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F1, <br />ACZ Laboratories, Inc. August 10, 2007 <br />Quality Assurance Plan Version 12 <br />SOPAD018.08.07.12 Page 16 of 96 <br />ETHICAL AND LEGAL RESPONSIBILITY <br />I <br />All ACZ employees have an ethical and legal responsibility to produce data that is accurate, reliable, and legally <br />defensible. ACZ's proactive program for the prevention and detection of improper, unethical or illegal actions <br />includes the implementation in 2002 of an Ombudsman who acts as a neutral party and serves as a confidential <br />liaison between ACZ employees and upper management regarding questions, problems, complaints, suggestions, <br />or ethical dilemmas. <br />All employees are educated with regards to ACZ's Code of Conduct and Code of Ethics as well as ACZ's zero- <br />tolerance policy, which is strictly enforced. Additionally, employees are informed about the processes in place <br />to ensure employees are free from any undue internal or external commercial, financial or other pressures that <br />may adversely effect the quality of an employee's work, endanger the trust in the independence of ACZ's <br />judgment, or compromise the integrity of ACZ's environmental testing activities. A more detailed description <br />of all aspects of the ethics program is provided in ACZ's SOP Ethics and Proactive Prevention Program <br />(SOPAD039). <br />ACZ will not tolerate any unethical or improper activities or behavior. Violation of company policies may lead <br />to repercussions ranging from a severe reprimand to termination, and possible criminal prosecution if <br />warranted by the situation. ACZ has access to many resources that may be utilized at any time to help clarify <br />any situation determined to be a "gray area." Employees are strongly encouraged to seek further guidance <br />from a supervisor, ACZ's Ombudsman, President or QA/QC staff whenever doubt is raised. Activities that <br />will not be tolerated include, but are not limited to: <br />• Misrepresentation of a procedure or documentation - Intentionally performing a job duty in a manner that <br />does not comply with a documented procedure, including but not limited to a test SOP or method used for <br />sample analysis; providing inaccurate and misleading documentation associated with a data package or failing <br />to provide the necessary documentation as part of a data package. <br />• Falsifying Records - Providing false information on personal credentials, resumes or educational transcripts, <br />logbooks, raw data and client reports, or creating data without performing the procedure (also known as dry <br />labbing). <br />• Improper peak integration - Intentionally performing improper integration of data chromatograms so <br />quality control samples meet acceptance criteria. This is also known as peak shaving or peak enhancing <br />• Improper clock setting - Readjusting the computer clock so that it appears samples were analyzed within <br />hold times. <br />• Improper representation of Quality Control samples - Failing to treat batch quality control samples in the <br />same manner as client samples (including Proficiency Testing samples) or misrepresenting any type of quality <br />control sample associated with the preparation batch and/or analytical batch. <br />• Improper calibration - Intentionally performing improper manipulation of calibration data or forging tune data <br />so that it meets acceptance criteria. <br />• File Substitution - Replacing invalid data with valid data from a different time so the analysis appears to be <br />successful. <br />2773 Downhill Drive 970-879-6590 <br />Steamboat Springs, CO 80487 www.acz.com <br />