Code of Ethics

Spencer Renovation and Construction (SRC) Code of Conduct outlines expected behaviors for all SRC employees. SRC expects its employees to act lawfully and with integrity in their dealings with our clients, business partners, government officials, and with each other. SRC will conduct its business fairly, impartially, in an ethical and proper manner, and in full compliance with all applicable laws and regulations. SRC employees are required to comply with all applicable laws, rules, and regulations. The highest standards of ethical business conduct are required of SRC employees in the performance of their company responsibilities. Employees will not engage in conduct or activity that may raise questions as to the company’s honesty, impartiality, or reputation or otherwise cause embarrassment to the company.

Unfair and deceptive business practices are strictly prohibited. SRC engages in responsible business practices and treat all clients fairly, without regard to gender, race, color, religion, national origin, pregnancy, age, marital status, veteran’s status, sexual orientation, or physical or mental disability.

Employees will ensure that:

• They do not engage in any activity that might create a conflict of interest for the company or for themselves individually.
• They do not take advantage of their SRC position to seek personal gain through the inappropriate use of SRC or non-public information or abuse of their position. This includes not engaging in insider trading.
•  They will follow all restrictions on use and disclosure of information. This includes following all requirements for protecting SRC information and ensuring that non-SRC proprietary information is used and disclosed only as authorized by the owner of the information or as otherwise permitted by law.
• They observe that fair dealing is the foundation for all of our transactions and interactions.
• They will protect all company, customer, and supplier assets and use them only for appropriate company-approved activities.
• Without exception, they will comply with all applicable laws, rules, and regulations.
• They will promptly report any illegal or unethical conduct to management or other appropriate authorities (i.e., Ethics, Law, Security, EEO).

SRC and its employees must, at all times, conduct business openly and avoid any situation that might create the appearance that SRC has made any agreement that improperly impacts industry prices or the competition. Because of the nature of our business, SRC possesses sensitive and confidential information about our clients, business partners, our employees and the company itself. All employees have a duty to protect against the disclosure of such information unless disclosure is authorized and within the law.

Every employee has the responsibility to ask questions, seek guidance, and report suspected violations of this Code of Conduct.

Retaliation against employees who come forward to raise genuine concerns will not be tolerated.