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Code of Ethics for the Principal Executive Officer and Senior Financial Officers |
Phoenix Aviation Managers, Inc. (the "Company") is committed to conducting
its business in compliance with applicable laws and regulations and in accordance
with high standards of business
conduct.
In managing its business, the Company is
mindful of the public trust with which it is vested. The Company strives to maintain high standards of accuracy, completeness and disclosure in its financial dealings,
records and reports. These standards are intended to protect and preserve the multiple
interests of its policyholders and beneficiaries of their insurance policies, and
the Company’s stockholders, employees and other stakeholders. To these ends, it
is the responsibility of the Company’s Chief Executive Officer, Chief Financial
Officer and principal accounting officer (the "Senior Financial Officers") to:
1. Act in good faith, in the Company’s best interests and in accordance with the
Company’s Code of Conduct and the principles of this Code of Ethics.
2. Act with honesty and integrity and in an ethical manner, avoiding actual or apparent
conflicts of interests in personal and professional relationships.
3. Provide full, fairly stated, timely and understandable financial information
and disclosure in reports and documents that the Company files with, or submits
to regulatory authorities and shareholders, in accordance with applicable rules
and regulations.
4. Act responsibly, with due care, competence and diligence, without misrepresenting
material facts or allowing his or her independent judgment to be compromised.
5. Use good business judgment in ensuring that all financial transactions are processed
and recorded in timely fashion with reasonable accuracy and documentation in the
Company’s books and records in adherence with sufficiently appropriate and necessary
internal controls.
6. Respect and protect the confidentiality of information acquired in the course
of the Company’s business, except when authorized or otherwise legally obligated
to disclose such information, and not use confidential information acquired in the
course of work for personal advantage.
7. Promote ethical behavior among constituents in the work environment through appropriate
communications and by setting a proper example.
8. Achieve responsible use of and control over all assets and resources employed or entrusted to him or her.
9. Comply with generally accepted accounting principles and, as necessary, regulatory
accounting practices, rules, regulations and controls applicable to the Company’s
reports and related disclosures.
10. Sign only those documents that he or she believes to be accurate and truthful
in all essential respects.
11. Prohibit the establishment of any undisclosed or unrecorded funds or assets
for any purpose and provide for the proper and prompt recording of all disbursements
of funds and all receipts.
12. Not knowingly be a party to any illegal activity or engage in acts that are
discreditable to his or her profession or the Company.
13. Respect and contribute to legitimate and ethical objectives of the Company.
14. Not make, or tolerate any willfully false or artificial statements or entries
for any purpose in the books and records of the Company or in any internal or external
correspondence, memoranda, or communication of any type, including telephone or
wire communications.
15. Report to the Company, through the Audit Committee any significant situation with respect to which this Code of Ethics, the Company’s standards or laws are being
violated.
Those required to comply with this Code of Ethics understand that failure to comply
with this Code of Ethics will not be tolerated by the Company and that deviations
therefrom or violations thereof will result in serious consequences, which may include,
but may not be limited to, serious reprimand, dismissal or other legal redress.
The parties subject to this Code of Ethics will acknowledge in writing that they
understand and will adhere to these requirements.
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