T.E.A.M.'s Code of Ethics
TEAM’s corporate philosophy is founded upon high ethical standards and professional responsibility. Each and every individual within our organization is required to observe these principles. TEAM is committed to conducting its business in accordance with applicable laws, rules and regulations and the highest standards of business ethics so as to earn the public trust. TEAM shall make full and accurate financial disclosure in compliance with applicable laws, rules and regulations.
This TEAM Code of Business Conduct and Ethics (the “Code”) applies to all members of Senior Management (which includes the Chief Executive Officer, President, and all Executive Vice Presidents), the Chief Accounting Officer, the Controllers (including persons performing similar functions), officers at any level and all employees.
As members of TEAM, each employee has a responsibility to conduct themselves in an honest and ethical manner. In particular, members of Senior Management and all officers have leadership responsibilities that include creating a culture of high ethical standards and commitment to compliance, maintaining a work environment that encourages employees to raise concerns, and promptly addressing employee compliance concerns.
Good judgment, fairness and personal integrity are the qualities that form the basis of our Code. Employees of TEAM must refrain from any activities that would violate TEAM's ethical standards. They should also refrain from requesting or causing others to violate these ethical standards. In any case where there is a question about whether an activity is prohibited, it should be reviewed in advance with a member of Senior Management.
This Code contains both general guidelines for conduct, as well as specific rules.
Compliance with Laws, Rules and Regulations
Each TEAM employee is required to comply with all applicable laws, rules and regulations (which are collectively referred to as “Laws”) governing the conduct of TEAM's business and to report any suspected violations of applicable Laws to any member of Senior Management.
This includes, but is not limited to:
- Compliance with environmental Laws;
- Compliance with Laws relating to equal employment opportunity, including providing a work environment free of unlawful harassment, and recruiting, hiring, training, compensating, promoting and providing other conditions of employment without regard to a persons race, color, religion, sex, disability, age, national origin, veteran status, or other classification protected by law; and
- Compliance with Laws relating to fair housing, including using standard, nondiscriminatory criteria in leasing to tenants.
Consequences for Code Violations
Violations of this Code may result in disciplinary action, up to and including discharge and prosecution. Senior Management, as necessary, shall determine, or shall designate appropriate persons to determine, appropriate action in response to violations of this Code.
Confidentiality and Reputation
Except as required by Law, an employee may not disclose the names, addresses, phone numbers or any personal information about the officers or directors of TEAM.
TEAM employees may not make any statement or take any action that would publicly discredit TEAM’s integrity or position of public trust. They may not disclose to any non-TEAM person any material information relating to TEAM that has not been disclosed to the general public. Such information must be kept in strict confidence and should be discussed only with persons who have a need-to-know basis for the information, for a legitimate business purpose. TEAMs confidential information, including information that is proprietary to it and its business may not be disclosed to any non-TEAM person.
Employees may not disclose to any non-TEAM person any information about a resident unless it is in compliance with TEAM policy and procedure, or required by law.
Compliance with the Code
If an employee knows of or suspects a violation of this Code or of any other TEAM policy, they must immediately report that information to a member of Senior Management. No one will be subject to retaliation because of a good faith report of a suspected violation.
It is a violation of this Code knowingly to provide false information to management or refuse to cooperate with management during an investigation of violations of this Code or unlawful activities.
Financial Reporting and Disclosures
It is TEAM policy to make full, fair, accurate, timely and understandable disclosure, to its investors as per their contractual obligation, in compliance with all applicable laws and regulations in all reports and documents that TEAM or any of its subsidiaries files with the State of Texas and in all other public communications made by TEAM. This includes compliance with TEAM standards, policies and procedures designed to promote compliance with this policy.
A TEAM employee may not:
- Intentionally record an income, expense, or other transaction inaccurately in order to misstate any material facts, or achieve some personal gain.
- Enter into a transaction or advance funds without appropriate authorization.
- Directly or indirectly take any action to fraudulently influence, coerce, manipulate or mislead TEAM's independent public accountants for the purpose of making the financial statements of TEAM or its subsidiaries misleading.
No Rights Created
This Code is a statement of certain fundamental principles, policies and procedures that govern TEAM’s Senior Management (which includes the Chief Executive Officer, President, and all Executive Vice Presidents), Chief Accounting Officer, Controllers (including persons performing similar functions), officers at any level and all employees in the conduct of TEAM’s business. It does not, nor is it in any way intended to, create any rights in any employee, resident, customer, supplier, competitor, shareholder, or any other person or entity.
Avoiding Conflicts of Interest and Protecting T.E.A.M.’s Assets
A conflict of interest occurs when an employee’s private interests interfere in any way with the interests of TEAM as a whole. An appearance of impropriety involving an actual or potential conflict of interest should also be avoided. TEAMs employees are expected to conduct business in an honest and ethical manner, which includes the ethical handling of actual or apparent conflicts of interest between personal and professional relationships. Before making any investment, accepting any position or benefits, participating in any transaction or business arrangement or otherwise acting in a manner that creates or appears to create a conflict of interest, full disclosure must be made to and written approval obtained from Senior Management (unless otherwise specified below).
Avoiding conflicts of interests and protecting TEAMs assets also means that an employee may not:
Accept a Business Entertainment (as defined below) if such Business Entertainment is worth more than a nominal amount (as defined below), or unless such Business Entertainment is specifically approved in advance by Senior Management after full disclosure. In the event of any inadvertent or unintentional acceptance of a Business Entertainment in violation of this directive, the employee shall have seven (7) days within which to make full disclosure of the circumstances to Senior Management. A “Business Entertainment” is a meal or entertainment provided for by anyone who does business with or seeks to do business with TEAM or who is a resident of a TEAM managed property. In the case of a Business Entertainment or a Gift (as defined below), “nominal” generally means less than $25, and such a Business Entertainment or Gift is something ordinarily used in establishing or maintaining business relationships or in a sales promotion, such as ordinary business meals and reasonable entertainment, services or gifts consistent with local social and business customs.
Accept a Gift (as defined below) if such Gift is worth more than a nominal amount (as defined above), or unless such Gift is specifically approved in advance by Senior Management after full disclosure. In the event of any inadvertent or unintentional acceptance of a Gift in violation of this directive, the employee shall have seven (7) days within which to make full disclosure of the circumstances to Senior Management. A “Gift” is a service or gift from anyone who does business with or seeks to do business with TEAM or who is a resident of a TEAM managed property.
Accept any fee, commission, payment or gratuity, from anyone who does business with or seeks to do business with TEAM or is a resident of a TEAM managed property.
Make or offer, directly or indirectly, anything of value (such as a bribe or kickback or a lavish gift which could be viewed as a bribe or kickback). A business courtesy, such as a gift, contribution or entertainment, should never be offered under circumstances that might create the appearance of impropriety.
Engage in any activity that would conflict with or detract from the employees ability to carry out their assigned duties and responsibilities.
Do business with, or authorize a TEAM property to do business with, any vendor who employs a relative of an employee without notifying and receiving prior written approval from Senior Management.
Have any material personal interest in any vendor who does business with any TEAM property.
Participate in any outside business activity with a person that the employee has met through their employment at TEAM without notifying and receiving prior written approval from Senior Management.
Use or take any property that belongs to TEAM or one of its properties without proper authorization.
Make any political contributions for, on behalf of, or in the name of, TEAM, or seek direct or indirect reimbursement for contributions made in any form. TEAM encourages all employees to exercise their individual rights of citizenship by voting, by making personal political contributions if they wish to do so with their own funds and by being otherwise politically active, in support of candidates or parties of the employees own personal selection. Such political activity by employees must be performed strictly in their individual and private capacity and not on behalf of TEAM or with the use of TEAM resources.