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CODE OF ETHICS As of June 2011

Natural Affordable Beauty Solutions

Janet Mosha

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CONTENTS

Mission Statement 3 Our Guiding Principles3 The Purpose of our Code of Ethics3 Our Core Values .4 Training and Education 4 Definitions of various terms 5 Enforcement .5 How to report Code of Ethics violations .5 What employees does the Ethics code cover 6 Compliance Procedures 6 Gifts .7 Drugs and Alcohol 7 Final Thoughts.7 Works Cited8

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Our Mission Statement


Divine Divas mission is to offer all-natural and organic cosmetics to our customers. We are with our customers side to side as they learn to take care of themselves naturally - enhancing what they already have as opposed to covering themselves up. The latest addition to Divine Divas is to offer make-up demonstrations, encouraging the clients to interact and gain confidence in applying natural looking make-up that is good for their skin. Divine Divas is a new revolutionary concept of applying pure ground minerals to ones skin to give a natural glow and healthy appearance. Our makeup is so pure you could use it on a baby; it is also completely manufactures in the U.S.A.

Divine Divas Guiding Principles


To provide our customers with the highest quality products and to develop satisfied customers with each transaction To provide a safe and conducive working environment for our employees To be a good citizen in our community as well as the environment To use some of our income in giving back to our community Encourage diversity in our workplace

The Purpose of our Code of Ethics


Divine Divas has implemented a Code of Ethics to guide our everyday operations so that our officers, employees, and other companies that we carry out business with knows where we stand and what we will and will not allow, we would not like even the slightest appearance of misconduct. Since the inception of our company over a decade ago, we have actively avoided lawsuits, unethical and unlawful behavior by always developing our codes to go with the times. We have been able to deter unacceptable conduct by enforcing our code of conducts and have displayed zero tolerance to those who break the code. Per Muel Kaptein, A code of ethics cannot make people or companies ethical. But nor can hammers and saws produce furniture. In both cases
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they are necessary tools, which need intelligent design and use. We assume that people would first and foremost use common sense when it comes to making decisions on proper conduct, if there are doubts then they can always use our code of ethics to guide them. Our code of ethics contains ways for our employees, executive officers and other companies we deal with (including customers) to contact us and where they are able to report any perceived misconduct. We never penalize our whistle blowers and in fact provide an anonymous choice if one does not want to be identified and would like privacy. We are committed to conducting ourselves with the highest integrity and providing the highest service to our customers and shareholders; we believe this is impossible if a strict code of ethics is not followed. We hope that everyone that we deal with will follow this code of ethics closely, we know that this code does not cover everything, but we believe that everyone would work together to seek guidance on the subjects not covered.9

Our Core Values


We will always act with integrity We will always work together for the greater good of the company and our customers We can always be counted on to do the right thing

Training and Education


We need ethics training so that the employees can know what is expected of them. Ethics training will enable our company to standardize the behavior of employees, ensuring that they follow the set rules, it also enable the employees to know the consequences of not following the code of ethics and what sort of punishment they can expect to receive as a result of not adhering to the guidelines. Ethic training helps build teams that are strong and also makes for a professional workplace environment. Training is provided first and foremost during our new employee orientations whereby the new workers are informed what our company

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expects from them. We will continue to provide ongoing training yearly as well as when the guidelines change or new rules are added. During training sessions we will address real life circumstances and how to deal with them. Per Debbie Wheeler, Regional compliance director of Tenet Healthcare Corporation, Companies should appoint a person who is capable, as a go to person, so that when employees need advise they can approach this person. This individual should be trustworthy with impeccable character, and good example to the employees. We will also be implementing e-learning opportunities for those employees who are unable to attend classroom training.

Definition of Various Terms


Integrity: This is a commitment to the highest ethical standards. Code of ethics: A written document that sets out rules for the business, describing what acceptable behaviors are and what are not.

Enforcement
Employees, who violate the Code of Ethics, fail to report a violation or make false reports will be subject to disciplinary action, which may include termination of employment. In the case where an employee violates the Code and is dismissed they would not be eligible for any severance or company benefits. Action will be taken not only on those who violate the Code of Ethics, but also against those fail to prevent or report violations.

How to report Code of Ethics violations


All the Divine Divas employees have the responsibility to report any violations or suspected violations of our Code of Conduct, as soon as possible. This protects the company, our stockholders, employees and finally our customers. If you have information regarding any such violation or if you suspect that a violation is being committed, a report should be made to immediate management or you may also bring the matter to the attention of: the office of the General Counsel, (651) 555-1111
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the office of the Human Resources manager, (651) 555-1122.; or the office of the Compliance Manager, (651) 555-1133. If you prefer to make a confidential report please do so at (651) 5553333. Please be assured that submissions will be treated as confidentially as possible. We promote an open environment where employees can share their concerns without fear of retribution or non-confidentiality.

What employees does the Ethics code cover?


All Divine Divas executives, officers, and employees are responsible for: Abiding by the Code of Ethics Seeking advice when an ethical issue arises. To report any known or suspected violations of the Code of Ethics as well as our policies and procedures Cooperating with any internal investigations about a perceived violation.

Direct managers have additional responsibilities to: Create a workplace that promotes ethical behavior and encourages employees to raise concerns without fear of retaliation. Make sure that employees are aware of the principles contained in the Code of ethics through training and yearly code reviews. Demonstrate a commitment to the Code of Ethics through their words and actions. Report any compliance violations and seek guidance if needed, on how to implement appropriate corrective actions. Handle all reports promptly and confidentially.

Conflict of Interest
No member of Divine Divas will engage in activities that can be construed as a conflict of interest. These activities are personal interests that get in the way with the companys best interest. One example of conflict of interest is having shares in another company with similar products that are our competitors e.g. Avon or Mary Kay and conducting Divine Diva business. Written consents will be needed in such situations. Other forms of conflict of are performing personal business during work hours or conducting oneself in a manner that would ruin the reputation of Divine Divas.
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Gifts Employees will not accept gifts or money from competing companies. Any gifts received in excess of $100 from our suppliers, vendors, customer etc should be refused. If any employee has any questions about the value of the gifts they have received, please ask you immediate supervisor for advice. On the other hand no employee should give any gifts to suppliers, vendors, customer etc, without the express permission of the compliance officer. Employees are absolutely forbidden from offering bribes or gifts to customers or government official including lawmakers and regulators. Drugs and Alcohol The use of alcohol and drugs are prohibited at Divine Divas. Upon hire we will perform a drug test on all new employees. The hiring process will depend on the passing of the drug test. Employees found to be under the influence of alcohol or illicit drugs are subject to reprimand or discipline which may include termination of employment. Final Thoughts Per Simon Webley and Andrea Werner, inadequate code of ethics do not include the input of employees and if these codes are to result in a long term change in behavior, employees would have to be involved in the code development process. We would therefore like to extend this opportunity to ask for some volunteers to be part of our compliance team and act as employee representatives. We ask that employees note all the ethical issues that they face on a daily basis and the representative group would brainstorm solutions to these situations and how the code of ethics can be geared to include these different circumstances. Please call the office of the Compliance Manager at (651) 555-1133 if you are interested in the volunteer positions available.

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*Works Cited: Wheeler, D. (2011, May). An ethical environment: How to create a culture of compliance and ethics in the workplace. Smart Business South Florida. Code of Business Conduct & Ethics for Members of the Board of Directors and Executive Officers. Retrieved from
http://www.investor.jnj.com/governance/boardconduct.cfm

Kaptein, M. (2011, March) Toward Effective Codes: Testing the Relationship with Unethical Behavior. Journal of Business Ethics. Webley, S. and Werner, A. (2008, October). Corporate codes of ethics: necessary but not sufficient. Business Ethics: A European Review. Stanwick, P. A., & Stanwick, S. D. (2009). Understanding Business Ethics.

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