INTRODUCTION

The purpose of this code of ethics policy is to ensure that all employees of Morris Communications Company and its subsidiaries know that this company expects and will accept no less than the highest standards of ethical and professional conduct from all employees.

This code sets out basic principles to guide all employees’ business behavior with the overriding principle being that all Morris employees are expected to avoid even the appearance of impropriety in all business dealings.

Any employee who violates the standards in this code of ethics will be subject to disciplinary action.  Any employee who believes himself or herself to be in a situation that may violate this code should follow the guidelines for reporting such violation outlined in this document.

CONFLICT OF INTEREST

Should an employee discover that his or her own private interest interferes with the interest of Morris, then a conflict of interest has arisen.  No Morris employee should become involved in any business or situation that might benefit or profit him or her at the expense of Morris business interests.

Employees should avoid any direct or indirect business connection with Morris customers, suppliers or competitors (except on behalf of Morris) as such relationships will almost always set up a conflict of interest for the employee.  Employees should also take care to avoid any appearance of impropriety and must disclose to their supervisor any material transactions or relationships that reasonably could be expected to give rise to a conflict of interest.

Acceptance of gifts can result in a conflict of interest.  Neither should employees offer gifts within the confines of a business relationship outside the following guidelines:

• The gift is not cash
• The gift is consistent with customary business practices
• The gift is not excessive in value; that is, the gift’s value should be less than $25.00
• The gift cannot be interpreted as a bribe
• The gift does not violate any law or regulation

Before any employee accepts any gift from any business entity, he or she should discuss the matter with management.

Other examples that would be considered a conflict of interest and in violation of this policy are:

• Taking or using Morris property for personal use, such as using Morris computer systems for personal business.
• Writing a personal letter of complaint on Morris stationery.
• Accepting a reward from a supplier or provider of services in exchange for business with Morris.
• Using employee status with Morris in inappropriate ways, such as to gain special consideration from authorities such as the police and to obtain (for personal purposes) information not available to the general public.
• Hiring a family member as a vendor or consultant without obtaining management approval.
• Working for another employer outside of working hours that proves to have a negative effect on the work the employee is doing for Morris.

This is in no way a comprehensive list but rather is intended to serve as examples for conflicts of interest.  If any employee has a question about whether an activity establishes a conflict of interest or not, that employee should discuss the matter with a manager.

COMPLIANCE WITH LAWS, RULES, AND REGULATIONS

Morris Communications Company expects all employees to respect and obey the laws of the cities, states and countries in which we operate.  While it’s impossible for any one person to know all the details of all laws, we expect our employees to have a working knowledge of the appropriate laws and just as importantly to know when to ask for advice from a manager regarding legal matters.

DISCLOSURE POLICY

It is Morris’s policy that all disclosures in financial reports and public documents that it files with or submits to the Securities and Exchange Commission (SEC) and in other public communications of a like nature made by Morris should be full, fair, accurate, timely and understandable.  Members of Morris’s senior management have the general responsibility for preparing SEC filings and other communications and will at all times endeavor to remain fully informed with respect to these matters and to see that such filings and communications comply with this disclosure policy.  In addition, employees of Morris should inform senior management if they learn that information in any filing or communication was untrue or misleading at the time the filing or communication was made or if they have information that would affect any such filings or communications to be made in the future.

MORRIS COMPETITION STANDARDS

Morris Communications Company is committed to open and fair competition in all our business dealings, both in our businesses and with the companies that do business with us.  Under no circumstances will unethical or illegal business practices be tolerated by this company.

Individuals who work for Morris are expected:

• To not disparage competitors, their products or their services
• To maintain arms-length relationships in all business opportunities
• To keep management informed of all business matters and especially those that might be of a sensitive nature

RECORD KEEPING

The recording and reporting of information must be honest and accurate at all levels of the Morris organization.  All employees are required to read, review, and verify the accuracy of all information on documents (e.g., check request, commission calculation) requiring their approval/signatures before approving the document.

The records, accounts, financial statements and all company books must be maintained in appropriate detail and must accurately reflect Morris’s transactions. All corporate records must be true, accurate and complete.  Company data must be promptly and accurately recorded in our financial systems in accordance with Morris Communications’s internal controls and other applicable accounting principles and legal requirements.

All documents relating to payroll actions must be approved by the appropriate parties and submitted to Human Resources prior to the effective date of that action.

All business records should be retained or destroyed according to our policies.  Under no circumstances should any business records be destroyed after knowledge of litigation or government investigation has been received.

CONFIDENTIAL INFORMATION

All employees who have access to confidential information must respect the responsibility Morris has to keep certain information confidential.  Such confidential information can be Morris business-based or customer-based.  Only when required by laws or regulations or when advised by Morris legal representatives should any confidential information be disclosed to any third party.

Also included in such confidential information is the requirement Morris has to keep certain employee information confidential.  All employees who have access to confidential employee information must take all precautions to keep employee personal information confidential.  Employees are prohibited from endorsing, recommending or providing employment information about other employees (past or current).  Human Resources personnel will provide limited information to third parties such as job title, hire and term dates and in some instances salary information (salary rates are disclosed only if the employee gives his/her permission in writing).

POLITICAL ACTIVITY

Individuals may choose to participate and or contribute to political parties, causes, and candidates.  However, such activity or contributions may not be represented as being on behalf of Morris Communications Company or any individual business unit.  Morris funds cannot be used for political contributions.

PROFESSIONAL CONDUCT

All employees of Morris Communications are expected to treat people with dignity, respect and compassion to foster a work environment free of harassment, intimidation, and unlawful discrimination. Employees should develop, administer and advocate policies and procedures that foster fair, consistent and equitable treatment for all.

Employees may not be physically or verbally abusive to others; this includes co-workers, supervisors, vendors, contractors, and customers. Employees may not engage in offensive or unsafe behavior. All Morris employees are expected to abide by all applicable policies regarding employee conduct.

REPORTING ILLEGAL OR UNETHICAL BEHAVIOR

Every employee of Morris Communications Company is expected to report what he or she believes in good faith are violations of the law or of Morris policy, whether accidental or deliberate, by any other Morris employee.  Should you become aware of a violation, it is your responsibility and obligation to disclose the matter fully to your supervisors.  The failure to report such violations is itself a violation of Morris policy.

When appropriate, employees should report violations to local management.  Under some circumstances, employees should report violations to someone on the corporate staff.  Employees may write or call any corporate staffer with such information.

Those who have a concern about a policy violation or ethical concern are to call or email:

[email protected]
Phone: (844) 301-2376 or (706) 828-4363

You may report ethical violations in confidence and without fear of retaliation.  Morris Communications Company does not permit retaliation of any kind against employees for good faith reports of ethical violations.

For more details, download this ReportAConcern poster. (.pdf file)