Code of Conduct

• Obey all applicable laws and regulations.
• Be fair and honest in all business activities and relationships.
• Avoid conflicts of interest.
• Support diversity and foster an atmosphere of respect and equal opportunity for all employees.
• Strive to create a safe and healthy environment for employees and customers.
• Record all transactions accurately and timely and safeguard company assets.

Key Compliance Policies Improper Payments Working with Governments Competition Laws Conflicts of Interest Environment, Health and Safety Intellectual Property Fair Employment Practices Controllership

Overview:
Employees must not offer anything of value to obtain any improper advantage in selling goods or services, conducting financial transactions or representing the company's interests to governmental authorities.

Core Requirements:

• Never offer or give anything of value (such as money, goods or a service) to a customer to obtain any improper advantage.
• Never offer or give anything of value to a government official or employee.
• Never contribute company funds or other company assets for political purposes without the approval of the CEO and the Legal Department.
• Reimbursing employees for political contributions is prohibited.

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Working with Governments

Overview:
Central Parking is committed to conducting business with all governmental representatives with the highest ethical standards and in compliance with applicable laws and regulations.

Core Requirements:

• Abide by all applicable laws and regulations, particularly special requirements for government contracts and transactions.
• Follow the company's improper payments policy.
• Be truthful and accurate when dealing with government officials and agencies.

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Competition Laws

Overview:
Central Parking System is committed to complying with the anti-trust and competition laws in all of its activities.

Core Requirements:

• Do not propose or enter into any agreements or understandings-expressed or implied, written or oral-with any competitor.
• Do not discuss with competitors:
• Pricing
• Terms or conditions of contracts
• Costs, profits or profit margins
• Market share
• Coordination of bidding activities
• Dividing territories or customers or allocating markets
• Memorialize all conversations with competitors and confirm no anti-competitive activities.

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Conflicts of Interest

Overview:
Employees must avoid conflicts of interest between work and personal affairs.

Core Requirements:

• Disclose any outside activities, interests or relationships that may present a possible conflict of interest.
• Disclosures must be in writing and to your supervisor.
• Do not misuse company resources (including office equipment, e-mail and computer applications).
• Do not accept gifts or favors of greater than nominal value from suppliers, customers or competitors.
• Do not direct business to a supplier that is owned or managed by a relative or close friend unless your relationship is fully disclosed to your supervisor and it is in the best interest of the company.

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Environment, Health and Safety

Overview:
Central Parking System is committed to achieving environmental, health and safety (EHS) excellence. Central Parking System will strive to provide a safe and healthy working environment and avoid adverse impact and injury to the environment. 

Core Requirements:

• Comply with all OSHA and all other relevant EHS laws and regulations.
• Implement Central Parking System safety program and comply with the company's EHS policies.
• Create and maintain a safe working environment and prevent workplace injuries.
• Respond promptly to concerns about safety issues.

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Intellectual Property

Overview:
Employees are expected to take steps to safeguard the company's intellectual property - trade secrets, client /customer information, trademarks, copyrights and other proprietary information, and to respect the intellectual property rights of others. 

         Core Requirements:

• Identify and protect proprietary information
• Restrict access on a “need to know” basis.
• Ensure managers have signed appropriate agreements protecting proprietary information.
• Respect valid patents, trademarks, copyrighted materials and other protected intellectual property rights.
• Consult company legal counsel before
• Soliciting, accepting or using proprietary information of others.
• Signing confidentiality agreements, licenses or other agreements designed to protect intellectual property rights.

Fair Employment Practices

Overview:
Central Parking is committed to fair employment practices, including the prohibition against all forms of illegal discrimination. By embracing diversity and providing equal access and fair treatment to all employees on the basis of merit, we improve Central Parking's success while enhancing the progress of individuals.

Core Requirements:

• Do not discriminate in employment-related decisions on the basis of race, color, religion, national origin, sex (including pregnancy), sexual orientation, age, disability, veteran status or other characteristics protected by law.
• Use merit qualifications (for example: education, experience, competencies, job performance, etc.) and other job-related criteria for all employment-related decisions.
• Maintain the integrity of the appraisal process and follow the company's progressive discipline policy.
• Treat all employees with dignity and respect-avoid all forms of harassment.
• Comply with all wage and hour laws and regulations.

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Controllership

Overview:
Controllership comprises three elements: (1) compliance with applicable laws, regulations and company policies; (2) rigorous business processes to ensure sound business decisions and proper safeguarding of company assets; (3) integrity in communications to ensure timely and accurate reporting of financial information.

Core Requirements:

• Follow the company's accounting procedures as well as all generally accepted accounting principles, standards, laws and regulations for accounting and financial reporting of transactions.
• Maintain complete, accurate and timely records and accounts to reflect all business transactions.
  Safeguard all company assets, including physical and financial assets, intellectual property and other proprietary information.
• Use economic, risk-based data to make business decisions.
• Provide timely, candid forecasts and assessments to management.
• Maintain sound processes and controls.

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