Receivable Acquisition & Management Corporation (the "Company") maintains a Business Conduct and Ethics Policy applicable to all directors and employees of the Company including the Chief Executive Officer ("CEO"), the Chief Financial Officer ("CFO"), the principal accounting officer and all senior financial officers. The provisions of the Policy cover ethical conduct, conflicts of interest and compliance with law. In addition, the CEO, CFO and all senior financial officers are subject to the following additional specific policies.

  • The CEO, CFO and all senior financial officers are responsible for full, fair, accurate, timely and understandable disclosure in the periodic reports required to be filed by the Company with the SEC. Accordingly, it is the responsibility of the CEO, CFO and each senior financial officer promptly to bring to the attention of the Disclosure Committee of the Company (the Disclosure Committee) any material information of which he or she may become aware that affects the disclosures made by the Company in its public filings or otherwise assist the Disclosure Committee in fulfilling its responsibilities.
  • The CEO, CFO and each senior financial officer shall promptly bring to the attention of the Disclosure Committee and the Audit Committee any information he or she may have concerning (a) significant deficiencies in the design or operation of internal controls which could adversely affect the Company's ability to record, process, summarize and report financial data or (b) any fraud, whether or not material, that involves management or other employees who have a significant role in the Company's financial reporting, disclosures or internal controls.
  • The CEO, CFO and each senior financial officer shall promptly bring to the attention of the General Counsel or the CEO and to the Audit Committee any information he or she may have concerning any violation of the Company's Business Conduct and Ethics policy, including any actual or apparent conflicts of interest between personal and professional relationships, involving any management or other employees who have a significant role in the Company's financial reporting, disclosures or internal controls.
  • The CEO, CFO and each senior financial officer shall promptly bring to the attention of the General Counsel or the CEO, and to the Audit Committee any information he or she may have concerning evidence of a material violation of the securities or other laws, rules or regulations applicable to the Company and the operation of its business, by the Company or any agent thereof, or of violation of the Business Conduct and Ethics Policy or of these additional procedures.
  • The Board of Directors shall determine, or designate appropriate persons to determine, appropriate actions to be taken in the event of violations of the Business Conduct and Ethics policy or of these additional procedures by the CEO, CFO and the Company's senior financial officers. Such actions shall be reasonably designed to deter wrongdoing and to promote accountability for adherence to the Business Conduct and Ethics policy and to these additional procedures, and shall include written notices to the individual involved that the Board has determined that there has been a violation, censure by the Board, demotion or re-assignment of the individual involved, suspension with or without pay or benefits and termination of the individual's employment or such other action as the Board may determine is appropriate under the circumstances. In determining what action is appropriate in a particular case, the Board of Directors or such designee shall take into account all relevant information, including the nature and severity of the violation, whether the violation was a single occurrence or repeated occurrences, whether the violation appears to have been intentional or inadvertent, whether the individual in question had been advised prior to the violation as to the proper course of action and whether or not the individual in question had committed other violations in the past.

Approved by the Board of Directors
October 9, 2003

 



Receivable Acquisition & Management Corporation & Subsidiaries

We collect certain personal information about our customers from the following sources: (a) information we receive from them, (b) information concerning their transactions with us, our affiliates, or others and (c) information we receive from consumer reporting agencies. We may disclose the following kinds of non-public personal information about our customers: (a) information we receive from our customers, such as names, addresses and social security numbers; (b) information about our customers’ transactions with our subsidiaries, affiliates or others, such as their account balance, payment history, parties to account transactions, and account usage; and (c) information we receive from a consumer reporting agency, such as credit histories.

We do not disclose any non-public personal information about our customers or former customers to anyone, except as permitted or required by law.

To maintain security of customer information, we restrict access to your personal and account information to persons who need to know that information. We also maintain physical, electronic, managerial and procedural safeguards to protect the privacy of your personal information and account information. We use software programs to create summary statistics, which are used for such purposes as assessing the number of visitors to the different pages of our web site. Your personal information is not revealed in these summaries. We urge you to take every precaution to protect your personal data when you are visiting our web site. We request that you never allow anyone else to have access to your personal account information or leave your computer unattended while visiting our web site.

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