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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.
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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.
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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.
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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.
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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.
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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
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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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