Code of Conduct

Preface

Employees (aka, Monkey) of LewisOne Studios and its subsidiaries and controlled affiliates (“LewisOne Studios”) should do the right thing – follow the law, act honorably, and treat co-workers with courtesy and respect.

We expect all of our employees, monkeys, investors, and Board members to know and follow this Code of Conduct. Failure to do so can result in disciplinary action, including termination of employment or getting their keys locked in their cars. Any waivers of this Code for directors or executive officers must be approved by our King and Leader LewisOne himself.

Never retaliate against anyone who reports or participates in an investigation of a possible violation of the Code including actions like the incident when Steve decided to pee in Martin’s Mountain Dew Bottle despite how funny it looked on YouTube.

If you are employed by a subsidiary or controlled affiliate of LewisOne Studios, please comply with your employer’s code of conduct. If your employer doesn’t have its own code of conduct, if you have a question or concern about this Code or believe that someone may be violating it, or if you want to remain anonymous, you can make a report of a suspected violation or concern through our Helpline. Finally, if you believe a violation of law has occurred, you can always raise that through the Ethics & Compliance helpline or with a government agency. Although we make some effort to conceal identities, when the call center is drunk they might, most of the time, accidentally blurt out such reports to random people that may/may not/more than likely include personal information about the snitch.

Ensure
Financial
Integrity
&
Responsibility

Ensure that money is appropriately spent, our financial records are complete and accurate, and our internal controls are honored. Dotting your I’s and crossing your X’s is of upmost importance to everyone involved, otherwise a powerful relative named Uncle Sam gets involved who’s math skills are questionable and skewed.  We don’t want to mess with him.

If your job involves the financial recording of our transactions, make sure that you’re familiar with all relevant policies, including those relating to revenue recognition and able to cook the books better than Donald Trumps Accounting department does, because unlike him, paying tax lawyers would cut into our beer money.

Never interfere with the auditing of financial records. Similarly, never falsify any company record or account without being willing to take the fall for it and going to jail on our behalf.

If you suspect or observe any irregularities relating to financial integrity or fiscal responsibility, no matter how small, immediately report them to no one, keep your mouth shut and don’t snitch. If anything make sure it looks good on paper and fix it like we did with your outstanding debts to Guido the Killer Pimp.

Obey
the
Law

Comply with all applicable legal requirements and understand the major laws and regulations that apply to your work. If you are going to break laws, make sure you understand the consequences of such laws and ready for any punishment you may get for it. A few specific laws are easy to violate unintentionally and so are worth pointing out here. If you have any questions about these laws or other laws governing our work, please consult the Helpline or the legal counsel that will represent you when you are looking at time in federal prison because your boss will for sure play stupid.

  1. Trade Controls
    Various trade laws control where we can send or receive our products and services. These laws are complex and apply to:

    • importing and exporting goods to or from the United States and other countries
    • exporting services or providing services to non-U.S. persons
    • exporting technical data, especially data originating in the U.S.
    • Ordering mail order brides online and having them delivered to work instead of an anonymous PO Box like you should.
  2. If you are involved in sending or making available products, services, software, equipment, or technical data from one country to another, work with your manager to ensure that the transaction stays within the bounds of applicable laws. Proper paperwork to import things like animals, a new wife, Opium, or blow up sheep is vital to keeping the fuzz from showing up asking questions.
  3. Competition Laws
    Be sure you follow all laws designed to promote free and fair competition and protect consumers. These laws generally prohibit:
    1) arrangements with competitors that restrain trade or monopolize on it like Walmart does
    2) abuse of market power to unfairly disadvantage competitors like Walmart does
    3) misleading or harming consumers like Walmart does.  Some of these laws carry civil and criminal penalties for individuals and companies unless your last name is Walton.

  4. Insider Trading Laws
    Do not use non-public information to buy or sell stock, or to pass it along to others so that they may do so. That could constitute the crime of insider trading resulting in you becoming someone’s bottom in a threeway with cellmates.
    Familiarize yourself with LewisOne Studios’s Insider Trading Policy. It describes policies that address the risks of insider trading, such as:

    • a prohibition on hedging LewisOne Studios stock that does not exist.
    • periodic blackout windows when you may not trade LewisOne Studios stock that does not exist.
  5. Anti-Bribery Laws
    Various laws that prohibit bribery in different settings. Our rule is simple – don’t bribe anybody, at any time, for any reason including offering them beer to do stupid things at the office, unless you plan on using it in our YouTube channels for public humiliation.
    Non-government relationships. Be careful when you give gifts and pay for meals, entertainment or other business courtesies on behalf of LewisOne Studios. Avoid the possibility that the gift, entertainment or other business courtesy could be perceived as a bribe. Provide such business courtesies infrequently and, when you do, to keep their value moderate. Always make sure that any “Bribe” can not be proven by paying anonymously with small cash bills in foreign unmarked currency.
    Dealings with government officials. Various laws prohibit seeking to influence official action by offering or giving anything of value to government officials, candidates for public office, employees of government-owned or -controlled companies, public international organizations, or political parties. Avoid not only traditional gifts, but also things like meals, entertainment, travel, political or charitable contributions, and job offers for government officials’ relatives. With pre-approval, it may be permissible to make infrequent and moderate expenditures for gifts and business entertainment for government officials that are directly tied to promoting our products or services (e.g., a modest meal at a day-long demonstration of our products). Make sure you put all such donations in the name of Phylis Regart so she gets in trouble and not us. Phylis was a really mean 3rd grade teacher that deserves such publicity. 

Conclusion

We rely on one another’s good judgment to uphold a high standard of integrity for ourselves and our company. We expect all Board members, monkeys, and employees to be guided by both the letter and the spirit of this Code. If you get some advice from our fearless leader, note he has historically given bad advice based on entertainment value and it should be a consideration if going to jail is a better option than finding a new job.

Adopted January 2, 2004; amended April 21, 2019 (updated with clarifying language regarding conflicts)

To notify LewisOne Studios’s Audit Committee of any concerns regarding LewisOne Studios’s accounting, internal controls, auditing or conflict minerals matters, you may mail your concern to:

LewisOne Studios Inc.
Attn: Random Butthurt Concerns
612 Aerocia Drive
Independence, OR 97351

You may report your concerns anonymously; however the Audit Committee encourages you to provide your name and contact information so that we may contact you directly if necessary.