Code of Conduct
Including Conflicts, Record Keeping, Compliance with Law & Reporting of Violations
(as adopted by the Executive Oversight Board on May 10, 2017)

The board members, employees and contractors of LOT Network (LOT) should do the right thing – follow the law, act ethically, and treat each other with respect.

We expect all of our employees, contractors and board members to know and follow this Code of Conduct (Code). Failure to do so can result in disciplinary action, including, for employees, up to termination of employment. Any waivers of this Code must be approved by the Executive Oversight Board (EOB).

Never retaliate against anyone who reports or participates in an investigation of a possible violation of the Code.

If you have a question or concern about this Code or believe that someone may be violating it, you can make a report of a suspected violation or concern through any member of the EOB.

I. Avoid Conflicts of Interest
A conflict of interest may arise any time competing loyalties could cause you to pursue a personal benefit for you, your friends, or your family at the expense of LOT. Avoid conflicts of interest and circumstances that would appear to be a conflict (absent written approval of the EOB after full disclosure and completion of mitigating steps). Sometimes a situation that previously didn’t present a conflict of interest may develop into one.

When faced with a potential conflict, ask yourself:

  • Would this activity create an actual or apparent incentive for me to benefit myself, my friends, or my family?
  • Would this activity harm my reputation or hurt my ability to do my job?
  • Would this activity embarrass LOT or me if it showed up in the press?

If the answer to any of these questions is “yes,” the relationship or situation is likely to constitute a conflict of interest, and you should seek to avoid it.

To the extent permitted by law, a board member that serves as an employee of a LOT member shall be deemed not to have a conflict with LOT merely as result of such service or for pursuing the interest of that member in its dealings with LOT.

II. Ensure Financial Integrity and Responsibility; Preserve Business Records
Ensure that LOT’s assets are used and accounted for properly, our financial records are complete and accurate, and our internal controls are honored.

If your job involves the financial recording of our transactions, make sure that you’re familiar with all relevant policies, including those relating to tax treatment.

Never interfere with the auditing of financial records. Similarly, never falsify any company record or account.

If you suspect or observe any irregularities relating to financial integrity or fiscal responsibility, no matter how small, immediately report them to the EOB.

Accuracy, reliability and timeliness in the preparation of all financial records are of critical importance to LOT’s decision-making processes and to the proper discharge of LOT’s financial and legal obligations. All employees and contractors shall carry out their duties as necessary to produce such records and preserve them (and all other business records) for as long as required for LOT by law, or, if longer, in accordance with the attached schedule.

III. Obey the Law
Comply with all applicable legal requirements and understand the laws and regulations that apply to your effort by or on behalf of LOT. A few specific laws are worth pointing out here.

1. Tax exempt status
LOT is a tax-exempt organization. For LOT to maintain its tax-exempt status, it must do the following:

  • Continuously engage primarily in activities which accomplish one or more of its tax-exempt purposes.
  • Not allow more than an insubstantial accrual of private benefit to individuals or organizations. Not allow its income or assets to accrue to a person who has a personal or private interest in the activities LOT such as an officer, director, or a key volunteer.

2. Anti-Bribery Laws
Various laws that prohibit bribery in different settings. Our rule is simple – don’t bribe anybody, at any time, for any reason, or participate in corruption.

Be careful when you give gifts, pay for meals, entertainment or other business courtesies on behalf of LOT. Make sure they are lawful. Avoid the possibility that the gift, entertainment or other business courtesy could be perceived as a bribe. Provide such items infrequently and, when you do, keep their value, to the extent lawful, moderate.

Dealings with government affiliated parties. Various laws prohibit seeking to influence official action by offering, giving or providing anything of value to government officials, candidates for public office, employees of government-owned or -controlled companies, public international organizations, or political parties. Be sure to know and abide by the laws for the business situation you face.

IV. Conclusion
We rely on one another’s good judgment to uphold a high standard of integrity for ourselves and our company. We expect all employees, contractors and board members to be guided by both the letter and the spirit of this Code.