Code of Business Conduct for Employees

5. Our Customers

     5.1. Tully’s Maintains High Customer Relations Standards

          5.1.a. Tully’s competes fairly and in accordance with the highest ethical standards in all of our customer relationships. We want to earn business on the basis of superior products, excellent service and competitive prices, not through improper, unethical, or questionable business practices.

          5.1.b. Tully’s credibility with our customers depends on our ability to fulfill our commitments. Every time we fail to live up to a commitment, hard-earned customer trust is damaged. To preserve our customer relationships:

• We do not misrepresent our services or products in any sales or promotional efforts. We only make promises to customers that we believe we will be able to keep.
• We communicate clearly so our customers understand the terms of our business relationships, including contracts, performance criteria, schedules, prices, and responsibilities.

     5.2. Tully’s Does Business Properly with Governments in the U.S.

          5.2.a. Doing business with governments in the U.S. is not always the same as doing business with private parties. Activities that might be appropriate when working with private sector customers may be improper or even illegal when a national, state, or local government is our customer.

          5.2.b. Business courtesies or entertainment that might be acceptable when dealing with private parties, like paying for meals, are rarely appropriate when working with government officials. Gifts or courtesies that would not be appropriate for private parties are also not appropriate for government officials.

          5.2.c. Prior to entering into any type of contract negotiation with a government agency in the U.S., contact the Tully’s President or Company Compliance Officer.

     5.3. Tully’s Protects Our Customers' Confidential Information

          5.3.a. Confidential customer information is information the customer or Tully’s would consider private, which is not common knowledge outside the Company, and which employees have learned as a result of Tully’s relationship with that customer. Some types of confidential customer information employees may be exposed to include:

• Names, addresses, phone numbers and email information for our customers and for the employees and customers of our customers;
• Plans, processes, procedures, and trade secrets of our customers;
• Financial, legal or other data of our customers; and
• Any other information, which could be of use to our customers' competitors to place our customers at a competitive disadvantage.

          5.3.b. Confidential customer information may not be disclosed without the prior written authorization from the customer, or in response to the requirements of a court order, subpoena, or other legal action. Employees are required to contact the Company Compliance Officer, President or Chief Financial Officer before disclosing, or agreeing to disclose, any confidential customer information.

     5.4. Tully’s complies with all applicable antitrust and fair competition laws.

          5.4.a. Tully’s policy is to compete vigorously, aggressively, and successfully in a very competitive business climate, and to do so at all times in compliance with the applicable antitrust laws. These laws and regulations are designed to preserve a competitive economy and to promote fair and vigorous competition. Tully’s employees are required to comply with these laws and regulations.

          5.4.b. Fair competition standards are also often a matter of law. Tully’s employees are required to comply with these laws and regulations.

Next Section

Table of Contents