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1) We strive to present accurate and recent factual statements, to the best of our ability.
2) Our site offers independent judgment and analysis.
3) We present only our opinions. We are not an objective company: we only provide subjective opinions, comments, and reviews based on our informed opinions.
Business Relationships and Activities
Compliance with Law, Rules and Regulations
Political and Civic Activities
Books and Records
Compliance with this Code
Waivers or Amendments
Any and all information and other material obtained by our partners, bloggers, and writers is strictly their personal property. Such information includes not only our own work and that of our colleagues, but also information relating to future activities, including as-yet-unpublished news, information and advertising, as well as schedules for publishing the same. Sensitive information or confidential material is not disclosed privately, such as to family, friends, or social acquaintances, until that information is made available to the public.
- 10K Group LLC has long-term relationships with people and companies in our client and partner base. These relationships typically arise through past positions, books and articles, social networking connections, consulting, mentoring and training, and professional reference work. 10K Group LLC may receive compensation for consulting work for companies that we publish in our editorial and review pages.
- 10K Group LLC attends industry conferences and events, where attendees may acquire promotional items, including but not limited to pens, t-shirts, pins, and other items inscribed with company logos or mottos. Attendees may also visit events where companies provide food, drinks, and product samples. Some companies may provide travel or housing assistance for such events.
- 10K Group LLC members has access to product beta versions or formal beta testing prior to product announcements or service launches from companies in our industry. We may provide preview information as directed by any agreements with those companies.
- 10K Group LLC sometimes receives product samples, review copies of books, and advance copies of CDs, DVDs, and other media in preparation for publication. Any items to be reviewed typically appear in a "reviews" section of our websites. Managing members do not resell products: we may offer them as gifts or donations at our discretion.
- Website income may come from advertising sales, annual fees, ads such as Google Ads, and affiliate links from products where we receive a commission based on every sale. These affiliate links may be embedded within our pages.
- 10K Group LLC managing members, employees, staff and contractors may hold stocks and/or bonds in individual companies and/or funds that we cover in our articles and reviews.
Any information relayed to us is solely used for authorized purpose within our website and community.
10K Group LLC does not provide our customers or prospective customers, directly or indirectly, any gift, entertainment or reimbursement of expenses of more than nominal value or that exceeds customary courtesies for that time and place. Our representatives do not provide, directly or indirectly, any material, equipment or services to any individual in a position to make or influence any business or governmental decision affecting 10K Group LLC.
10K Group LLC does not requisition, order, approve or otherwise participate in the purchase of goods or services on behalf of 10K Group LLC from any person or entity if the employee or any member of the principal or employee's family or household has a substantial financial interest in the supplier or vendor.
The unauthorized duplication of computer software developed internally or obtained from outside suppliers is prohibited, regardless of whether such unauthorized duplication is for business or personal use. Additionally, all principals and employees must adhere to the Company's standards and policies regarding the use of its technology and computer equipment.
All principals and employees must obey the applicable laws, rules and regulations of the United States. All principals and employees of 10K Group LLC engaged in business outside of the United States must obey the applicable laws of countries in which they do business, and respect local culture and values while operating within the strictures of such laws and this code. All applicable trade agreements, including U.S. trade laws, must be honored and observed, including the U.S. Foreign Corrupt Practices Act, which generally makes it illegal to offer or give a bribe to a foreign official or candidate for foreign office, whether directly or through third parties such as consultants or agents.
It is the Company's policy that all disclosures made by the Company in its tax-related filings should be accurate, complete, understandable to the reader and fairly present the Company's financial and business condition and results of operations in all material respects. All such filings should be made on a timely basis as required by applicable laws and the requirements of any exchange on which the Company's securities are listed or traded. It is the duty and responsibility of the member managers, the chief executive officer, the chief financial officer and the controller to carry out this policy.
All 10K Group LLC employees are expected to conduct themselves at all times in a manner that leaves no grounds for belief, or even suspicion, that:
An employee, an employee's family, or anyone else connected to an employee made financial gains by acting on the basis of "inside" information obtained through employment before that information was available to the general public; such information includes hold-for-release material or publishing plans with respect to news, advertising or other information, as well as any other items that might affect movements in the prices of any securities;
The creation or dissemination, or non-dissemination, of any news or other information was influenced by a desire to affect the price of any security;
An employee's personal financial situation with respect to investments is such that it creates a temptation to violate these rules; or
An employee is beholden to newsmakers, information providers, advertisers or market participants, creating a temptation to violate these rules.
In making personal investments, all employees must avoid speculation or the appearance of speculation. No employee of 10K Group LLC may engage in short selling of securities.
10K Group LLC does not contribute, directly or indirectly, to political campaigns or to political parties or groups seeking to raise money for political campaigns or parties, and 10K Group LLC does not and will not reimburse any employee for any political contribution made by an employee. All employees and members of senior management with any responsibility for sensitive information should refrain from partisan political activity judged newsworthy by their senior editor or in the case of senior management, the chief executive officer. Other political activities (including "issue oriented" activity) are permitted, but should not be inconsistent with this code.
However, 10K Group LLC does not dissuade employees, staff, contractors, and board members from participating actively in civic, charitable, religious, public, social or residential organizations. Such activities are permitted, and even encouraged, to the extent that they:
Do not detract from performance or effectiveness at work;
Do not, by their extensiveness, cause the Company to subsidize or appear to subsidize the activity; and
Do not otherwise violate this code. In the event that a conflict arises or may arise between an outside organization with which an employee is affiliated and the interests of 10K Group LLC, the employee should refrain from participating in the conflicting or potentially conflicting activity.
No 10K Group LLC employee should permit his or her company affiliation to be noted in any outside organization's materials or activities without the express written approval of a member of senior management, unless the employee serves as a representative of 10K Group LLC or unless the affiliation is noted as part of a broader description of the employee's identity.
It is essential to the successful operation of 10K Group LLC as a business that the integrity of our books and records be resolutely maintained. Therefore:
All 10K Group LLC funds, assets, and liabilities are fully and properly recorded on the Company's books and records;
No transaction shall be effected and no payment shall be made on behalf of 10K Group LLC with the intention or understanding that the transaction or payment is other than as described in the documentation evidencing the transaction or supporting the payment;
All employees shall comply with 10K Group LLC's accounting principles, procedures and controls, and no false, artificial or misleading entries in any books or records of the Company shall be made for any reason whatsoever;
No employee will issue or authorize anyone else to issue any Company document that is false or misleading;
No employee will knowingly accept and treat as accurate any false or misleading document prepared by a person not employed by 10K Group LLC; and
No employee will knowingly make any false or misleading statements to our external or internal auditors. Indeed, when questioned by any auditor, all employees should be fully forthcoming.
10K Group LLC strives to ensure that all employees, staff, and contractors are treated with dignity and respect. Among our goals are to make benefits and services available to employees to promote their well-being, to communicate effectively with employees, to ensure equal employment treatment, to maintain a safe work environment, to observe the terms of collective bargaining agreements where applicable, to assist employees in realizing their potential and maximizing their productivity, and to fairly evaluate and recognize performance.
For its part, the Company expects employees to perform excellent work in a cost-effective manner, to strive for quality and productivity, to follow directions and instructions, to properly care for facilities and equipment, to anticipate problems and suggest improvements, to treat other employees and clients and customers with honesty and courtesy, and to be energetic in the performance of tasks and fulfillment of goals.
10K Group LLC values the talents and contributions of its employees. The Company also seeks and values diversity among employees, recognizing that a mix of people enriches the Company and encourages creativity and business growth. 10K Group LLC's policy is to provide equal employment opportunities and advancement consideration to all individuals based on job-related qualifications and ability to perform the job, without regard to race, color, ancestry, national origin, religious creed, sex, disability, veteran status, sexual orientation, age or marital status. It is also 10K Group LLC's policy to provide a working environment that is free of intimidation or harassment based on any of these factors.
Complete statements of policies setting forth the Company's standards regarding personnel matters, and other matters relating to employment with 10K Group LLC are published by the Human Resources department.
10K Group LLC is committed to maintaining a safe work environment by eliminating all significant recognized hazards in the workplace, and to conducting business in an environmentally sound manner based on scientific understanding, customer needs and local requirements. Employees are required to comply with all applicable health, safety and environmental laws and regulations, and all related Company policies.
10K Group LLC takes this code of conduct very seriously. All employees and subcontractors of 10K Group LLC are responsible for compliance with all aspects of this code. All new employees shall be required to read this code at the outset of their employment, and to attest in writing that they have done so; all 10K Group LLC employees shall be required, at the time this code is first promulgated, to read it and so attest. In the case of all members of senior management, such written attestations shall be required once every two years.
The matters addressed by this code are sufficiently important that any lapse in judgment within the areas covered here may be considered serious enough to warrant discipline up to and including dismissal.
Any employee who has a question about or becomes aware of his or her own possible violation of this code or by any other employee, or who becomes aware that he or another employee is involved in a transaction or relationship that could reasonably give rise to an actual or apparent conflict of interest, should promptly discuss the situation with his or her supervisor or with the Deputy General Counsel or General Counsel. Every effort will be made to maintain the confidentiality of such discussions. The Company will not permit or tolerate any retaliation against any employee who makes a good faith report about a possible violation of the code by another employee.
Any waivers of or amendments to this code that apply to the member managers, chief executive officer, chief financial officer or controller may be made only by the board of directors or a committee of the board. Any such waivers or amendments will be disclosed promptly as required by applicable law.