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takes positions that. It believes can be shown to <br />be in the larger public interest. CARE encourages <br />trade and tribal associations with which it Is as- <br />sociated to do the same. <br />It Is important to separate personal and corpo- <br />rate political activities in order to comply with the <br />appropriate rules and regulations relating to lob- <br />bying or attempting to influence government offi- <br />cials. No use of CARE resources, including e-mail, <br />Is appropriate for personally engaging in political <br />activity. A CARE colleague may, of course, particle <br />We are k <br />t we <br />repeatedly do. <br />not an act, but a <br />habit. <br />Aristotle <br />pate in the political process on his or her own <br />time and at his or her own expense. While doing so, It is important CARE col- <br />leagues not give the impression they are speaking on behalf of or represent- <br />ing CARE In these activities. Colleagues cannot seek to be reimbursed by <br />CARE for any personal contributions for such purposes. <br />At times, CARE may ask colleagues to make personal contact with govern- <br />ment officials or to write letters to present our position on specific Issues. In <br />addition, It is a part of the role of some CARE management to interface on a <br />regular basis with government officials. If a colleague is making these com- <br />munications on behalf of the organization, he or she must be certain to be <br />familiar with any regulatory constraints and observe them. <br />The Company's Compliance Program <br />Program Structure <br />CARE's Compliance Program Is intended to demonstrate in the clearest pos- <br />sible terms the absolute commitment of the organization to the highest <br />standards of ethics and compliance. The elements of the program include <br />setting standards (this Code of Conduct and the CARE Compliance Policies <br />and Procedures), communicating the standards, providing a mechanism for <br />reporting potential exceptions, monitoring and auditing, and maintaining an <br />organizational structure that supports the furtherance of the program. Each <br />of these elements is detailed below and in the CARE Compliance Policies <br />and Procedures. These elements are supported at all levels of CARE's organ- <br />ization. <br />Providing direction, ,guidance and oversight is the CARE Compliance Officer, <br />28 <br />