Wanderwell Code of Ethics
Wanderwell strives to always meet the highest ethical standards for all directors and employees.
We set the standard for excellence at the top of the organization, demonstrating the importance of adhering to the Code of Ethics by communicating and modeling the behavior we want all employees to follow.
Wanderwell requires that all directors and employees comply with all laws, rules and regulations applicable to the business. We provide training to ensure all employees understand the company policies, laws and regulations that apply to their specific roles, and seek guidance from experts when unsure of whether a contemplated action is permitted by law. We promote open communication so all employees, directors, and board members feel comfortable speaking up if they see possible violations.
Wanderwell prohibits bribes in any form, including kickbacks or gifts, on any portion of contract payments or soft dollar practices. We ensure all employees who award contracts or who have influence in the allocation of resources understand the role they play in promoting impartiality and fair dealing, including refusal of any courtesies from suppliers when involved in selecting or reconfirming a supplier or under circumstances that would create an impression of favoritism.
Wanderwell requires that all direct or indirect political contributions, charitable donations, and sponsorships by the Company are overseen and approved prior to the activity mentioned.
Wanderwell will publicly disclose financial and in-kind contributions to political parties, politicians, lobby groups, charitable organizations, and advocacy groups.
If you become aware of the violation of any law, rule or regulation by the Company, whether by employees, directors, or any third party doing business on behalf of the Company, it is your responsibility to promptly report the matter to your supervisor.
Conflicts of Interest
Employees and directors must act in the best interests of Wanderwell. You must refrain from engaging in any activity or having a personal interest that presents a “conflict of interest.” It is your responsibility to disclose any transaction or relationship that reasonably could be expected to give rise to a conflict of interest. A “conflict of interest” is defined as a situation in which a person is in a position to derive personal benefit from actions or decisions made in their official capacity.
Employees and directors must maintain the confidentiality of sensitive or private information entrusted to them. Unauthorized disclosure of any confidential information is prohibited. Additionally, employees should take appropriate precautions to ensure that confidential or sensitive business information, whether it is proprietary to the Company or another company, is not communicated within the Company except to employees who have a need to know such information to perform their responsibilities.
Honest and Ethical Conduct
Employees and directors should deal honestly, ethically and fairly with Wanderwell’s suppliers, customers, competitors, and employees. Statements regarding Wanderwell’s products and services must not be untrue, misleading, deceptive or fraudulent. One must not take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or any other unfair dealing practice.
Accuracy of Books and Records and Public Reports
Employees and directors must honestly and accurately report all business transactions. You are responsible for the accuracy of your records and reports. Accurate information is essential to Wanderwell’s ability to meet legal and regulatory obligations.
Reporting and Compliance Procedures
Every employee, officer and director has the responsibility to ask questions, seek guidance, report suspected violations and express concerns regarding compliance with this Code. Any employee, officer or director who knows or believes that any other employee or representative of the Company has engaged or is engaging in Company-related conduct that violates applicable law or this Code should report such information to his or her supervisor. Such reports should be made without any fear of retaliation. The Company will not discipline, discriminate against or retaliate against any employee who reports such conduct, unless it is found that the report was made with knowledge that it was false, or who cooperates in any investigation or inquiry regarding such conduct.