Business records and communications often become public, and we should avoid exaggeration, derogatory remarks, guess work, or inappropriate characterizations of people and companies that can be misunderstood. This applies equally to e-mail, internal memos, and formal reports….
In accordance with these policies, in the event of litigation or governmental investigation please consult with the company’s General Counsel.
Have your actions been in complete compliance with the above provisions?
Have you avoided exaggeration?
Have you avoided derogatory remarks?
Have you avoided guess work?
Have you avoided inappropriate characterizations of people and companies that can be misunderstood?
When you received your SEC subpoena, did you promptly inform the Company’s General Counsel?
When you received your SEC subpoena, did either you or the company’s general counsel promptly inform Overstock.com’s Audit Committee?
Sam E. Antar (former Crazy Eddie CFO & convicted felon)
I quote from Overstock.com’s Code of Business Conduct and Ethics, as adopted by the Company’s Board of Directors on 01/23/04:
“We are firmly committed to providing equal opportunity in all aspects of employment and will not tolerate illegal discrimination or harassment of any kind. Examples include derogatory comments based on racial or ethical characteristics and unwelcome sexual advances.”
How carefully was Overstock.com's Code of Business Conduct and Ethics drafted?
Is there a typo?
The document states “…comments based on racial or ethical characteristics….”
Should it be “…comments based on racial or ethnic characteristics….”? (Note: Bold and italic print added by me.)
PS: If it is a typo, I understand that typos sometimes happen.
However, Overstock.com's Code of Business Conduct and Ethics is an important legal document governing your company’s business and ethical conduct.
Is the company paying close attention to its Code of Business Conduct and Ethics?
Gary Weiss Blog: Judd Bagley Hears his Master's Voice
Tracy Coenen: Preserving a little piece of Sith Lord History (Yes, Overstock.com again)