Responsibility and Accountability
Our Responsibility To: Each Other
Our Responsibility To: Clients And Consumers
Our Responsibility To: Business Partners
Our Responsibility To: Shareholders
Our Responsibility To: Competitors
Our Responsibility To: Communities
Our Responsibility To: Governments
Conflicts of Interest
Code of Business Ethics and Conduct Confirmation
How to Get Help
The company is dedicated to supplying clients with high quality products and services,
serving fairly the interests of stockholders and associates, dealing fairly with suppliers
and competitors and fulfilling its social responsibilities. This Code of Business Ethics and
Conduct is a guide to help associates (part-time and full-time), officers, directors and
temporary staff live up to the company’s high ethical, fiscal, and general business
standards. The code should also be provided to and followed by the company’s agents
and representatives, including consultants.
The code strives to deter wrongdoing and promote the following objectives:
- Honest, ethical and respectful conduct, including the ethical handling of actual or
apparent conflicts of interest between personal and professional relationships;
- Full and accurate disclosure of fact or information during the course of company
- Full, fair, accurate, timely and understandable disclosure in reports and
documents filed with or submitted to the Securities and Exchange Commission
and in other public communications made by the company;
- Compliance with all applicable laws, rules and regulations;
- Prompt internal reporting of code violations; and
- Accountability for compliance with the code.
This code sets our general principles but does not cover every situation that may arise.
For many topics included in this Code of Business Ethics and Conduct, a policy
summary exists with further detailed information. Our associates, officers, directors and
temporary staff should not only conduct themselves in accordance with the code, but
also avoid the appearance of improper behavior. A person who violates this code will be
subject to disciplinary action, up to and including termination.
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Responsibility and Accountability
All associates and officers of the company are responsible for conducting themselves in
compliance with this Code of Business Ethics and Conduct, other company policies and
applicable laws and regulations. This Code of Business Ethics and Conduct applies to all
associates, part-time and full-time, and officers as well as contractors and temporary
staff. In addition, all members of the Board of Directors, in regard to their Company
duties, are responsible for conducting themselves in accordance with the provisions of
this Code of Business Ethics and Conduct, other company policies and applicable laws
This code is neither a contract nor a comprehensive manual that covers every situation
company associates, officers, directors and temporary staff might encounter. It is a guide
that highlights key issues and identifies resources to help associates, officers, directors
and temporary staff, reach business decisions that are in line with the company's values.
Each associate, officer, director and temporary staff person is expected to read the
entire Code of Business Ethics and Conduct and be familiar with the laws and guidelines
that apply to his/her position. Each associate, officer, director and temporary staff person
must adhere to the spirit as well as the letter of these laws and guidelines. Keep in mind
that failure to abide by this code and the law may lead to disciplinary measures
appropriate to the violation, up to and including termination.
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After reading the code, each associate, officer, director and temporary staff person must
acknowledge that he/she has read, understands, and to the best of his/her knowledge is
adhering to the code, by submitting a code confirmation, which is attached hereto. If
such person's circumstances should change, an updated confirmation should be
completed and submitted. Compliance issues and violations must be promptly reported
to management personnel or to the company anonymously through the Valassis
Corporate Governance Hotline at 1-800-789-5409.
Confidentiality regarding those who make compliance reports, and those potentially
involved, is maintained to the extent possible during a compliance investigation. The
company will not tolerate retribution, retaliation or adverse personnel action of any kind
against anyone for lawfully reporting a situation of potential noncompliance, or providing
the company or law enforcement or other governmental agency any information or
assistance relating to the commission of any state or federal offense or breach or
company policy. Those wishing to report compliance problems may call the company's
toll-free compliance assistance service, the Valassis Corporate Governance Hotline at 1-
800-789-5409. All “hotline" reports shall be delivered to the Legal Department and
Internal Audit for review and appropriate dissemination and attention.
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The company’s values define who we are - as individuals and as a company. This Code
of Business Ethics and Conduct is based on these values, and each of the company’s
associates, officers, directors and temporary staff is expected to demonstrate these key
beliefs in our work.
- Accountability for Results
- Client Impact
- Collaborative Partnerships
- Diversity and Inclusion
- Profitability and Business Focus
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1.0 OUR RESPONSIBILITY TO: EACH OTHER
The company values its associates, officers, directors and temporary staff and
We respect the dignity of every associate, officer, director and temporary staff
person. We will treat each other with respect and fairness at all times, just as we
wish to be treated. We will value the difference of diverse individuals from around
the world. Employment decisions will be based on business reasons, such as
qualifications, talents and achievements, and will comply with local, national and
international employment laws.
Equal Employment Opportunity and Benefits
The company is committed to providing equal benefits to all persons regardless
of race, sex, age, religion, color, national origin, marital status, sexual orientation,
physical and mental disability or veteran status. See policy WE07 EEO &
Respectful Atmosphere for further information.
Abusive, harassing or offensive conduct, including threats or acts of violence or
physical intimidation, is unacceptable. Examples include derogatory comments
based on racial or ethnic characteristics and unwelcome sexual advances. We
are encouraged to speak out when a coworker's conduct makes us
uncomfortable, and to report harassment when it occurs. See policy WE13
Sexual and Other Harassment for further information.
Safety and Health
The company strives to provide and we are all responsible for maintaining a safe
workplace by following safety and health rules and practices. We are responsible
for immediately reporting accidents, injuries, and unsafe equipment, practices or
conditions to a supervisor or other designated person. The company is
committed to keeping its workplaces free from hazards.
In order to protect the safety of all associates, officers, directors and temporary
staff, each of us must report to work free from the influence of any substance that
could prevent us from conducting work activities safely and effectively. See
policy WE18 Work Related Injury & Illness for further information.
Associates, officers, directors and temporary staff are prohibited from heeding,
repeating or acting on rumors about another person or the company.
All personnel records will contain only information needed for business or legal
purposes, and will not be divulged to outsiders without the affected person's
approval except to verify employment or to comply with legal requirements.
Only authorized persons may have access to personnel records and then, only
after receiving permission from the Human Resources Department. Associates,
officers, directors and temporary staff may inspect their records according to
Work Time Reporting and Time Off
Associates will be productive and focused on business matters throughout the
course of each work day and have prompt and regular attendance.
Additionally, associates must not falsify records, including time worked, or
misrepresent reasons for absence, tardiness or use of other time-off benefits.
Associates, officers, directors and temporary staff will respect the confidentiality
of information entrusted to them or acquired in the course of their work, except
when authorized by a leader or executive officer of the company or otherwise
legally obligated to disclose. Confidential information acquired in the course of
one's work is not to be used for personal advantage. Divulging information that
may not be in the best interest of the Company or associates, officers, directors
or temporary staff will not be tolerated. This includes an associate’s participation
in confidential investigations and any information discussed during the
investigation. Confidential information includes all non-public information and
information that might be of use to competitors or harmful to the company or its
customers if disclosed. The obligation to preserve confidential information
continues even after employment ends.
Associates, officers, directors and temporary staff will act in good faith,
responsibly, with due care, competence and diligence, without misrepresenting
material facts or allowing their independent judgment to be subordinated.
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2.0 OUR RESPONSIBILITY TO: CLIENTS AND CONSUMERS
The Company exists to satisfy its customers.
Product Quality and Safety
To maintain the company’s valuable reputation, compliance with our quality processes and safety requirements is essential. We damage our good name when we deliver products or services that fail to live up to company’s standards.
Sales and Marketing
We will build long-term relationships with our clients by demonstrating honesty
and integrity. All of our marketing and advertising will be accurate and truthful.
Deliberately misleading messages, omissions of important facts, or false claims
about our competitors' offerings are never acceptable. We will only obtain
business legally and ethically. Bribes or kickbacks are not acceptable. For further
guidance, see Section 8.0, Conflicts of Interest.
We must protect client information that is sensitive, private or confidential just as
carefully as our own. Only those who have a need to know should have access
to confidential information. For further guidance, see Section 1.0, Confidentiality.
Disclosure of Client Information
Client information is defined as any materials provided by the client to the
company or that the company may develop for the exclusive use of the client.
These materials include but are not limited to: sample pieces; volume by in-home
date, month, and year; frequency by market, region, and company; response
rates; product pricing; revenue; products; anticipated mail dates; profiles;
targeting zones and data; redemption information and data; annual client spend,
or client strategy.
Client material (i.e., client pieces processed through the company) may not be
distributed to company associates or temporary staff, (except as necessary to
service the client) or non-company persons prior to the client’s material in-home
date. On the first day of the client's material in-home date, client material may be
distributed to Valassis associates and temporary staff and non-Valassis persons
for use as sample pieces to promote selling efforts, except where explicitly
prohibited. A client's sample piece cannot be distributed to the client's
competitor(s) until the first day of the client's material in-home date, except where
explicitly allowed to the contrary
The company and its associates, officers, directors and temporary staff, agents,
and representatives will not duplicate or use any client information except as
specifically authorized by the client. The company will not permit any other
person to duplicate or use any client information except as necessary to service
the client or as otherwise expressly authorized by the client.
The company will take all reasonable action to ensure the security of client
information and will establish and maintain procedures and facilities reasonably
designed to protect the privacy and confidentiality of client information.
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3.0 OUR RESPONSIBILITY TO: BUSINESS PARTNERS
Building quality relationships with other companies gives the company a
Doing Business with Others
We will not do business with others who are likely to harm the company’s
reputation. For example, we will avoid doing business with others who
intentionally and continually violate the law. These laws include, for example,
local environmental, employment, safety and anti-corruption statutes. All
arrangements with third parties must comply with company policy and applicable
law. We will not use a third party to perform any act prohibited by law or by this
Agents and Consultants
Commission rates or fees paid to dealers, distributors, agents, finders or
consultants must be reasonable in relation to the value of the product or work
that is actually being done. We will not pay commissions or fees that we have
reason to believe will become bribes.
Subcontractors play a vital role in the fulfillment of many of our contracts. In
some cases, the subcontractor is highly visible to our customers. It is therefore
very important to ensure that our subcontractors preserve and strengthen the
company’s reputation by acting consistently with this code.
Joint Ventures and Alliances
The company will strive to ally with companies that share our commitment to
ethics. We will also work to make the standards of our joint ventures compatible
with our own.
Purchasing decisions must be made based solely on the company’s best
interests. Suppliers win the company’s business based on product or service
suitability, price, delivery and quality. Purchasing agreements should be
documented and clearly identify the services or products to be provided, the
basis for earning payment, and the applicable rate or fee. The amount of
payment must be commensurate with the services or products provided.
Under no circumstances will the company expect or authorize any associate,
officer, director or temporary staff person to offer payments of any kind to induce
a purchaser to buy its products, or to pay more for them than the established
The Company has developed a Supplier Diversity Vendor program to increase
the overall number of minority supplier vendors with whom we do business and
to strengthen the base of suppliers for consideration
Associates, officers, directors and temporary staff will not mislead, intentionally
misinform, lie to or withhold relevant information from any customer, vendor or
the company itself in the course of doing their job.
If the client is also a supplier, purchase of the company's products will not be a
condition of the company’s patronage.
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4.0 OUR RESPONSIBILITY TO: SHAREHOLDERS
We will treat the investment of our shareholders as if it were our own.
Protecting the Company’s Assets
We have a responsibility to protect the company’s assets from loss, damage,
misuse or theft. The company’s assets, such as funds, products, or computers,
may only be used for business purposes and other purposes approved by
management, including incidental personal use. The company's assets may
never be used for illegal purposes.
Loan of company funds to associates, officers, directors or other staff is strictly
prohibited except as permitted by specifically authorized company-benefit plans.
The obligation of associates, officers, directors and temporary staff to safeguard
company assets includes the protection of proprietary information. Such
proprietary information includes intellectual property such as trade secrets,
patents, trademarks and copyrights, as well as business, marketing and service
plans, engineering and manufacturing ideas, designs, databases, records, salary
information and any unpublished financial data and reports.
You may protect such proprietary information by marking it accordingly, keeping
it secure, and limiting access to those who have a need to know in order to do
their jobs. Proprietary also includes information that suppliers and clients have
entrusted to us. The obligation to preserve proprietary information continues
even after employment ends. Unauthorized dissemination of this information
would be a violation of policy and may be illegal or result in civil or criminal
Inside Information and Securities Trading
Associates, officers, directors and temporary staff are not allowed to trade in
securities or any other kind of property based on knowledge that comes from
their jobs, if that information hasn't been reported publicly. It is against the laws of
many countries, including the United States, to trade or to "tip" others who might
make an investment decision based on inside job information. For example,
using non-public information to buy or sell company stock, options in company
stock or the stock of a company supplier or client is prohibited.
Whether or not an associate, officer, director or temporary staff person may use
inside information often requires legal clarification; therefore, associates, officers,
directors and temporary staff should consult with the Legal Department and
review the LE04 Insider Trading Policy and LE05 Addendum Insider Trading
Disclosure Controls and Record Keeping
We require honest, accurate and complete recording and reporting of information
in order to make responsible business decisions. This includes such data as
quality, safety, and personnel records, as well as all financial records. The
company follows the accepted accounting rules and controls set forth by the U.S.
Securities and Exchange Commission (SEC) and the Financial Accounting
Standards Board. The company requires honest and accurate recording and
reporting of information in all circumstances, without exception. The company
requires that its certified public accountants have access to any and all
information necessary for them to conduct audits properly.
Business expense accounts used by associates, officers, directors and
temporary staff must be documented and recorded accurately. All of the
company's books, records, accounts and financial statements must be
maintained in reasonable detail, must appropriately reflect the company's
transactions and must conform both to applicable legal requirements and to the
company's system of internal controls. Unrecorded or "off the books" funds or
assets should not be maintained unless permitted by applicable law or regulation
and approved in writing by our Chief Financial Officer. Any associate with
information about inaccurate company records, unrecorded funds or assets, or
any misappropriation of the company assets must promptly notify the Chief
Financial Officer, the Legal Department or the Valassis Corporate Governance
Hotline at 1-800-789-5409.
The company must disclose to the SEC, our current security-holders and the
investing public certain information under applicable laws, regulations or rules,
and any additional information that may be necessary to ensure that the required
disclosures are not misleading or inaccurate. The company requires associates
to participate and fully cooperate in this disclosure process.
Recording and Retaining Business Communications
All business records and communications should be clear, truthful and accurate.
Business records and communications often become public through litigation,
government investigations and the media. We will avoid exaggeration, colorful
language, guesswork, legal conclusions and derogatory remarks or characterizations of people and companies. This applies to communications of all kinds, including e-mail and "informal" notes or memos. Records should always be retained and destroyed according to the company’s record retention policies.
In accordance with those policies, in the event of litigation or governmental
investigation, threatened or known, please consult our Legal Department or other
executive officer of the company. See LE06 Document Retention Policy for
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5.0 OUR RESPONSIBILITY TO: COMPETITORS
We compete aggressively and with integrity at the same time.
We must never use illegal or unethical methods to gather competitive
information. Stealing proprietary information, possessing trade secret information
that was obtained without the owner's consent, or inducing such disclosures by
past or present associates of other companies is prohibited. If information is
obtained by mistake that may constitute a trade secret or confidential information
of another business, or if there are questions about the legality of information
gathering, associates should consult the Legal Department.
Fair Competition and Antitrust
The company believes that the success of the private enterprise system depends
upon fair competition, which, by encouraging productivity and efficiency, tends to
improve products. The company supports the antitrust and unfair competition
laws that are designed to foster competition and thus benefit both business and
Associates, officers, directors and temporary staff should become familiar with
the basic provisions of these laws that are applicable to their jobs. Information
regarding these laws may be obtained by contacting the Legal Department.
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6.0 OUR RESPONSIBILITY TO: COMMUNITIES
The company is a responsible citizen in all the communities where we do
As a company, we strive to serve society by providing consumers with products
to help them save time and money, and by actively supporting the communities
in which we operate. Company associates, officers, directors and temporary staff
across the country provide generous financial and voluntary support to
worthwhile community programs.
Personal Community Activities
Company associates, officers, directors and temporary staff are free to support
community, charity and political organizations and causes of their choice, as long
as they make it clear that their views and actions are not those of the company.
We must ensure that our outside activities do not interfere with our job
No associate, officer, director or temporary staff person may pressure another
associate, officer, director or temporary staff person to express a view that is
contrary to a personal belief, or to contribute to or support political, religious or
We will respect the environment by operating our facilities in accordance with
clean air, clean water and resource conservation standards, laws, and
regulations. The company has designated the EVP Manufacturing & Client
Services as champion for Environmental, Health and Safety to further company
efforts in this area. Any associate, officer, director or temporary staff person with
knowledge of possible violations should notify his/her leader or call the Valassis
Corporate Governance Hotline at 1-800-789-5409.
Communicating to External Audiences
To ensure professional and consistent handling and compliance with the law,
requests from the media must be forwarded to Corporate Communications.
Through proper channels, the company will cooperate with reasonable requests
for information from government agencies and regulators. Corporate
Communications and Investor Relations should consult with the Legal
Department before responding to any non-routine requests. All information
provided must be truthful and accurate. We will not alter or destroy documents or
records in response to an investigation or other lawful request. Requests from financial analysts and shareholders must be forwarded to Investor Relations.
Please refer to SM13 External Communications Policy for more specific
guidelines and details regarding external communications.
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7.0 OUR RESPONSIBILITY TO: GOVERNMENTS
As a responsible citizen, it is our obligation to obey the law.
Compliance With the Law
Company associates, officers, directors and temporary staff are required to
comply with all applicable laws and regulations wherever we do business.
Perceived pressures from leaders or demands due to business conditions are not
excuses for violating the law. When associates have any questions or concerns
about the legality of an action, they are responsible for checking with a member
of the leadership team, Human Resources, the Legal Department or the Valassis
Corporate Governance Hotline at 1-800-789-5409.
Responding to Government Requests
Associates, officers, directors and temporary staff are expected to respond
truthfully to governmental inquiries. It is the company's policy to cooperate with
all reasonable requests from governmental agencies concerning the company's
business operations. Any associate learning of a governmental inquiry should
promptly report the inquiry to the Legal Department.
Company Political Activities
The company believes in and supports the democratic political process and
provides government agencies with business information and, within legal and
ethical bounds, voices its opinions on issues affecting the company, its
stockholders, associates, officers, directors and temporary staff, the communities
in which it operates, and the business community.
The company's Political Action Committee (PAC) may make contributions
consistent with all applicable laws and regulations.
No company associate, officer, director or temporary staff person may, except
with approval from the Government Relations Office, make any political
contribution for the company or use the company’s name, funds, property,
equipment or services for the support of political parties, initiatives, committees
or candidates. This includes any contribution of value. Additionally, lobbying
activities or government contacts on behalf of the company, other than sales
activities, should be coordinated with the Government Relations Department.
The company will comply with anti-corruption laws. Associates, officers, directors
and temporary staff will not directly or indirectly offer or make a corrupt payment
to government officials, including employees of state-owned enterprises. The
U.S. Foreign Corrupt Practices Act prohibits giving anything of value, directly or
indirectly, to officials of foreign governments or foreign political candidates in
order to obtain or retain business. It is strictly prohibited to make payments to
government officials of any country.
In addition, there are federal laws and regulations that prohibit U.S. government
personnel from accepting business gratuities. The promise, offer or delivery to an
official or employee of the U.S. government of a gift, favor or other gratuity in
violation of these rules would not only violate company policy but could also be a
criminal offense. State and local governments, as well as foreign governments,
may have similar rules with which the company must comply.
Associates, officers, directors and temporary staff may not use company
expense accounts, facilities or other assets for the benefit of any political party or
candidate, including an associate individually running for office. Associates,
officers, directors and temporary staff are not prohibited from contributing on their
own to political action committees. All travel by government officials that is
sponsored or paid for by the company must be approved in advance by the
Government Relations Department.
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8.0 CONFLICTS OF INTEREST
All associates, officers, directors and temporary staff are expected to make
decisions in the best interest of the company, and are required to handle in an
ethical manner any actual or apparent conflicts of interest between personal and
professional relationships. A conflict of interest exists when a person's private
interest interferes in any way with the interests of the company.
A conflict situation can arise when an associate takes actions or has interests
that may make it difficult to perform his/her company work objectively and
effectively. Conflicts of interest may also arise when an associate, or members of
his/her family, receives improper personal benefits as a result of his/her position
in the company.
It is almost always a conflict of interest for an associate, officer, director or
temporary staff person to work simultaneously for a competitor, client or supplier.
Associates, officers, directors and temporary staff are not allowed to work for a
competitor as a consultant or board member. The best policy is to avoid any
direct or indirect business connection with our clients, suppliers, or competitors,
except on our behalf.
You must fully disclose all relevant facts of any actual or potential conflict to your
leader, Human Resources, an executive officer or the Legal Department, and not
proceed with any action related to such conflict unless the action is approved in
accordance with the provisions of the Code of Business Ethics and Exception
Approval Form. Conflicts of interest may not always be clear-cut, so if you have
a question about whether a conflict may exist seek advice as provided in this
All associates, officers, directors and temporary staff will act with honesty and
integrity, avoiding actual or apparent conflicts of interest in company/business
transactions. For any exceptions to this policy, an associate must complete the
Code of Business Ethics and Conduct Exception Approval Form.
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9.0 COMPLIANCE GUIDELINES
All associates must work to ensure prompt and consistent action against
violations of this code. However, in some situations it may be difficult to know
right from wrong. Since the company cannot anticipate every situation that will
arise, keep in mind the following if a new question or problem occurs:
MAKE SURE YOU HAVE ALL THE FACTS. In order to reach the right
solutions, we must be as fully informed as possible.
- ASK YOURSELF - WHAT SPECIFICALLY AM I BEING ASKED TO DO?
DOES IT SEEM UNETHICAL OR IMPROPER? Focus on the specific
question you are faced with and the alternatives you have. Use your
judgment and common sense; if something seems unethical or improper,
it probably is.
- CLARIFY YOUR RESPONSIBILITY AND ROLE. In most situations, there
is shared responsibility. Are your colleagues informed? It may help to get
others involved and discuss the problem.
- DISCUSS THE PROBLEM WITH YOUR LEADER. In many cases, your
leader will be more knowledgeable about the question and will appreciate
being brought into the decision-making process. Remember that it is your
leader's responsibility to help you solve problems.
- ALWAYS ASK FIRST, ACT LATER. If you are unsure of what to do in any
situation, seek guidance before you act.
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10.0 REPORTING VIOLATIONS
It is every associate's, officer's, director's or temporary staff person's
responsibility to report any suspected, observed, or known violations of the
company’s Code of Business Ethics and Conduct, or business conduct
inconsistent with this policy or any other policies/principles to his/her functional
leader, functional Vice President, Human Resources or the Legal Department.
Alternatively, you may call the Valassis Corporate Governance Hotline at 1-800-
Action Line: If an associate, officer, director or temporary staff person is
uncomfortable with reporting violations to any of the above noted functions, the
associate, officer, director or temporary staff person is encouraged to use
Valassis Corporate Governance Hotline at 1-800-789-5409. The company’s
Governance Hotline Line is an anonymous, confidential resource for associates,
officers, directors and temporary staff to provide valuable input regarding
possible criminal activity, unethical business behavior, or violations of the
Valassis Code of Business Ethics and Conduct.
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Neither the company, its agents, nor its associates, officers, directors or
temporary staff are permitted to engage in retaliation, retribution or any form of
harassment directed against an associate, officer, director or temporary staff
person who has, in good faith, reported a concern of unethical or improper
activity. Any associate, officer, director or temporary staff person of the company
found to be engaging in retribution will be subject to disciplinary action up to and
including termination of employment.
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12.0 CODE OF BUSINESS ETHICS AND CONDUCT CONFIRMATION
All company associates, officers, directors and temporary staff (full-time, parttime,
contract, and temporary) will be required to certify their compliance with the
Code of Business Ethics and Conduct by signing the Code of Business Ethics
and Conduct Confirmation on a yearly basis. All Valassis new hires will receive
the Code of Business Ethics and Conduct and confirmation from the local Human
Resources Department as part of their offer letter package.
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13.0 EXCEPTION REPORTING/WAIVERS
Any associate, officer, director or temporary staff person who feels they need to
note an exception to any provision of the Code of Business Ethics and Conduct
must complete, and secure appropriate approval of, a Code of Business Ethics
and Conduct Exception Approval Form. Any waiver of this code for
associates, non-executive officers and temporary staff may be made only in
accordance with the provisions of the Exception Approval Form.
In addition to completing the Exception Approval Form, any waiver of this code
for executive officers or directors must be approved by the Nominating/Corporate
Governance Committee of the Board of Directors and promptly disclosed as
required by law, the Securities and Exchange Commission and any applicable
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14.0 HOW TO GET HELP
If you have questions or concerns about the company’s Code of Business Ethics
and Conduct, the first place to turn is your leader. If you're uncomfortable
discussing the issue with your leader, please talk to another member of
management, Human Resources, the Legal Department or the company’s Action
Line. Our Open Door Policy allows you the freedom to approach any level of
management with your concerns.
The Code of Business Ethics and Conduct Policy is reviewed annually and
updated as needed.
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