PURPOSE OF THE CODE
The M & F Worldwide Corp. Code of Business Conduct (the ‘‘Code’’) describes the basic legal and ethical principles that guide the conduct of the Company’s business. The Code also provides a general description of certain key policies and procedures that implement these principles. The Code applies to all of M&F Worldwide Corp.’s business units and subsidiaries. Therefore, all references in the Code to ‘‘the Company’’ include all business units and subsidiaries. Employees should refer to the Company’s written corporate policies for the full texts of applicable policies and procedures.
The most basic principle of the Code is that all business conducted by the Company and the people who are employed or retained by the Company must meet high standards of business and personal ethics, in addition to complying with the letter and spirit of all applicable laws, regulations and policies.
Failure to comply with the standards contained in the Code can damage the Company’s good name, trade and customer relations and business opportunities. In addition, conduct that violates applicable laws or regulations can subject the individuals involved and the Company and its officers to civil liabilities and, in many cases, to prosecution, imprisonment or fines. Therefore, the Company intends to prevent conduct that does not comply with the Code, to halt any such conduct that may occur as soon as reasonably possible after its discovery, and to discipline those who violate the Code and the Company’s related policies and procedures, including individuals who fail to exercise proper supervision and thereby fail to detect a violation by their subordinates. Such discipline may include, where appropriate, termination of employment with the Company, forfeiture of any benefit or right that is forfeitable upon termination for cause, referral of individual misconduct for criminal prosecution and commencement of civil proceedings for reimbursement of any loss or damage resulting from a violation. In all matters involving disciplinary action, principles of fairness will apply.
For convenience, the Code is drafted to refer to Company employees, but ‘‘employees’’ should be read to include also every director, officer, consultant and agent of the Company, unless the context clearly indicates otherwise. Please provide copies of the Code, available from the Corporate Compliance Officer, to consultants and agents retained to provide services to which the Code is applicable.
THE CODE IS A STATEMENT OF POLICIES FOR INDIVIDUAL AND BUSINESS CONDUCT AND DOES NOT, IN ANY WAY, CONSTITUTE AN EMPLOYMENT CONTRACT OR AN ASSURANCE OF CONTINUED EMPLOYMENT.
EMPLOYMENT WITH THE COMPANY IS A VOLUNTARY, AT-WILL RELATIONSHIP WHICH CAN BE TERMINATED BY EITHER THE COMPANY OR THE EMPLOYEE AT ANY TIME, WITHOUT NOTICE, AND FOR ANY REASON, EXCEPT AS APPLICABLE LAW OR A WRITTEN AGREEMENT OTHERWISE PROVIDES.
Questions, concerns or complaints regarding the Code may be directed to the Company’s 24-hour Hotline at (877) 787-8714 or via email to compliance@mandfworldwide.com. Employees located outside of the United States may reach the Hotline by dialing the toll-free international number made available at each international location of the Company. Employees located in the United States may choose to report concerns anonymously. In some countries where the Company has operations, local laws or regulations may prohibit or discourage anonymous reporting of violations. Therefore, employees located outside of the United States should consult with their business unit’s Compliance Officer or the Hotline to determine whether anonymous reporting is permitted and should consult all special rules that apply to reporting a violation in that country. The Company has special rules for reporting alleged violations of the Code or the law with respect to its operations in France. Employees located in the Company’s French operations should consult and adhere to those special reporting rules. All reported violations will be handled with care and will receive a diligent and thorough investigation and review.
