CODE OF ETHICS
Conflicts of Interest
Managing Potential Conflicts
To determine if you have a conflict of interest that should be disclosed, review the LP Conflicts of Interest Policy to see if your situation is addressed. If it is not, ask yourself these questions:
Do my outside interests influence, or appear to influence, my ability to make sound business decisions?
YES or NO?
If the answer is yes, you have a potential conflict of interest that should be disclosed.
Do I stand to personally benefit, or appear to benefit, from my involvement in this situation?
YES or NO?
If the answer is yes, you have a potential conflict ofinterest that should be disclosed.
Does a friend or relative of mine stand to benefit or appear to benefit?
YES or NO?
If the answer is yes, you have a potential conflict ofinterest that should be disclosed.
Could my participation in this activity interfere, or appear to interfere, with my ability to do my job?
YES or NO?
If the answer is yes, you have a potential conflict of interest that should be disclosed.
Is the situation causing me to put my own interests ahead of LP’s interests? Does it appear to?
YES or NO?
If the answer is yes, you have a potential conflict ofinterest that should be disclosed.
If the situation became public knowledge, would I be embarrassed? Would it embarrass the company?
YES or NO?
If the answer is yes, you have a potential conflict ofinterest that should be disclosed.
Employees, Directors, and Officers of LP are expected to act in the best interests of the Company. This means that you should not use your position for private gain from customers, vendors, suppliers, or contractors.
A potential conflict of interest exists when your outside interests (e.g., financial interests) interfere with your work responsibilities. LP Personnel must never use their position to influence a decision that could lead to a private benefit for them, or their family members. You may not participate in any activity (whether for personal profit or incident to industry, civic, or charitable organization affairs) if it is likely to involve continued and unreasonable use of your time during normal LP business hours.
You are required to disclose certain information related to personal activities that may relate to your job. Any conflict disclosures should be made, in writing, in accordance with the Company's Conflicts of Interest Policy.
Possible Conflicts of Interest will be reviewed to determine the best course of action. The reviewing manager will ensure that information necessary to conduct a thorough, even-handed review that adequately protects both the interests of LP and the employee is gathered. The results of any conflicts review will be communicated, in writing, to you, along with copies of supporting information and/or documentation related to the decision.
Reporting Process for Conflicts
Report any potential conflict of interest immediately to your supervisor, manager, the Compliance Department, or any other resource outlined in the Code. Executive Officers and Directors have the responsibility to report potential conflicts of interest to the Board of Directors (or its designated committee) for review.
Business Ethics Questionnaire
Reporting Activities on An Annual Basis
Salaried employees are required to annually review, assess, and report, in writing, their activities and or observations, by completing the Company’s Business Ethics Questionnaire (“Questionnaire”). Completing this Questionnaire helps us spot potential compliance issues, including conflicts of interest. Failure to complete the Questionnaire promptly, accurately, and completely is considered a violation of the Code and may lead to appropriate disciplinary action.
Gifts and Entertainment
Potential for Undue Influence
LP Personnel should never accept or give gifts/entertainment that could compromise their independent judgment, create a conflict of interest, or otherwise influence their actions to the potential detriment of the Company. Gifts or lavish entertainment may be seen as attempts to unduly influence business relationships.
Tell Your Supervisor
Receipt of either gifts or entertainment must be reported to your supervisor. Any gift, gratuity, or item that exceeds $100.00 in value should be returned with a note respectfully declining the gift, donated to a local charity on behalf of LP, or given to your supervisor or member of LP’s management for proper disposal.
What To Do if You Receive a Gift
If you or any immediate family members receive a gift, gratuity, or other item that is of more than nominal value from any person or entity having current or prospective dealings with LP, it must be returned.
Insider Trading
What is Insider Trading?
LP is a publicly listed company on the NYSE, which means that LP and its employees, Directors, and Officers are subject to stringent rules regarding inside information (“Inside Information”) and insider trading (“Insider Trading”). Inside Information is non-public information, about a public company that could potentially give an unfair advantage to those who have the information. Insider Trading is trading on the stock exchange using Inside Information.
Who is an Insider?
Any individual who has knowledge of material, non-public information may be considered an “insider” for purposes of federal securities laws. It is a violation of the Code and the law to trade in LP stock, or “tip” others to trade, if you have material information about the Company that is not available to the public. Securities trading can include the purchase and sale of LP stock, put or call options, and instructions to move funds into or out of an IRA, 401(k), or other employee benefit plan or trust.
What is Considered Material Information?
Information is "material" if it would be considered important by a reasonable investor making an investment decision, or if it would be likely to affect the market price of securities.
Examples of Inside Information
- Annual or quarterly financial results
- Projections of earnings or losses
- News of mergers, acquisitions, or divestitures
- Changes in dividend policy
- Management changes
- New products
- Gain or loss of a substantial customer or supplier
Tips are Prohibited
It is also illegal to "tip " such Company information to any other person who may then trade on the information.
Questions
If you have questions about whether you might have Inside Information, you should contact the Company’s corporate secretary or the Legal or Compliance Departments.
Approval of Stock Transactions
Outside of a restricted trading period any proposed trade by a member of LP’s Executive Team or certain designated employees must be approved in advance in writing (including via email) by the General Counsel, the CFO or, in their absence or availability, the CEO.
Not Just Unethical
Insider Trading is both unethical and illegal. There can be serious consequences for violations of securities laws, and LP, along with individual LP personnel, can be held civilly and criminally responsible for violations. If you have any questions or doubts about Insider Trading, promptly consult the LP Legal Department.
Frequently Asked Questions
In most cases, business meals can be accepted. However, employees directly involved in the negotiation with a supplier may only accept modest entertainment.
Yes. As long as you or another LP employee accompanies them to the event this is considered entertainment, not a gift. Therefore, it is not subject to the $100 gift limit.
No. This is considered a gift since the consultant is not going with you to the event. The tickets are subject to LP’s gift limit of $100.
Yes. As long as the amount of the gift card is below the gift limit threshold of $100.
Yes. As long as the amount of the gift card is below the gift limit threshold of $100.
Yes, as long as the supplier is in attendance at the event and you are not directly involved with current negotiations with this supplier. Prizes for the tournament can be accepted as long as they are not lavish.
All offers to attend industry conferences and trade shows should be discussed with your supervisor. In some cases, if you have been invited to speak, it is appropriate to allow the conference organizers to cover or waive the registration fee. In most cases, however, if your supervisor believes it is a good use of your time to attend the conference or trade show, LP should pay the registration fee and related travel expenses.
It depends. Does the official work for the federal government or a state or local government? What specific state government? Are they an elected official, an appointed official or a civil servant? Do they work for the executive or legislative branch? Rules involving gifts to government officials are complex so you should always consult with the General Counsel prior to offering government officials anything of value.
Yes. The gift limit applies to LP employees and their immediate family members.
No. Gift cards for such an event that do not exceed the $100 limit are allowable since this is a prize and not a direct gift to a particular customer.
This might be perceived as a conflict of interest or favoritism. You should discuss the relationship and receive advance written approval from management before pursing this business arrangement or recommending it to others in the company.
You should consult with your supervisor. Your board activities should not conflict with your working time, and you should not use corporate resources to communicate with others in your capacity as an outside nonprofit board member. Positions on for-profit company boards will require additional review and preapprovals.
The Code is not designed to cover private matters between employees. However, romantic relationships with others in the workplace can create situations that may be prohibited by the Code. For instance, employees who supervise one another and coworkers who work closely together or who could influence each other’s pay, performance rating, job benefits, or other terms and conditions of employment must avoid even the appearance of a conflict of interest. If you find yourself in a romantic relationship with a coworker that may lead to a potential or actual conflict of interest, you are encouraged to bring the matter to the attention of your supervisor or the Human Resources Department.
No. Since you are aware of material, non-public information about the publicly traded company, you must not trade in any security of that company or pass along such information to anyone else.
If you are aware of material, non-public information relating to the customer, in addition to violating company policies, you could be violating insider trading laws if you purchase the security of the customer. If, however, you are not aware of material, non-public information relating to the customer, you might be allowed to purchase the security of the customer if it does not create an actual or potential conflict of interest. Questions regarding conflicts of interest should be directed to LP’s Legal Department.
Information may be material if it is likely to affect the market price of the security (stock) or if a reasonable investor would consider the information important in deciding whether to buy or sell the security. Examples may include newsworthy information, such as financial results, mergers or acquisitions, purchases or sales of a business, new products or businesses, or changes in executive management.