PFJ Standards of Business Conduct
February 2016
Page 1
PFJ Standards of Business Conduct
February 2016
Page 2
Dear Team Members:
At Pilot Flying J, our success has been built on our
exceptional team and a work environment where
Team Members have a commitment to act with the
highest standards of honesty, fairness and integrity,
and show respect for one another. Our core values
guide our behavior, actions and decisions and living
up to these high standards is absolutely critical to our
continued success.
Inherent in each value is an obligation and
expectation to always be ethical, truthful and
dependable. Pilot Flying J’s Standards of Business
Conduct (“Standards”) articulate this commitment
and provides the framework for operating in today’s
environment of complex laws and regulations.
I am personally asking you to commit to following
the Standards as a guide for your interactions with
our guests, fellow Team Members, business partners, and anyone else with whom you
come in contact.
Each of us is responsible for knowing when to speak up, asking tough questions and
reporting any possible violation of the Standards. Since no code or policy can spell out
the appropriate behavior for every situation, you should talk with your supervisor, or refer
to any of the resources listed throughout the Standards, when you have questions or
concerns.
Thanks for all you do.
Ken Parent
Ken Parent, President
PFJ Standards of Business Conduct
February 2016
Page 3
PILOT FLYING J
PILOT FLYING JPILOT FLYING J
PILOT FLYING J
MISSION, VISION AND VALUES
MISSION, VISION AND VALUESMISSION, VISION AND VALUES
MISSION, VISION AND VALUES
OUR VISION
Fueling Life’s Journeys
OUR MISSION
Connecting People and Places with Comfort, Care and a
Smile at Every Stop
OUR VALUES
Pilot Flying J SERVES
YOU & YOUR FAMILY
SERVICE
Guest and Team Members are at the center of everything we do
EXCELLENCE
Working together drives success and opportunity
RESPECT
We value Team Members, celebrate achievements, and appreciate guests
VALUES
Stand for integrity and fairness
ENRICH
We are committed to making a difference in people’s lives
SPIRIT
Our family culture encourages passion and humility
PFJ Standards of Business Conduct
February 2016
Page 4
GUIDING PRINCIPLES
All interactions will be conducted in compliance with the law and in keeping with high
ethical standards. We will act honestly and responsibly in all community and business
relationships with guests, suppliers, Team Members, representatives, owners, and
others. Our people are expected to abide by these principles and to strive for
professional excellence. The foregoing principles are consistent with the specific
statements of policy that follow and with the separate policies and procedures of the
operating companies.
Look Inside
PFJ Listens
6
Asking for Guidance and Voicing Concerns
6
Anti-Retaliation Policy
6
Workplace Environment
7
How We Treat One Another 7
Workplace Bullying 8
Team Member Relationship 8
Fraternization 8
How We Treat Our Guests 9
Diversity 9
Environmental, Health, Safety and Security 9
Substance Abuse and Weapons 9
Wage and Hour Rules 10
Business Practices
11
Compliance with Laws and Regulations 11
Interaction with the Government 11
Fair Competition 11
Conflicts of Interest and Corporate Opportunities 12
Gifts and Entertainment 12
Intellectual Property and Proprietary Information
14
Confidential Information 14
Other Intellectual Property 15
Protecting the Pilot Flying J Assets and Brand Name 15
Computer Applications and Software 16
System Integrity 16
System Security 16
Personal Use of Pilot Flying J Technology 16
Email Policy 17
Social Media Policy 18
Financial Integrity and Responsibility
19
Spending Pilot Flying J’s Money 19
Signing a Contract 19
Purchasing Practices 19
Business Records and Communications 20
Community Involvement
20
Personal Activities 20
Political Activities 20
Public Relations 20
Frequently Asked Questions
22
PFJ Standards of Business Conduct
February 2016
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ABOUT THE STANDARDS OF
BUSINESS CONDUCT
Pilot Flying J empowers all partners to make decisions that impact our reputation.
Individual actions at work shape how the world views Pilot Flying J, which is why it’s so
important that we each take responsibility for our Mission and acting ethically in all
situations. Remember, all Team Members should answer this question when considering
the Standards of Business Conduct:
Would I be proud to explain my actions to my family or fellow Team Members — or to
thousands of people around the world on tonight’s news broadcast without hesitation?
The Standards of Business Conduct support our core values and provide an overview of
some of the legal and ethical standards we are each expected to follow every day. If you
are unsure of what to do in a situation, you have support. Speak to your supervisor,
management, HR Zone Manager, the Compliance & Ethics Department, or Law
Department and remember any communication in good faith is covered by our anti-
retaliation policy covered on page 6 herein.
Please read the Standards carefully at work. If you have any questions, refer to the “PFJ
Listens - Asking for Guidance and Voicing Concerns” section of this document.
This information is available in different formats.
PFJ Standards of Business Conduct
February 2016
Page 6
PFJ LISTENS -
Speak Up! We’ll Listen
ASKING FOR GUIDANCE AND VOICING CONCERNS
Pilot Flying J’s core values require compliance with the law, as well as ethical
conduct. If you feel these standards have not been met, need access to policies,
or have any questions, please ask for guidance or voice your concerns by
contacting any of the following resources:
• Your supervisor
• HR Zone Manager
• PFJ Listens Integrity Line 1-888-55 PILOT (you may remain
anonymous)
• PFJListens.com (you may remain anonymous)
•
Compliance & Ethics Office at
PFJListens@pilottravelcenters.com or
865-474-2987
Team Members can also seek advice and counsel from PFJ’s functional departments such
as Human Resources, Finance, Auditing and the Law Department. All Team Members
reporting issues will be held in the strictest of confidence by trained professionals in these
departments.
The PFJ Listens Integrity phone number is: 1-888-55 PILOT. The Integrity Line and
PFJListens.com are available 24 hours a day, seven days a week and an interpreter for the
Integrity Line can be made available upon request. In addition, if requested by the Team
Member, the Integrity Line will treat the Team Member’s identity and the alleged illegal or
unethical conduct as confidential information, and will disclose the identity of such source
only as absolutely necessary to comply with legal requirements and to investigate the
reported conduct. Those informed of the Team Member’s identity shall be made aware of
the need for confidentiality. If a Team Member calls anonymously or uses the web portal,
he or she will be provided a number to use in identifying his or her inquiry. The group of
outside professionals who answer the call will work with each Team Member to get the
information PFJ needs to address his or her concern.
If a Team Member is aware of any ethical issue or irregularity, do not attempt to handle an
investigation on your own. Ask for help from Compliance & Ethics, Human Resources, Law
Department, or contact the PFJ Listens Integrity Line or web portal. Each Team Members’
concerns will be taken seriously, and all information provided will be treated in a
confidential manner.
ANTI-RETALIATION POLICY
Pilot Flying J has a strict policy against retaliation and does not tolerate retaliation against or the
victimization of any team member who raises concerns or questions regarding a potential violation
of law, the Standard of Business Conduct or any Pilot Flying J policy that he or she reasonably
believes to have occurred
.
PFJ Standards of Business Conduct
February 2016
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WORKPLACE
ENVIRONMENT
How We Treat One Another
Pilot Flying J promotes equal opportunity in its hiring practices and makes recruiting
decisions based solely on job-related criteria. Discriminating against any Team Member or
person with whom we do business on the basis of age, race, religion, sex, disability, national
origin, sexual orientation, gender identity or any other legally protected status is not
permitted and is subject to disciplinary action, up to and including termination.
At Pilot Flying J we treat each other with respect and dignity. You and your ideas create
value and success for Pilot Flying J. We must value and respect the unique character and
contribution of each Team Member and guest. This means that all Team Members are
entitled to a work environment that is free of harassment and discrimination. Failing to
treat each other with dignity, respect and fairness is damaging to an effective work
environment and could be grounds for termination.
Harassment and discrimination take many forms, including:
• Unwelcome remarks, gestures or physical contact
• The display or circulation of offensive, derogatory or sexually explicit pictures or
other materials, including by email and on the internet
• Offensive or derogatory jokes, language or comments (explicit or by innuendo)
• Verbal or physical abuse or threats
• Emails, materials or other communication which includes inappropriate or
derogatory, racial, ethic, or religious slurs or stereotypes
Example:
Q: One of my co-workers emailed an inappropriate joke to me and some teammates.
I find it offensive, but I don’t know if I should approach my co-worker with my
concerns. What should I do?
A: We each have an obligation to ensure that Pilot Flying J is a great place to work
for all Team Members and offensive behavior such as this is not acceptable. If you
feel uncomfortable speaking with your co-worker directly, contact your
supervisor, HR Zone Manager, 1-888-55 PILOT or the Law Department.
PFJ Standards of Business Conduct
February 2016
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Workplace Bullying
Pilot Flying J does not tolerate bullying in the workplace under any circumstances.
Workplace bullying is behavior that harms, intimidates, offends, degrades or humiliates a
co-worker, subordinate, or supervisor, whether in private or in front of other Team
Members, vendors, clients, guests, or other third parties. Any Team Member caught
bullying while at work will be subject to disciplinary action, up to and including termination.
Examples of workplace bullying include, but are not limited to: continuous pattern of
unwarranted or invalid criticism; blame without factual justification; exclusion or social
isolation; and name calling, being sworn at, shouted at or being humiliated.
Team Member Relationships
Pilot Flying J discourages Team Members from dating or entering into consensual social
relationships with other Team Members. If such a relationship is entered into, Pilot Flying
J cautions Team Members not to let such relationships affect their job performance. Team
Member relationships are allowed provided: both parties mutually and voluntarily consent
to the social or dating relationship; the social or dating relationship does not breach
corporate values or these Standards; the social or dating relationship does not involve a
supervisor and subordinate (refer to the fraternization policy below in this Standards); and
the social or dating relationship does not affect or appear to affect judgment or
performance of duties of involved Team Members and those Team Members’ co-workers;
and/or the social or dating relationship does not negatively impact the common good of
Pilot Flying J.
Team Members who do not have a supervisor/subordinate status that choose to enter into
any social, dating, personal or business relationships must comply with the following:
• Immediately self-report;
• Review PFJ’s policy prohibiting workplace harassment and conflict of interest as set
forth in this Standards of Business Conduct;
• Behave professionally at all times, avoiding indiscreet behavior while at the
workplace or while on Company time or business including refraining from public
displays of sexual affection, sexual innuendo, and suggestive comments and
sexually oriented joking.
Fraternization
Fraternization is most commonly thought of as an intimate, sexual or romantic relationship,
including the appearance or implication of such as relationship, between a supervisor
(includes all leadership positions from shift supervisor on up) and subordinate. It also
includes personal or outside business relationships between a supervisor and subordinate
that crosses the boundary of the supervisor and subordinate working relationship. Such
relationships tend to lead to accusations of discrimination, harassment or the perception
of favoritism.
Personal relationships include, but are not limited to: regular non-business social
interactions, dating, cohabitation and any type of sexual relationship. Business
relationships include, but are not limited to: loaning and borrowing money and business
partnerships. Except as set forth below, PFJ strictly prohibits such personal and business
relationships between a supervisor and a subordinate of PFJ. To report a relationship
prohibited in this Standards of Business Conduct see the Getting Help section of this
Standards of Business Conduct.
The personal and business relationships described above between salaried or hourly
managers/supervisors and hourly Team Members are prohibited and failure to follow the
steps below will result in disciplinary action up to and including termination. Any Team
PFJ Standards of Business Conduct
February 2016
Page 9
Member desiring to enter into a personal or business relationship with a supervising or
subordinate Team Member must speak discuss the matter with his or her supervisor or the
HR department and the Company will determine, in its sole judgment, whether to
termination, reassignment, demotion, or transfer either or both Team Members.
Example:
Q: I am a Manager in a Travel Center and the coffee hostess recently approached me
to ask if I would like to join her for drinks after work. I told her I did not think this
would be appropriate. Do I need to do anything else?
A: Yes. If a subordinate Team Member attempts to initiate a potentially inappropriate
relationship with a supervisor, it is the responsibility of the supervisor to make sure
the Fraternization policy is followed and if the behavior is persistent, contact a HR
Zone Manager for assistance with the policy.
How We Treat Our Guests
Pilot Flying J’s goal is to make life better for America’s drivers. We strive to make every
guest’s experience pleasant and fulfilling, and we treat our guests as we treat one another,
with respect and dignity. This means, for example, that we never harass or discriminate
against our guests.
Diversity
Pilot Flying J actively creates and promotes an environment that is inclusive of all people
and their unique abilities, strengths and differences, and promotes diversity as a strategic
and competitive business advantage for the Company.
As we continue to grow, embracing diversity in every aspect of our business – from the
way we work together to the way we procure goods and services – is vital to our long-
term success. We respect diversity in each other, our guests and suppliers and all others
with whom we interact.
Environmental, Health and Safety
Pilot Flying J is committed to complying with all Federal, state and local laws, rules and
regulations (including environmental, OSHA and labor). In addition, Pilot Flying J is
committed to providing a healthy and safe workplace. Each Team Member is expected to
follow all environmental, health and safety laws, cooperate with officials who enforce these
rules and practices, take necessary steps to protect themselves and the other Team
Members, attend all required training, and immediately report all accidents, injuries and
unsafe practices or procedures. Furthermore, each Team Member must take steps to
correct those conditions immediately so as to prevent harm or danger to any guests, fellow
Team Members, or the general public.
Substance Abuse and Weapons
Pilot Flying J is committed to a safe workplace free of substance abuse. That commitment
is jeopardized when any Pilot Flying J Team Member illegally uses drugs on or off the job,
comes to work under the influence, possesses, distributes or sells drugs in the workplace,
or abuses drugs or alcohol on the job. The use, possession, or distribution of alcohol
(except for consumer sales as allowable by law) or illegal drugs while engaged in work for
Pilot Flying J or on Pilot Flying J premises is strictly prohibited. It is also a violation of this
Standards of Business Conduct to operate a Company owned or rented vehicle under the
PFJ Standards of Business Conduct
February 2016
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influence of alcohol or drugs, regardless of how slight. Team Members are encouraged to
confidentially seek treatment for alcohol and substance abuse problems. Team Members
are also encouraged to report instances of violation of this policy and the specific policy
contained in the Team Member handbook through the reporting channels found at the
end of this Standards of Business Conduct.
Unless otherwise required by applicable law,
Team Members may not have or possess any
weapon while in a Travel Center, Support Center, dispatch facility or any other Pilot Flying
J property. Pilot Flying J takes its rules regarding workplace health, safety and security very
seriously. It is essential that you understand and follow them, together with any more
detailed guidance provided to you by your supervisor or in other Pilot Flying J policies.
Wage and Hour Rules
Pilot Flying J is committed to following all applicable wage and hour laws and regulations.
To help ensure that all worked performed for Pilot Flying J is compensated correctly, Team
Members must clock in and out for their schedule shifts. This confirms the number of
hours worked during the Thursday through Wednesday work week and provides Pilot
Flying J with correct information for calculation of wages. Team Members have the
opportunity each week to review and verify the accuracy of their time records and are
expected to do so.
Team Members should review his/her time cards weekly and
electronically acknowledge same to insure accuracy. If a Team Member disagrees
with his/her time entries and/or disputes the accuracy of his/her time card, he/she
will be given the opportunity during the electronic verification process to note any
objections. If a Team Member believes that he/she is not being paid for time worked
during the workweek, he/she should immediately contact his/her supervisor, Region
Manager, HR Zone Manager, Payroll manager or PFJ Listens at 888-55 PILOT or
PFJListens.com. PFJ will investigate any concerns brought to its attention and strive to
correct any errors with respect to the reporting of time and payment of wages.
Pilot Flying J wants its Team Members to be paid in accordance with the law for all hours
worked and takes allegations regarding working off the clock or not being paid overtime
very seriously. Asking someone to work off the clock, forcing someone to do so, paying in
alternative means other than the payroll system or altering time records to avoid paying for
hours worked or overtime is strictly prohibited and anyone found to have done so shall
be terminated.
With respect to Team Members, Pilot Flying J understands that times may arise that an off
the clock Team Member may feel compelled to help in the store or restaurant in order to
complete a task or help with guests before his/her shift begins or break is over. While Pilot
Flying J greatly appreciates each Team Member’s willingness to help when needed, Pilot
Flying J cannot allow any Team Member to work without being paid for the time spent
doing so. Team Members should always clock in before performing any work. If it is
impossible for a Team Member to clock in prior to beginning to work, he/she should
document his/her start date in writing, submit the documentation to management so Pilot
Flying J’s time records can be updated and then review his/her timecard each week to
ensure any and all necessary changes have been made. Team Members found to have
willingly worked off the clock without documenting the time worked and following the
procedures noted herein shall be subject to disciplinary action, up to and including
termination.
Example:
Q: Lately, my store has been very busy and it’s been hard to find time to do routine
cleaning. At this morning’s store meeting, our manager told everyone that if they
don’t complete their tasks before they punch out they will have to stay “off the
clock” to do so. Is it okay for our manager to ask this of us?
A: No. Working off the clock is strictly prohibited by Pilot Flying J. Pilot Flying J is
committed to ensuring that all Team Members are accurately compensated for all
PFJ Standards of Business Conduct
February 2016
Page 11
work performed. Any requests to work off the clock must be reported to the
Regional Manager, HR Zone Manager or the Law Department.
BUSINESS PRACTICES
Compliance with Laws and Regulations
Pilot Flying J is committed to full compliance with the laws, rules and regulations of the
United States and Canada (and any other country in which it may operate). Team Members
must comply will all applicable laws, rules and regulations, including but not limited to the
Foreign Corrupt Practices Act (“FCPA”), when performing his or her duties.
When you think a conflict exists between the Standards of Business Conduct and an
applicable law, rule or regulation, or if you have a question concerning the legality of your
or other Team Member’s conduct, you should consult with your supervisor or another party
described in the “Asking for Guidance and Voicing Concerns” section of this policy.
Interaction with the Government
Pilot Flying J is committed to complying with local laws, regulations and codes and to
working fairly and honestly with government officials and others in our communities. In
doing so, our actions must meet high ethical and legal standards. It is against Pilot Flying
J’s policy (and violates states’ commercial bribery statutes) to offer or make a payment or
gift of any kind in order to facilitate a local process or to influence a local government
official.
If you are contacted by a government or regulatory representative and asked to provide
information or submit to an inspection, you should inform your supervisor or the Law
Department immediately. Your supervisor or Law Department will take appropriate actions
or contact the appropriate department for guidance.
Pilot Flying J’s policy is to deal honestly and fairly with government authorities and to
comply with valid governmental requests and processes. Team Members must be truthful
and straightforward in their dealings with the government and may not direct or encourage
another Team Member or anyone else to provide false or misleading information to any
government official or representative. Team Members must not direct or encourage
anyone to destroy records relevant to an investigation or legal proceeding, or in a situation
PFJ Standards of Business Conduct
February 2016
Page 12
where circumstances make it reasonable to assume there is a likelihood that there will be
an investigation or legal proceeding.
Fair Competition
Fair competition laws are intended to promote vigorous competition in a free market. It is
in Pilot Flying J’s best interest to promote free and open competition. Pilot Flying J must
make its own business decisions, free from understandings or agreements with
competitors or suppliers that restrict competition. We consider compliance with these
laws mandatory and of vital importance.
When conducting Pilot Flying J business, all Team Members must:
• Not discuss pricing, production or markets with competitors
• Not set resale prices with guests or suppliers
• Always present Pilot Flying J’s services and products in a manner consistent with
our core values
• Not induce a third party to breach an existing agreement
• Never act in a manner that could be seen as an attempt to exclude present or
potential competitors or to control market prices
• Not disparage the products or business of competitors, guests or suppliers
Example:
Q: I am going to a trade show. May I go to a competitor’s booth?
A: Yes. You may go to the booth and collect any publically distributed material.
However, if you talk to anyone at the booth, identify yourself as a Pilot Flying J
Team Member, and avoid conversations about business. If you have any
questions, a good practice is to consult with the Law Department for guidance
before you attend.
Q: A salesperson for a competitor and I are friends. Occasionally we talk about
marketing plans. Should I be concerned?
A: Yes. You are revealing confidential information that Pilot Flying J has invested
time and money to develop. Also, you are likely violating competition laws that
ban discussions of marketing and pricing.
Conflicts of Interest and Corporate Opportunities
Business decisions and actions on behalf of Pilot Flying J must never be influenced by
personal considerations or personal or outside relationships. You must never use Pilot
Flying J property, information or its position to create personal or family benefit. A conflict
of interest may occur when: (1) family members or close personal friends of a Team
Member are involved in business matters with Pilot Flying J; (2) Team Members within Pilot
Flying J are close personal friends or family members, to the extent that such relationship
interferes with sound business judgment being exercised by one or more of the involved
Team Members; (3) when a Team Member or a Team Member’s family member has a direct
or indirect personal or financial interest in any business issue that is under consideration;
(4) when outside business interests, or “moonlighting” interferes with a Team Member’s
ability to do his or her job to the satisfaction of Pilot Flying J; and (5) when a Team Member
enters into a business or personal relationship, including fraternization, unrelated to Pilot
Flying J business, with a vendor of Pilot Flying J or someone who works with or for such
vendor, to the extent such relationship affects a Team Member’s ability to make sound
business decisions with regard to such vendor or a competing vendor.
PFJ Standards of Business Conduct
February 2016
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A Team Member should never attempt to become involved in a business that may compete
with Pilot Flying J nor attempt to acquire an interest in property or other assets in which
Pilot Flying J might reasonably be expected to have an interest, without first offering the
opportunity to PFJ.
Each Team Member must
mustmust
must annually disclose to the PFJ Compliance & Ethics Office all
actual and potential conflicts of interest as listed above, including those where even the
appearance of a conflict of interest may exist. Disclosure and discussion are the best ways
to protect against and deal with conflicts of interest.
Example:
Q: I have a relative I’d like to hire to do some work for Pilot Flying J. Since it’s a
legitimate project that needs to be done, and my relative is trained to do this type
of work, is it okay if I hire her?
A: Although the work is legitimate, this situation creates the appearance of a conflict.
The circumstances of this situation should be raised with the Law Department so
that an independent review can be done prior to committing to a contract. This
will help protect you, your relative and Pilot Flying J if the relationship ever comes
into question.
Gifts and Entertainment
The exchange of gifts, meals and entertainment is a common practice in business, and can
help us build better relationships with guests, vendors and other business allies. One
principle is clear and common: no gift, favor, or entertainment should be accepted or
provided if it will obligate, appear to obligate or is intended to obligate, or unduly influence
Pilot Flying J and/or the Team Member receiving the gift, favor, or entertainment. Consider
what other Team Members will think about a Team Member receiving such gift, favor or
entertainment and what kind of example such receipt might be setting. The types of gifts
and entertainment that are appropriate to give or receive as a Pilot Flying J Team Member
depends on many factors. If the gift, meal or entertainment in question is lavish or frequent,
or unusual for the receiving Team Member’s job, it is probably not acceptable. If a Team
Member is in the middle of negotiations or bid evaluations, extra care is required. Never
request or solicit personal gifts, favors, entertainment, or services. Never offer or accept
gifts of cash or cash equivalents such as securities.
Acceptance of meals, refreshments, travel arrangements, accommodations or
entertainment, all of reasonable value, in the course of a meeting to hold a bona fide
business discussion or to foster better business relations is permissible under the following
guidelines:
• When the expense involved would be payable by Pilot Flying J as a reasonable
business expense if it were not paid by the other party; or
• When gifts, services, travel or entertainment exceeding $100 in value has received
approval by the Team Member’s immediate supervisor and from one of the
following officers: PFJ’s President, Chief Financial Officer, Chief People Officer or
General Counsel; or when gifts, services, travel and entertainment do not exceed
$100 in value.
You may not encourage or solicit meals or entertainment from anyone whom Pilot Flying
J does business or from anyone who desires to do business with Pilot Flying J. Giving or
accepting valuable gifts or entertainment might be construed as an improper attempt to
influence the relationship.
Example:
Q: May I accept a business meal from a supplier?
PFJ Standards of Business Conduct
February 2016
Page 14
A: In most circumstances, modest and infrequent business meals may be accepted.
However, whenever a supplier pays for a meal, always consider the specific
circumstances and whether your impartially could be compromised or appear to
others to be compromised. If the meal is offered during contract negotiations,
you must always politely decline the invitation. Talk with your supervisor if you are
unsure.
INTELLECTUAL PROPERTY AND
PROPRIETARY INFORMATION
Confidential Information
During the course of employment at Pilot Flying J, all Team Members gain some
knowledge and information that is non-public and belongs to Pilot Flying J. Team
Members are trusted with maintaining the confidentiality of this valuable information.
Confidential information regarding Pilot Flying J’s operations and business activities is
essential to the conduct of our business. We operate in a very competitive environment
and our competitors are intensely interested in obtaining Pilot Flying J’s financial and
operating information. Confidential information includes any information that is not
common, public knowledge and/or known to competitors, guests, suppliers, and others
(including other Team Members of Pilot Flying J who do not have a valid business reason
for obtaining this
information). Confidential information includes pass codes and log-in
codes used by Managers. Any Team Member who possesses confidential information shall
take all steps necessary to safeguard and protect such information from disclosure which
include but are not limited to:
•
Store confidential information in a secure place and do not leave it out where
others can see it.
•
Clearly mark confidential information as confidential
•
Do not send confidential information to unattended fax machines or printers
•
Do not discuss confidential information where others may hear
Confidential information does not include information lawfully acquired or shared by non-
management Team Members about wages, hours or other terms and conditions of
employment if used by them for purposes protected by § 7 of the National Labor Relations
Act or as otherwise protected and permitted under applicable law.
PFJ Standards of Business Conduct
February 2016
Page 15
Disclosure of store locations that Pilot Flying J may be building, selling or acquiring, should
not be discussed with internal or external parties that are not involved in the projects until
construction has begun, in the case of a store being built, or a public announcement has
been made by Pilot Flying J, in the cases of stores being sold or bought. In addition, Pilot
Flying J does not permit under any circumstances the discussion of future pricing strategy
with those outside Pilot Flying J. Please refer to Pilot Flying J’s separate Policy Regarding
Antitrust Compliance and Policy Regarding Price Discussions for further details.
Pilot Flying J is committed to being fair in the areas of confidential information and
materials. Just as we take care to protect our information, Pilot Flying J respects the
information of others. Here are some basic rules to follow:
• Do not bring any material from prior employers to Pilot Flying J
• Do not accept or use anyone else’s confidential information (or agree to maintain
anyone’s information in confidence)
• Do not solicit confidential information from another Company’s present or former
Team Member’s or suppliers
• Do not engage in commercial espionage; be transparent in obtaining information
about the marketplace
Example:
Q: What is confidential information?
A: Confidential information is all non-public information that might be of use to
competitors or harmful to the owner of the information if disclosed. Examples
would include information on business plans or operations that are not known to
the general public or competitors.
Q: I just returned from a general managers meeting where I learned about Pilot Flying
J’s exciting new product plans and excellent financial results. I am very proud of
Pilot Flying J’s success and am eager to share the news. Can I tell my family, or
answer questions if a reporter contacts me?
A: No. This information has not been released to the public and is confidential.
Unauthorized disclosure could have serious consequences. For example, Pilot
Flying J could be placed at a competitive disadvantage or exposed to legal liability.
Never disclose confidential Company information to reporters or anyone outside
Pilot Flying J.
Other Intellectual Property
As a Team Member, the things you create for Pilot Flying J belongs to the Company. This
includes inventions, discoveries, ideas, improvements, software programs, artwork and
works of authorship. This work product is Pilot Flying J’s property if it is created or
developed, in whole or in part, on Company time, as part of your duties or through the use
of Company resources or information.
Team Members must promptly disclose to Pilot Flying J, in writing, any such work product
and cooperate with the Company’s efforts to obtain protection for Pilot Flying J.
To ensure that Pilot Flying J receives the benefit of work done by outside consultants, it is
essential that an appropriate written agreement or release be in place before any work
begins.
Remember, too, that our brands, including but not limited to Pilot Travel Centers LLC, Pilot
Flying J, Flying J Inc. and Pilot Corporation have significant value and recognition in our
industry. Each Team Member should act in a manner that enhances and does not detract
from the value of our trade names and trademarks. Brands are fragile and must be used
carefully and protected from misuse.
PFJ Standards of Business Conduct
February 2016
Page 16
When Pilot Flying J uses the work product of others, including art and software programs,
we must also be sure to follow the rules relating to properly attributing trademark, service
mark, or copyright notices. Written materials and software are subject to copyright
protection and should be copied only when permitted. Use caution, as not all protected
materials bear a notice.
Protecting Pilot Flying J Assets and Brand Name
Each Team Member is entrusted with Pilot Flying J’s assets and honoring that trust is a basic
responsibility to each other and to Pilot Flying J. We must protect Pilot Flying J assets from
loss, damage, misuse or theft. Theft of property, inventory for sale, equipment or money
from Pilot Flying J, vendors or guests will not be tolerated and will be grounds for
immediate termination. This includes paid time when compensated by Pilot Flying J. Use
of Pilot Flying J assets for purposes other than Pilot Flying J business requires prior
authorization by appropriate levels of management. Consult your immediate supervisor
about the authorization needed for any non-business use of Pilot Flying J assets.
Computer Applications and Software
The following four directives apply to all computer and electronic systems owned and
installed by Pilot Flying J for the express purpose of assisting us in the efficient operation
of our Travel Centers, Convenience Stores, Restaurants and Corporate Offices:
System Integrity
Hardware, peripheral attachments, and all installed software on electronic systems owned
by Pilot Flying J may not be modified, added to or deleted without the express permission
of Technology Services or the Division Director or the Region Manager in consultation with
Technology Services. At no time may a Pilot Flying J Team Member use, or allow to be
used, any personal hardware or software on any Pilot Flying J electronic systems.
No software program such as but not limited to: audio cd’s, internet provider software,
screen savers, etc., or any portion thereof, may be copied or transferred from Pilot Flying J
electronics systems under any circumstances. No additional communications programs
such as on-line or Internet access software may be installed on any Pilot Flying J electronic
system. Pilot Flying J telephone access lines may not be used to transmit or receive any
data other than authorized Pilot Flying J business-based information.
All Pilot Flying J electronics systems must maintain the original desktop configurations,
properties or “ini.” files in order to allow the system to function properly.
System Security
All data entered and stored on Pilot Flying J electronic systems, disks, and tapes is the
property of Pilot Flying J and is considered proprietary and confidential. Data stored on
these systems is to be treated as such and reasonable steps must be taken in order to
protect the information from unnecessary loss, improper modification, or damage.
All data entered and stored on Pilot Flying J electronic systems must be “backed up” or
saved on a daily basis. Failure to save this data can result in a serious loss of information in
the event of an equipment failure. If a loss of operational data is caused by an individual’s
negligent failure to save data on a daily basis, it may be cause for disciplinary action, up to
and including termination.
Pilot Flying J is consistently working to better protect our systems and data with improved
processes and technologies. Any attempts to circumvent the processes and technologies
that are in place will result in the appropriate disciplinary action up to and including
termination of employment.
PFJ Standards of Business Conduct
February 2016
Page 17
In order to protect the confidentiality of Pilot Flying J data, as well as to deter the
introduction of outside virus infections, electronic data may not be transferred from one
operations facility to another without the prior approval of the Manager of Operations
Technology, the Division Director, and the Region Manager.
Personal Use of Pilot Flying J Technology
The use of Pilot Flying J Technology to view or store pornography or visiting any other sites
that create a hostile or sexually charged workplace is strictly prohibited. “Surfing” the
world-wide web during work hours is prohibited. It amounts to time abuse and subjects
Pilot Flying J technology to viruses and spyware. The use of Pilot Flying J Technology to
engage in online gambling is also strictly prohibited. E-mail and Voicemail should not be
utilized for personal purposes such as, but not limited to, outside business ventures,
political or religious causes, or social media. This policy will be treated like all other Pilot
Flying J policies, and non-compliance will result in the appropriate disciplinary action up
to and including termination of employment.
Example:
Q: I have my own business and do a lot of my business over the internet. I have been
using my Pilot Flying J’s computer to send e-mail and search the internet for my
own business on my lunch break and after work. Is this okay?
A: No. Using Company equipment and/or internet service to pursue or conduct non-
Pilot Flying J’s business is not acceptable.
E-Mail Policies
The e-mail system (which includes the Internet access and Outlook/Microsoft Exchange
Servers) is the property of Pilot Flying J. Pilot Flying J reserves the right to review, audit,
intercept, access, disclose, or handle accordingly all messages composed, sent, and
received on the e-mail system at any time for any purpose. The contents of any Team
Member’s e-mail may be disclosed to Pilot Flying J management without the permission
of the Team Member when properly authorized and doing so is for a legitimate business
purposes. However, unauthorized access of another Team Member's electronic mail is
strictly prohibited.
Be selective when addressing e-mail and using DISTRIBUTION GROUPS. As more and
more Pilot Flying J Team Members gain access to Outlook/Microsoft Exchange Servers and
Intra-Company e-mail, it becomes increasingly important to use the e-mail functionality
in the most appropriate way possible. In an effort to use e-mail more efficiently, Team
Members should limit message recipients to those on a “need-to-know” basis or an interest
in the information provided in the message. Blast emails regarding personal items (such as
the sale of tickets for an event by a Pilot Flying J Team Member) are strongly discouraged,
as such emails disrupt the efficiency of all Pilot Flying J Team Members. If in doubt, ask
your supervisor on whether a “blast” email to numerous Team Members is appropriate.
A Team Member should answer “no” to enabling macros if they receive a file that contains
a macro. First, open the file, and view its contents without enabling the macros. Once it
is determined that the macros are needed, close the file then reopen the file with the
macros enabled. Macros can sometimes contain damaging viruses. If a Team Member has
a question whether or not a macro should be enabled or may be damaging please contact
the Helpdesk or Desktop Support.
Refrain from creating, sending, or forwarding “chain letters” or jokes in e-mail. If a Team
Member receives an unsolicited “chain letter” or joke from an external or internal user,
delete it. The content of e-mail can be extremely damaging to Pilot Flying J if it contains
statements that you, as a Team Member of Pilot Flying J, would not be proud of if it was
PFJ Standards of Business Conduct
February 2016
Page 18
published on the front page of your hometown newspaper. Please be mindful of that
standard when creating, sending, or forwarding e-mail.
Please note that Pilot Flying J Team Members have no privacy rights when it comes to use
of Pilot Flying J hardware, software or technology.
Social Media Policies
Team Members may maintain personal websites or blogs on their own time (i.e. while not
on the PFJ time clock) using their own facilities. Team Members must ensure that social
media activities do not interfere with their work. In general, Pilot Flying J considers social
media activities to be personal endeavors, and Team Members may use them to express
their thoughts or promote their ideas, on their own time and with their own devices, as
long as they do not conflict with Company policies or business. In addition, all Team
Members should be aware that anything posted on social media is open to the public. As
such, violations of the Social Media Policy, including but not limited to posting financial,
confidential or proprietary information about Pilot Flying J, defamatory, discriminatory or
illegal remarks, falsely representing Pilot Flying J or violating state, federal or local law can
result in discipline of the team member, up to and including termination. Please refer to
and learn PFJ’s Social Media Policy, which is available on Pilot Flying J’s HUB under “My
Info: Social Media” for explicit rules and instructions on using social media at Pilot Flying J.
PFJ Standards of Business Conduct
February 2016
Page 19
FINANCIAL INTEGRITY AND
RESPONSIBILITY
Financial integrity and fiscal responsibility are core aspects of corporate professionalism.
The money we spend on behalf of Pilot Flying J is not ours; it’s the Company’s and,
ultimately, our owners’. Each person at Pilot Flying J – not just those in Finance – has a
role in making sure that money is appropriately spent, our financial records are complete
and accurate and internal controls are honored. This matters every time we hire a new
vendor, expense something to Pilot Flying J, sign a new business contract or enter into any
deals on Pilot Flying J’s behalf.
To make sure that we get this right, Pilot Flying J maintains a system of internal controls to
reinforce our compliance with legal, accounting, tax and other regulatory requirements in
every location in which we operate.
Spending Pilot Flying J’s Money
A core Pilot Flying J value has always been to spend money wisely. When you submit an
expense for reimbursement or spend money on Pilot Flying J’s behalf, make sure that the
cost is reasonable, directly related to Company business and supported by appropriate
documentation. Always record the business purpose (e.g., if you take someone out to
dinner on Pilot Flying J, always record in our expense reimbursement tool the full names
and titles of the people who attended as well as the reason for the dinner) and comply
with other submission requirements of our Concur system. If you’re uncertain about
whether you should spend money or submit an expense for reimbursement, check with
your supervisor. Supervisors are responsible for all money spent and expenses incurred
by their direct reports, and should carefully review such spend and expenses before
approving.
Signing a Contract
Each time you enter into a business transaction on Pilot Flying J’s behalf, there should be
documentation recording that agreement, approved by the Law Department. Signing a
contract on behalf of Pilot Flying J is a very big deal. Never sign any contract on behalf of
Pilot Flying J unless all of the following are met:
o
You are authorized to do so under our Financial Approval Authority Matrix. If
you are unsure whether you are authorized, ask your supervisor or department
head;
o
The contract has been approved by the Law Department. If you are using an
approved Pilot Flying J form contract, you don’t need further Law Department
approval unless you have made changes to the form contract or are using it
for other than its intended purpose; and
o
You have studied the contract, understood its terms and decided that entering
into the contract is in Pilot Flying J’s interest.
All contracts at Pilot Flying J must be in writing and should contain all of the relevant
terms to which the parties are agreeing – Pilot Flying J does not permit “side agreements,”
oral or written. You should also send a copy of the signed contract to the Law
Department for the contract management system.
Purchasing Practices
All purchasing decisions will be based on the best value realized by Pilot Flying J and in
alignment with our business standards and goals. Important components of purchasing
include competitive bids, partnering arrangements, incentive-based contracts, quality
verification, confirming the legal and financial condition of the supplier, and avoiding
personal conflicts such as dealing with family members or friends of Pilot Flying J Team
Members. The Conflict of Interest Section above should be considered in all purchasing
decisions.
PFJ Standards of Business Conduct
February 2016
Page 20
If you have been entrusted with a Pilot Flying J Purchasing Card or Pilot Flying J Travel
Card, you are bound by the respective card’s terms and agreements. The use of the
Purchasing Card for purchase of personal items is against Pilot Flying J policy and makes
you subject to disciplinary action up to and including termination.
Business Records and Communications
When Pilot Flying J creates or maintains reports, records and communications, the Team
Members are also responsible for the integrity of those records. It is against this Standards
of Business Conduct to make false or misleading entries in Pilot Flying J books or records.
All financial reports, sales reports, expense reports, time sheets, accounting records and
other similar documents must be true and accurate to the best of your knowledge and
belief. If you are uncertain of the validity of an entry or report, raise your concern to the
best source for correcting it, which will most likely be your immediate supervisor. Never
allow yourself to be part of a chain of incorrect information. No Pilot Flying J Team
Member should ever destroy or alter any documents or records in response to any
investigation, suspected investigation, anticipated litigation, litigation or lawful request,
whether internal or external. Please refer any external requests for documents to the Law
Department.
Employment documentation that is not accurate is also strictly prohibited. Falsification of
reports regarding: employment applications; absence from work; claims made about
injuries while on the job or on Company premises; claims made under benefit plans
provided by Pilot Flying J and falsification of Company communications or time sheets are
strictly prohibited and may be grounds for termination from Pilot Flying J.
COMMUNITY INVOLVEMENT
Personal Activities
Pilot Flying J understands the need for balance between work, personal and family life, and
we encourage Team Members to be involved in their communities. However, Team
Members should not impose their personal beliefs or opinions on other Team Members or
represent their personal opinions as those of Pilot Flying J.
You may keep your personal activities outside of the workplace confidential, but always
keep in mind that you are a representative of Pilot Flying J. Your conduct can affect
perceptions of Pilot Flying J’s brand and service.
Political Activities
Many governments have laws prohibiting or regulating corporate contributions to political
parties, campaigns or candidates in the form of cash or the use of Pilot Flying J facilities,
aircraft, automobiles, computers, mail services or personnel. Team Members who
communicate with government officials on issues that affect Pilot Flying J should contact
the Law Department to ensure that such activities fully comply with the law and that Pilot
Flying J’s lobbying efforts are coordinated. We respect the right of each of our Team
Members to participate in the political process and to engage in political activities of his or
her choosing. While involved in their personal civic and political affairs, however, Team
Members must at all times make clear that their views and actions are their own, and not
those of Pilot Flying J. Team Members may not use Pilot Flying J resources to support their
choice of political parties, causes, or candidates.
Public Relations
All information disclosed outside the Company must be accurate, complete and consistent,
and disseminated in accordance with Pilot Flying J’s policies. We all represent Pilot Flying
J; if someone asks you for information (for example, the media), be sure to notify your
PFJ Standards of Business Conduct
February 2016
Page 21
manager or department head about the request and/or direct the person to the Media
Relations Manager at corporate headquarters. They will contact the appropriate party to
ensure that the correct procedure is followed. Please do not attempt to answer these
questions yourself.
The standards and policies stated herein are not all the applicable Pilot Flying J standards
and policies nor are they a comprehensive or complete explanation of the laws that are
applicable to Pilot Flying J and its Team Members. All Pilot Flying J Team Members have
a continuing obligation to familiarize themselves with applicable laws relating to their
job responsibilities and all Pilot Flying J policies. Breach of these standards, Pilot Flying
J policies or the law may give rise to disciplinary action up to, and including dismissal.
The standards and policies discussed herein may be amended from time to time. Team
Members should access the Standards of Business Conduct posted on the employee
HUB for the most current version.
PFJ Standards of Business Conduct
February 2016
Page 22
Frequently Asked Questions:
Q: What is Pilot Flying J’s Compliance & Ethics Office?
A: Pilot Flying J’s Compliance & Ethics Office is a department that supports our Mission
and Values and helps protect our culture and our reputation by providing resources
that help Team Members make ethical decisions at work.
Q: What are Pilot Flying J’s Standards of Business Conduct?
A: The Standards of Business Conduct is a resource distributed to all Team Members
to help them make appropriate decisions at work. The Standards are a brief
statement of some of the Company’s expectations of how we are all to conduct
Pilot Flying J business.
Q: What am I expected to do with the Standards of Business Conduct?
A: Read the Standards carefully at work and make sure that you understand them. If
you have any questions or concerns, ask the Compliance & Ethics office.
Q: What is PFJ Listens?
A: PFJ Listens is a program for reporting issues or raising concerns that involve ethics,
legal issues or potential violations of Pilot Flying J policy, including the Standards of
Business Conduct and our core values. The PFJ Listens Integrity Line and web portal
are managed by a third party, 24 hours a day, seven days a week. In addition to the
Integrity Line and web portal, Team Members have several other options to report
issues and/or seek advice including contacting the Compliance & Ethics Office at
PFJListens@pilottravelcenters.com or speaking directly to their HR Business Partner
or Regional Manager.
Q: What happens when an individual contacts PFJ Listens Integrity Line?
A: Calls to the PFJ Listens Integrity Line are answered by a third party outside of Pilot
Flying J. Trained specialists speak with callers regarding their questions or concerns
and then forward a report to Compliance & Ethics Office who works with the
appropriate party or department for investigation and any appropriate action.
Q: May I contact PFJ Listens anonymously?
A: Yes, you may remain anonymous when contacting the PFJ Listens Integrity Line and
web portal. You will be given a unique report number, which will allow you to call
the Integrity Line or web portal to check on the status of your report. Calls and
submissions through the web portal are not traced and are handled in a confidential
manner. However, we encourage Team Members to provide their names and
contact information because issues can be more difficult to investigate or additional
facts may be needed to appropriately investigate the issue.
Pilot Flying J cannot guarantee anonymity if you identify yourself or give
information from which you can be identified, but the Company will take every
reasonable precaution to assure that the identity of a caller remains as confidential
as possible and only shared on a need to know basis to conduct an effective
investigation.
Q: Can I be retaliated against or victimized for reporting or raising a concern?
A: Pilot Flying J has a strict policy against retaliation and does not tolerate retaliation
against or the victimization of any Team Member who raises concerns or questions
regarding a potential violation of law, the Standard of Business Conduct or any Pilot
Flying J policy that he or she reasonably believes to have occurred.
