Corporate Governance and Code of Business Conduct

Alpine 4 Holdings, Inc. is committed to conducting business in accordance with the highest standards of business ethics. In furtherance of this commitment, it is the expectation that all employees and the Board of Directors promote ethical behavior.

  1. Compliance with Laws, Rules and Regulations: It is expected that employees must follow applicable laws, rules and regulations at all times. Employees with questions about the applicability or interpretation of any law, rule or regulation, should contact the Legal Department.
  2. Conflicts of Interest: In performing their job duties, employees are expected to use their judgment to act, at all times and in all ways, in the best interests of Alpine 4.
  3. Insider Trading Policy: Federal and state laws prohibit trading in securities by persons who have material information that is not generally known or available to the public. 
    1. Employees of the Company may not a) trade in stock or other securities while in possession of material nonpublic information or b) pass on material nonpublic information to others without express authorization by the Company or recommend to others that they trade in stock or other securities based on material nonpublic information.
    2. The Company has adopted guidelines designed to implement this policy.
    3. All employees are expected to review and follow the Alpine 4 Insider Trading Guidelines. Certain employees must comply with trading windows and/or preclearance requirements when they trade Alpine 4 securities.
  4. Discrimination and Harassment: Alpine 4 provides equal opportunity in all aspects of employment and will not tolerate any illegal discrimination or harassment of any kind. For more information, see the Alpine 4 policies on Equal Employment Opportunity and Workplace Harassment in the Alpine 4 Owner’s Manual.
  5. Health and Safety: Alpine 4 provides a clean, safe and healthy work environment. Each employee has responsibility for maintaining a safe and healthy workplace by following safety and health rules and practices and reporting accidents, injuries and unsafe conditions, procedures, or behaviors. Violence and threatening behavior are not permitted. Employees must report to work in a condition to perform their duties, free from the influence of illegal drugs or alcohol.
  6. Bribery; Payments to Government Personnel: Employees may not bribe anyone for any reason, whether in dealings with governments or the private sector. The U.S. Foreign Corrupt Practices Act, and similar laws in other countries, prohibit offering or giving anything of value, directly or indirectly, to government officials in order to obtain or retain business. Employees may not make illegal payments to government officials themselves or through a third party. Employees who are conducting business with the government officials of any country must contact the Legal Department for guidance on the law governing payments and gifts to governmental officials.
  7. Questions; Reporting Violations: Employees should speak with anyone in their management chain or the Legal Department when they have a question about the application of the Code of Conduct or when in doubt about how to properly act in a particular situation.
    1. Alpine 4, with its legal counsel, has developed and maintains reporting guidelines for employees who wish to report violations of the Code of Conduct. These guidelines include information on making reports to the Legal Department and to an independent third party. Please see the reporting guidelines for information and instructions.
    2. Alpine 4 will not allow retaliation against an employee for reporting misconduct by others in good faith. Employees must cooperate in internal investigations of potential or alleged misconduct.
    3. Employees who violate the Code of Conduct will be subject to disciplinary action up to and including discharge.
  8. Periodic Certification: The Legal Department will designate certain employees who, based on their level of responsibility or the nature of their work, will be required to certify periodically that they have read, understand and complied with the Code of Conduct.
  9. Board of Directors: With respect to their service on behalf of the Company, Alpine 4’s Board of Directors must comply with the relevant provisions of this Code of Conduct, including conflicts of interest, insider trading and compliance with all applicable laws, rules and regulations.
  10. Waivers: Waivers of this Code of Conduct may be made only in a manner permitted by law.