEVANT
LAWS
ILX
employees must obey all relevant laws including those that apply to consumer
marketing, privacy, copyright protection, securities and taxes.
CONFLICT OF
INTEREST
Employees
of ILX Resorts Incorporated may not engage in any activity, practice, or
conduct, which conflicts with, or appears to conflict with, the interest of ILX,
its customers, or its suppliers. Any appearance of a conflict of
interest will be deemed as an actual conflict of interest and is hereby
prohibited. As such, employees and their immediate family may not
engage in the same or similar lines of business as those of ILX nor hold a
material financial interest in companies which are competitors to
ILX. For purposes of these provisions, immediate family includes
spouse, children and others sharing the same home as the
employee. Exceptions may be made on a case-by-case
basis. Such exception requests must be made in advance of their
occurrence to the employee’s supervisor and approved, in writing, by the Human
Resource Department.
Employees
are not to engage in, directly or indirectly, either on or off the job, any
conduct, which is disloyal, disruptive, competitive, or damaging to ILX Resorts
Incorporated.
REPORTING
ILX will
report the financial condition and results of operations
honestly. The Company’s records will be kept in accordance with
generally accepted accounting principles and with established internal control
policies. No financial data will be influenced by others or by
performance objectives. ILX will cooperate fully with, and not
conceal information from, external auditors and regulatory agencies during
examinations of the Company’s books, records and operations.
CONCERNS REGARDING
QUESTIONABLE ACCOUNTING OR AUDITING MATTERS
Any
employee who has concerns regarding questionable accounting or auditing matters
may anonymously submit his or her concern by mailing it in an envelope marked
“Audit Committee-Confidential” to ILX Resorts Incorporated, 2111 E. Highland
Avenue, Suite 200, Phoenix, Arizona 85016.
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I adhere
to the above Finance Code of Ethics.
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