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The policy requires all departments to maintain current, accessible written guidance that addresses legal and regulatory compliance risks and supports the Code of Conduct. The Ethics and Compliance Policy Committee is the sole approver for compliance or Code of Conduct-related implementations. 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All corporate departments must have written policies and procedures that address issues related to compliance with laws and regulations in their areas. These policies and procedures must be current and accessible to affected colleagues.\u003Cbr>2. Department colleagues at all levels are responsible for identifying activities within their areas that should be documented as policies and procedures.\u003Cbr>3. All policies and procedures must be prepared in the format provided as Attachment A.\u003Cbr>4. The Corporate Ethics and Compliance Policy Committee will receive for approval corporate policies and procedures relating to ethics and compliance issues. Only this committee can approve a compliance or Code of Conduct-related policy or procedure for implementation. The committee will meet, on an as needed basis, to hear presentations of proposed policies and procedures.\u003Cbr>5. When it appears the underlying purposes of a particular policy are not achieved by the strict application of the policy to a particular set of circumstances, exceptions to the policy may be granted by either the Company’s Chief Executive Officer (CEO) with the concurrence of the Senior Vice President (SVP) and Chief Ethics and Compliance Officer (CECO) or by the SVP and CECO with the concurrence of the Company’s CEO, President of Operations or Executive Vice President and Chief Financial Officer. If the contemplated exception appears to implicate any laws or regulations, the Legal Department should be consulted before any exception is made. This exception authority is in addition to any exception authority already in particular policies. |\n| PROCEDURE:\u003Cbr>Section I -Development of Policies and Procedures\u003Cbr>1. If areas of potential compliance risk exist within a department or function, the department must determine if it is necessary to have corporate direction with regard to that compliance risk.\u003Cbr>2. If corporate direction is required to minimize the risk of non-compliance, the department must identify whether there is an existing policy that addresses the issue in question. If one exists, ascertain if it is valid (meaning it has been approved by the Ethics and Compliance Policy Committee) and current. If one does not exist or it is invalid, proceed with developing a new policy. If the existing one is not current, proceed with a revision.\u003Cbr>3. The document should be created using the Arial font. The font size should be 11 pitch. The author |\n\n\n| EFFECTIVE DATE: July 1, 2025 | REFERENCE NUMBER: EC.001 |\n| --- | --- |\n| APPROVED BY: Ethics and Compliance Policy Committee |  |\n\nof the document may receive an electronic copy of the policy and procedure template by contacting the Ethics and Compliance department.  \n4. When developing a new or revising an existing policy, consider a readability level equivalent to 8th grade, keep sentences short, focused and simple and use active voice versus passive voice where appropriate. Define the objectives the policy should achieve. Define clearly the steps required to meet the goals of the objective. Ensure accuracy by referring to information provided by regulatory and accrediting agencies, company policy, or applicable laws. Include this information as a reference.  \n5. Complete the top portion of the policy and procedure template","cbCaicUsSM2XJ9Oj","https://ap.wps.com/l/cbCaicUsSM2XJ9Oj","pdf",175636,8,"English","# Policy Overview\n## Scope and Purpose\n# Policy Requirements\n## Policy Content and Exceptions\n# Procedure Guidelines\n## Development and Revision\n## Formatting and Document Sections\n# Approval Process","[{\"question\":\"What is the scope of EC.001 Policy and Procedure Development?\",\"answer\":\"It applies to all corporate departments and all company-affiliated facilities.\"},{\"question\":\"Who approves compliance or Code of Conduct-related policies and procedures?\",\"answer\":\"Only the Ethics and Compliance Policy Committee can approve such policies and procedures for implementation.\"},{\"question\":\"What is required when developing a new or revising an existing policy?\",\"answer\":\"Use the specified Arial font settings, keep sentences short and simple at an 8th-grade readability level, define objectives and clear steps, and include supporting information from regulatory/accrediting agencies, company policy, or applicable laws.\"}]","EC.001 Policy and Procedure Development - Ethics and Compliance | PDF",1789564950]