Business Ethics and Conduct Policy

Purpose
The New Day Company, LLC is committed to the highest standards of ethical conduct and integrity in its business operations. This Business Ethics and Conduct Policy sets forth the principles and ethical standards that guide our decisions and actions in the marketplace.

Scope
This policy applies to all employees, officers, and directors of The New Day Company, LLC, as well as contractors, consultants, and other representatives when they are acting on behalf of the company.

Policy Statement
The New Day Company, LLC expects all employees and representatives to conduct business legally and ethically, making decisions that are not only in the best interests of the company but also in accordance with the highest standards of integrity and compliance with all applicable laws.

Guidelines for Conduct

• Compliance with Laws: All employees must understand and comply with all laws, regulations, and policies that apply to their job responsibilities.
• Conflicts of Interest: Employees must avoid situations where their personal interests could conflict, or appear to conflict, with the interests of the company.
• Confidentiality: Employees must protect the confidentiality of company information and not use it for personal gain.
• Fair Dealing: Every employee should endeavor to deal fairly with the company’s customers, suppliers, competitors, and employees.
• Protection and Proper Use of Company Assets: Employees should protect the company’s assets and ensure their efficient use for legitimate business purposes.
• Reporting Any Illegal or Unethical Behavior: Employees should report any observed illegal or unethical behavior and not feel threatened when doing so.

Responsibilities

• Management: It is the responsibility of company management to lead by example and support all aspects of this policy.
• Employees: All employees are expected to adhere to the principles set forth in this policy and report any violations.
• Ethics Committee: The company will maintain an Ethics Committee responsible for the implementation of this policy and the resolution of any related issues.

Reporting Violations

• Mechanisms: The company will establish mechanisms for the reporting of unethical behavior, including a confidential hotline.
• No Retaliation: The New Day Company, LLC prohibits retaliation against individuals who report ethical violations in good faith.

Training and Communication

• Regular Training: The company will provide regular training to employees on the principles and expectations of this Business Ethics and Conduct Policy.
• Dissemination: This policy will be widely disseminated to all employees and clearly communicated to ensure understanding and commitment.

Enforcement and Discipline

• Consistent Enforcement: The New Day Company, LLC will consistently enforce this policy through appropriate disciplinary action up to and including termination.
• Regular Review: The Ethics Committee will regularly review and update this policy to ensure that it meets the evolving standards of ethical business conduct.

Commitment to Ethical Standards
The New Day Company, LLC is dedicated to maintaining the trust of its employees, customers, shareholders, and the communities in which it operates. This policy is central to that commitment and serves as a guide to ensure that our business practices reflect our ethical standards.