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Tracking Innovations Commitments to Customers and Business Partners

Our customers and business partners are essential to our success, and we are dedicated to preserving the trust they have placed in us. We must treat our customers and business partners with fairness and respect at all times. As such, we endeavor to always deal fairly, to compete ethically and to carefully protect our business partners’ confidential information.

Dealing Fairly

Text Box: Q.
I mention to a vendor during contract negotiation that by lowering the price on the current order, 
he will greatly improve the chances that Tracking Innovations will place its next order with his company. I’m not sure this 
is true, but I figure I’m helping our Company obtain the best price possible. Is my behavior acceptable?
A.

No, absolutely not. We must only make statements that are completely true and honest when dealing with vendors. Even though 
your statement may benefit us in the short-term, taking unfair advantage of our vendors and making misrepresentations about 
our Company is unethical. This conduct violates our shared values and our Code.

As a new organization, we must compete vigorously in order to gain a strong foothold in the marketplace. However, at no time may our competitive methods be anything other than ethical and lawful. This requires that we be truthful and honest when interacting with others on Tracking Innovations’ behalf.

In particular, our marketing and sales practices must always be fair. This means we may not misrepresent the quality, features or availability of our products and services. In addition, we may never make statements about our competitors’ products or services that are false or misleading, or make comparisons that are unfair or unsupported.

Dealing fairly also means we keep our word to our customers, vendors and other business partners and fulfill all contracts according to their exact specifications. We always use honorable means to meet and exceed these parties’ reasonable expectations. In the same spirit, we do not take on work that we are unable to fulfill. At all times, we strive to establish our Company’s reputation in the marketplace as an organization that is fully committed to doing business with integrity.

Following Competition Laws

We are striving to become key players in the global marketplace. As such, we must strictly follow free market rules, which ensure that only objective factors (such as quality and price) determine who succeeds and who fails. In short, this means we may never violate applicable competition laws, which include U.S. antitrust laws and competition laws in effect in the other countries where we do business. Text Box: Q.
I know that one of my fellow associates previously worked for a competitor. I would like to ask him about the 
former employer’s business practices, as I think some of the information could really give Tracking Innovations a competitive edge in 
an upcoming bid. Is this okay?
A.
No, it is inappropriate to ask an associate for confidential information regarding a 
previous employer, no matter what the reason. Just as we are obligated to protect Tracking Innovations’ confidential information after 
we’ve left our Company, he must also protect his former employer’s information.

Competition laws prohibit us from entering into discussions with our competitors regarding fixing prices, allocating markets, dividing customers or otherwise restricting competition. In addition, we may not enter into formal or informal agreements with customers, vendors or other business partners that may limit competition, such as agreements to tie products, fix resale prices or refuse to sell to particular customers or buy from particular vendors.

We must always exercise particular caution when attending industry association meetings, as conversing with competitors carries a risk of violating competition laws. These meetings provide excellent opportunities for networking and business development, but you should be careful to avoid both formal and informal discussions regarding prices, discounts, boycotts, terms and conditions of sale, standardization of terms, warranties or product specifications. If any of these topics arise, you should stop the conversation immediately and report the situation to our CIO.

Gathering Competitive Information

To compete effectively, we must know what our competitors are doing. Although it is certainly appropriate to gather competitive information, we must always make sure we do so ethically and legally. Generally speaking, we may gather and use competitive information that is publicly available, including information from newspaper or magazine articles, corporate financial reports and non-confidential proposal information. However, it is inappropriate to use inadvertently disclosed confidential information or competitive bid information. In addition, it is unethical and oftentimes illegal to seek to obtain such information. If you possess competitor information that you believe was sent to you inadvertently or was obtained in an unethical or illegal manner, contact our CIO immediately.

Always be cautious when requesting competitive information from a fellow associate about a prior employer. Confidential information about prior employers should stay confidential even after that employment relationship ends.

Keeping Customer and Third-Party Information Secure

We are also responsible for protecting confidential information belonging to our customers, vendors and other business partners that we acquire through the work we do on behalf of Tracking Innovations. We must never disclose this information to unauthorized persons, even after our employment with our Company ends.

In addition, we must respect all intellectual property belonging to others, including information relating to software licenses and publications. When an invention, product, idea, written work, logo or name is owned by another company or an individual, we may only use that property if we have obtained prior express permission from its owner.

If you have any questions regarding your responsibility to protect third-party confidential information, please consult our CIO.