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Business Ethics and Conduct

The successful business operation and reputation of Meridian is built upon the principles of fair dealing and ethical conduct of our employees. Our reputation for integrity and excellence requires careful observance of the spirit and letter of all applicable laws and regulations, as well as a scrupulous regard for the highest standards of conduct and personal integrity. Meridian will comply with all applicable laws and regulations and expects its Trustees, employees, officers, and agents to conduct business in accordance with the letter, spirit, and intent of all relevant laws and to refrain from any illegal, dishonest, or unethical conduct.

In general, the use of good judgment, based on ethical principles, will guide Trustees, employees, officers, and agents with respect to lines of acceptable conduct. If a situation arises where it is difficult to determine the proper course of action, the Trustee, employee, officer, or agent should discuss the matter openly with the immediate supervisor, and if necessary, consult with Meridian’s Human Resources for advice and guidance.

Compliance with this policy of business ethics and conduct is the responsibility of every Meridian Trustee, employee, officer, and agent. Disregarding or failing to comply with this standard of business ethics and conduct may result in disciplinary action, up to and including immediate termination of employment. Conflicts of Interest The purpose of this policy is to avoid conflicts of interest and any other situation that might give rise to questions about Meridian’s integrity and ethics.

It is critical that Meridian Trustees, employees, officers, or agents, members of a Trustee’s, employee’s, officer’s, or agent’s immediate family, or persons with whom a Trustee, employee, officer, or agent shares or has shared, within the last year, a mutual residence and with whom the Trustee, employee, officer, or agent has maintained a committed relationship, refrain from conduct that constitutes an actual conflict of interest or gives the appearance of a conflict of interest.

Examples of actual or perceived conflicts of interest include, but are not limited to: Engaging in activity to benefit Meridian competitors directly or indirectly. Using the confidential information of Meridian or Meridian’s partners for personal benefit or profit or the benefit or profit of another party. Using Meridian funds, confidential or proprietary information, property, or services for personal use or for the profit or benefit of another party.

Exploiting a relationship developed in the course of Meridian business for personal benefit or for the profit or benefit of another party. Accepting special favors or gifts offered based upon the Trustee’s, employee’s, officer’s, or agent’s relationship to Meridian. Performing services for a partner or Meridian competitor, whether as a Trustee, employee, officer, or agent, or an independent contractor, regardless of whether remuneration is to be provided to the Trustee, employee, officer, or agent unless such services have been expressly approved, in writing, by Meridian Human Resources.

Engaging in outside employment that conflicts with the interest of Meridian. All Trustees, employees, officers, and agents must disclose in writing outside employment or engagement in consulting for others, prior to the commencement of such outside employment or consulting to Meridian Human Resources, unless it is beyond dispute that such activity could not present a conflict of interest, potential conflict of interest, or the appearance of a conflict of interest.

All conflicts of interest or appearances of conflicts of interest must be resolved. Authorization to engage in conduct that constitutes a potential conflict of interest or the appearance of a conflict of interest must be obtained from Meridian Human Resources. Trustees, employees, officers, and agents are reminded that, in addition to this policy, Meridian maintains specific policies on other matters presenting a potential for a conflict of interest including policies on employment of relatives.

Violations of this policy may result in disciplinary action, up to and including immediate termination of employment. Accepting Gifts Trustees, employees, officers, and agents, members of Trustee’s, employee’s, officer’s, or agent’s immediate family, or a person with whom a Trustee, employee, officer, or agent shares or has shared, within the last year, a mutual residence and with whom a Trustee, employee, officer, or agent has maintained a committed relationship may not request or accept gifts, gift certificates, discounts or other benefits or gratuities from any individual, company, or organization supplying goods, merchandise, supplies, equipment, or services to Meridian; or from any individual, company, or organization that has a current working relationship with /Meridian and/or that would have financial interest and/or public policy views on issues affecting any of the programs that Meridian administers.

This provision does not extend to invitations to normal, reasonably-priced meals or beverages, paying for joint cab rides that are normal business practices, or gifts of food provided by vendors during the normal course of business, such as around the holidays. Financial Interest Trustees, employees, officers, and agents, members of Trustee’s, employee’s, officer’s, or agent’s immediate family, or a person with whom a Trustee, employee, officer, or agent shares or has shared, within the last year, a mutual residence and with whom a Trustee, employee, officer, or agent has maintained a committed relationship will disclose to Meridian Human Resources any financial interest, direct or indirect, in any business supplying goods or services to Meridian.