Memorandum

To: All Employees

The AKC expects all employees to support its mission, policies and programs and to conduct themselves in the performance of their job duties, in an ethical manner. In addition, every AKC employee has certain responsibilities in regards to access and disclosure of confidential information.

The protection of confidential business information is vital to the interests and the success of AKC. Such confidential information includes business files — both hard copy and electronic.

AKC business files may only be accessed by those employees whose job duties require them to do so. The contents of those files may not be disclosed to anyone who does not have a business need to know.

Employees who improperly use, copy, or disclose the contents of confidential company files will be subject to disciplinary action, up to and including termination of employment and legal action, even if they do not personally benefit from the disclosed information.

Questions and concerns about business file access should be addressed to your division executive.

Conflict of Interest

Policy

It is the policy of The American Kennel Club that all employees avoid any conflict between their interests and those of the AKC. The AKC expects all employees to support its mission, policies and programs and to conduct themselves, in the performance of their job duties, in an ethical manner. The fundamental principles guiding this policy is that no AKC employee should have or appear to have personal interests or relationships that conflict with the best interests of the AKC.

Principles

No AKC employee may engage in outside work or activity, whether paid or not paid, that:

1. Distracts from the employee's job performance during normal working hours at the AKC;
2. Results in a product (such as a publication) that competes with any product of the AKC;
3. Might lead to disclosure of AKC confidential information;
4. Might impair the employee's independent judgment on behalf of the AKC or subordinate the AKC's interests to that of other persons or entities;
5. Might cause the employee to withhold work properly owned by the AKC in order to satisfy his or her obligation to another person or entity;
6. Might cause the employee to acquire a financial or proprietary interest in the substance or outcome of any work performed by the AKC; or
7. Might prescribe, direct or suggest when or how the employee should fulfill his or her obligations to the AKC.

The definitions of outside work includes speaking engagements, writing, editing, photographic or graphic arts assignments, consulting services, association activities, teaching positions, volunteer leadership roles and any other activity that might reasonably be expected to create an actual or potential conflict between the AKC's interests and that of another person or entity.

“Confidential Information” means any material related to the AKC's internal business affairs that is not made available or published for dissemination to the general public.

Nothing in this policy, however, shall be construed to limit the employee's freedom of association or action in areas where AKC's interest is not involved.

Employees Must Not

1. Show favor or preference to any contractors, suppliers, customers or other persons doing or seeking to do business with AKC based on anything other than appropriate business concerns.
2. Participate in any decisions as part of their duties as an AKC employee if their interest in any company or business concern might influence such decisions.
3. Participate in any decisions as part of their duties as an AKC employee if they stand to gain a financial or other benefit based upon the decision.
4. Offer, give, seek or accept for themselves or others any gifts, favors or benefits other than modest courtesies openly given and accepted as part of the usual business amenities, e.g. occasional business-related meals or promotional items of nominal or minor value.

As used in paragraph 2 above, the term “interest” means any ownership or positional connection but does not include the ownership of stock shares acquired solely for investment purposes in a company whose stock is listed on a recognized stock exchange or is actively traded over the counter.

Because of the special relationship of the AKC and its employees to the entire world of dogs, any employee obtaining a dog must be especially careful that a conflict of interest, or the appearance of such, is not created.

Purchase of a dog at the going rate is acceptable, as is obtaining a placement of an older animal. Any other arrangements should be carefully evaluated in consultation with General Counsel.

Employees may own dogs and breed an occasional litter. Employees may belong to dog clubs, but should not hold any policy-making position in a club. Employees are not permitted to compete in or judge Regular Classes at AKC licensed dog events. Employees may not be delegates. Household members of employees are subject to the same policies concerning dog activities as employees. Employees with any question concerning a dog activity should discusss it with the Director of Administration.

Procedure

Each employee has an ongoing responsibility to report in writing any possible, actual or contemplated violation of the above policy to the Vice President, General Counsel. The Vice President, General Counsel, after any further appropriate inquiry, shall forward the information to the President with a recommendation as to the appropriate resolution. Every effort will be made to hold such reports confidential.

Any activity or interest that is fully disclosed may be continued until such time as the employee is notified that a conflict exists. An anticipated activity or interest should not be commenced, however, until a response has been received. While questions about conflicts may be directed to the Vice President, General Counsel, such inquiries will not be considered a substitute for the required written report. Any opinions expressed by the Vice President, General Counsel will not be considered a substitute for the required written response.

This policy applies to all employees and each salaried payroll employee will be required to complete a Conflict of Interest questionnaire (or statement) annually.

Failure to comply with this policy may be grounds for immediate termination of employment.

Conflict of Interest Questionnaire

In order to facilitate compliance with AKC's Conflict of Interest policy, we ask that you answer the following questions.

1. Are you or is any member of your immediate family employed or engaged as a consultant, by any organization or individual which to your knowledge does or is seeking to do business with the AKC?
2. Have your or any member of your immediate family accepted any benefits beyond the customary business courtesies from any organization which to your knowledge does or is seeking to do business with AKC?
3. Have you disclosed AKC confidential information outside of the scope of your employment or used such information in any way to promote your own interest or the interest of others?
4. Do you or any member of your immediate family have any other interest or arrangement which may violate AKC's policy on Conflict of Interest, which may result in compromising yourself or AKC or may result in the impairment of your independent judgment?

If you answered yes to any of the above questions, please explain below.

I have read and am familiar with the Conflict of Interest policy of AKC and have answered the above questions fully, accurately and truthfully. I recognize that the consequences of an incomplete, inaccurate or untruthful response may be dismissal.

__________________________ __________________________ __________________________

Signature Print Name Date

AKC-Specific Policies

Involvement in Elections for Board of Directors

Employees perform valuable services in carrying out the policies determined by the AKC Board of Directors as well as developing proposals for Board consideration. The Board relies upon the independent opinions and evaluations it receives from employees. The professional relationship between the two is essential to the successful operation of the AKC.

All employees must remain apart and independent from the Board elections that are held at the Club's annual meeting. It is detrimental to the well being of the Company and to the professional character of AKC employees for them to become involved in any way in Board elections.

Employees who are approached by anyone to become involved, either directly or indirectly, in the Board elections, should respectfully decline. Any such incidents should be reported to the President.

This prohibition does not preclude employees from assisting in the administration of elections by serving on the Teller Committee if so requested.

Dog Club Participation

Employees may belong to dog clubs but may not hold any policy-making position in a club. Employees may not become delegates to the AKC.

Purchasing a Dog

Because of the special relationship of the AKC and its employees to the entire world of dogs, any employee obtaining a dog must be especially careful that a conflict of interest, or the appearance of such, is not created.

Purchase of a dog at the going rate is acceptable, as is obtaining a placement of an older animal. Any other arrangements should be carefully evaluated in consultation with AKC's General Counsel.

Exhibiting by Employees

Employees and members of their household are permitted to compete at AKC events under the following conditions:

1. Dogs housed with and owned by an employee or co-owned with a household member may be shown by either the employee or the household member. Dogs co-owned by persons other than household members are not eligible to be shown.
2. Conformation, Obedience and Performance field staff may exhibit at events other than those within their area of responsibility; only at events at which they are not officially assigned.
3. Dogs may be exhibited until such time as they achieve a title or titles; through the highest title listed below in each category:
   

   Conformation	…………..	Champion of Record
   Obedience	…………..	Obedience Trial Champion (OTCH)
   Tracking	…………..	Champion Tracker
   Performance	…………..	Field Champion, Amateur Field Champion
   Hunting Tests	…………..	Master Hunter
   Herding Trials	…………..	Herding Champion
   Lure Coursing	…………..	Field Champion
   Earthdog	…………..	Master Earthdog
   Agility	…………..	Master Agility Champion (MACH1)
   Rally	…………..	Rally Advanced Excellent (RAE)

4. Officers, CMC, inspectors, investigators, as well as employees involved in the judging application process, except as allowed in 2 above, and their household members may not exhibit dogs.

Any questions or concerns regarding this policy should be referred to a member of the Human Resources professional staff.