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Use of Company funds or other Company property for illegal, unethical or otherwise improper purposes is prohibited. The purpose of business entertainment and gifts in a commercial setting is to create goodwill and a sound working relationship, not to gain personal advantage with customers or suppliers.
Gifts
Except as set forth below, without approval by the Office of Business Conduct and Ethics, employees and non-employee directors should refrain from giving and receiving business-related gifts.
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You may not solicit or accept a gift (including any payment, compensation, loan or other financial favor) to or from a person or organization with the intention of influencing the recipient’s business judgment or conduct relating to National. Giving or accepting unsolicited gifts having a nominal value where there is a business benefit or purpose for the gift and any benefits received which do not influence, or appear to influence, selection and purchasing decisions is permitted. In some countries, gifts having a greater value are customary and may be given or accepted with the approval of the Office of Business Conduct and Ethics.
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It is never appropriate or permissible to accept or give cash or a cash equivalent from or to a vendor, supplier or customer outside the Company’s normal business. Cash equivalents include, among other things, checks, money orders and vouchers.
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Rules relating to U.S. and foreign government personnel are more stringent. See "Doing Business Internationally" and "Government Contracting".
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No employee may accept a customer, vendor or supplier discount unless it is generally available to the public or is otherwise approved.
Loans
Employees may not accept loans from any person or entities having or seeking business with the Company. Designated Executives, other executive officers and Non-Employee Directors may not receive loans from the Company, nor may the Company arrange for any loan.
Meals, Entertainment, and Travel
 Employees may provide or accept meals and entertainment, including attendance at sporting or cultural events, as long as it is associated with an occasion at which business is discussed and is provided as a normal part of business. The value of the activity must be reasonable and permissible under National’s expense account procedures. Employees must insure that such activities are necessary, that they are properly documented, and that their value and frequency are not excessive under all the applicable circumstances. In addition to expense account reimbursed entertainment, you may entertain socially friends or relatives doing business with the Company and these occasions need not be documented provided that expenses for this entertainment are not reimbursable by the Company.
Rules relating to U.S. and foreign government personnel are more stringent. See "Doing Business Internationally" and "Government Contracting"
Investment Activities
Unless pre-approval is obtained, employees may not:
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participate in so-called “directed shares,” “friends and family,” and similar stock purchase programs of customers, vendors or suppliers of National;
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invest in non-public companies that are, or are likely to be, customers, vendors or suppliers of National; or
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invest in non-public companies in which National has made or is expected to make an investment.
Investments that you do not personally control, such as investments by funds or discretionary accounts that do not consult you before making an investment decision, are exempt from this requirement.
Non-Employee Directors who become aware that any of their personal investments fall into the above categories should disclose such to the Audit Committee.
Bribes and Kickbacks
The use of Company funds, facilities or property for any illegal or unethical purpose is strictly prohibited.
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You are not permitted to offer, give or cause others to give, any payments or anything of value for the purpose of influencing the recipient’s business judgment or conduct in dealing with the Company other than facilitating payments discussed in “Doing Business Internationally”;
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You may not solicit or accept a kickback or bribe, in any form, for any reason.
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