1) How comprehensive is this ethical code?

2) What is something missing for this ethical code?

3) What is the value of this ethical code for financial management?

-I act with honesty and integrity, avoiding actual or apparent connflicts of interest in personal and

professional relationships.

-I provide constituents with information that is accurate, complete, objective, relevant, timely, and

understandable. I routinely disclose information to all relevant constituents, both positive and negative,

that is necessary to present an accurate picture of our financial status and to ensure the elective running

of our business.

-I comply with rules and regulations of federal, state, provincial, local and national governments, and

other appropriate private and public regulatory agencies. I notify the General Auditor at corporate

headquarters if I am aware of any violations of laws or regulations, frauds, or defalcations.

-I act in good faith, responsibly, with due care, competence, and diligence, without misrepresenting

material facts or allowing my independent judgment to be subordinated.

-I respect the confidentiality of information acquired in the course of my work except when authorized or

otherwise legally obligated to disclose. Confidential information acquired in the course of my work is not

used for personal advantage.

-I share knowledge and maintain skills important and relevant to my constituents' needs.

-I proactively promote ethical behavior as a responsible partner among peers and subordinates in my

work environment and community. I promote and provide a safe environment for subordinates to report

unethical/inappropriate behavior or suspected fraud and will not condone or accept any retribution

against those subordinates for reporting these activities.

-I achieve responsible use of and control over all assets and resources employed by or entrusted to me. I

recognize my fiduciary duties in the ensuring of effective internal control systems and a control

environment necessary to protect those assets and resources employed by or entrusted to me. I notify the

General Auditor and Chief Accounting Officer if I am aware of any material weakness in the design or

operation of internal controls which could adversely affect the ability to record, process, summarize, and

report financial data.

-I have read, understand, and model the behaviors called for in The Red Book, Lilly's code of business

conduct, and act as an advocate to ensure compliance with The Red Book in all areas within my span of

control.