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I. Introduction

This Ethics Code (“Code”) applies to the directors, officers and employees of (“FTL”) and any subsidiaries.  This Code is intended to deter misconduct and promote honest and ethical behavior (including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships); full, fair, accurate, timely, and understandable disclosure in reports and other communications; compliance with applicable governmental laws, regulatory rules and guidelines; proper internal reporting of violations of the Code; and accountability for adherence to the Code.

II. Principles and Responsibilities

In performing his or her duties, each director, officer and employee must:

  • Engage in and promote honest and ethical conduct in both personal and professional relationships;
  • Avoid conflicts of interest by disclosing to the Board of Directors any transaction or relationship that reasonably could be expected to give rise to such a conflict;
  • Not give or receive any type of gift, token or favor, that has or could reasonably be viewed as having any potential to influence how one would engage in or conduct business relations with the Company, or any of its suppliers, customers, competitors, or any other party with which FTL may engage; and
  • Promptly report any actual or suspected violations of the Code to a Director. Reports are anonymous and confidential.

No officer, employee, contractor, subcontractor, or agent of FTL may discharge, demote, suspend, threaten, harass, or in any other manner discriminate against an employee in terms and conditions of employment because of any lawful act done by the employee for providing information, causing information to be provided, or otherwise assisting in a governmental investigation regarding any conduct that the employee reasonably believes constitutes a violation of applicable law or this Code.

III. Adherence and Accountability

Each director, officer and employee will be held accountable for his or her adherence to this Code.  The failure of any director, officer or employee to comply with the Code may result in disciplinary action, up to and including termination of employment or removal from the Board of Directors.  Violations of this Code may also constitute violations of law and may result in civil and/or criminal penalties against the party.  This Code is not intended to nor does it create any rights in any reader, employee, customer, supplier, competitor, shareholder or any other person or entity.