TurnPoint Code of Conduct

Why We Have a Code

Our mission at TurnPoint is to Turn Bad Days Into Good Ones.  Accomplishing that mission begins with creating a culture that is committed to ethical behavior. The purpose of this Code of Conduct is to establish clear values and hold ourselves accountable to them – from the CEO to the newest employee.  We believe that these key values and expectations make us an employer of choice, a reliable business partner, and a trusted member of our communities.

Who the Code Applies To

This Code applies to everyone and every Brand in the Turnpoint family – employees, officers, and the Board. In this Code, we will collectively refer to TurnPoint and each of the Brands as “TurnPoint” or the “Company.”  As further described in our Business Partner Expectations section below, we also expect our vendors, suppliers, consultants, and other business partners to act in a way that is consistent with this Code.

The TurnPoint Way

Safe and Respectful Workplace

  • Equal Opportunity - We are proud to promote equal opportunity in every aspect of employment at TurnPoint. We also treat each other with respect and dignity. This means that all employees and customers can expect an environment that is free from harassment and discrimination.
  • Safe Workplace - We are committed to providing a safe workplace and will not allow threats, threatening language, bullying, or any other acts of aggression or violence by or toward any TurnPoint employee. To the extent permitted by law, employees and visitors are prohibited from carrying weapons onto TurnPoint premises.
  • Pay Practices - We accurately compensate employees in compliance with all applicable state and federal laws.

Reputable Business Practices

  • Confidential Information – You may have access to confidential information about TurnPoint's business, including information regarding our finances, pricing, products, software, marketing strategies, suppliers, and customers or potential customers. You may also become aware of confidential information belonging to our vendors. It is extremely important that all such information remain confidential. Protecting our confidential information helps us maintain our competitive advantage and preserve our reputation as an industry leader. If you have access to confidential information, it is your obligation to keep it safe and we expect you to know when and how that information can be appropriately shared.
  • Company Assets – At TurnPoint, you will have access to many resources: physical assets, like buildings, trucks, and equipment; electronic assets, like computers, software, and mobile devices; and, intellectual property, like trademarks, trade secrets, and confidential information. It is your responsibility to protect these from misuse and you should never use a Company asset for outside business or personal gain or for anything illegal or unethical.  You should also protect your physical access keys and badges, and your cyber access logins, password, security tokens, or similar information from use by anyone other than yourself. Providing access to another individual, either deliberately or through failure to secure your own access credentials, could be a violation of policy.
  • Accurate Records – Accurate recordkeeping and reporting is at the heart of how we do business. Every TurnPoint employee has a responsibility for ensuring the accuracy of all Company records, from time sheets to expense reports, budget forecasts to government filings. It is important to always be honest, accurate, complete, and timely in what you record. It is also important to know and follow the document retention policies that relate to storage and disposal of Company documents.  Never destroy or dispose of information that might be needed for an investigation, audit, or legal proceeding.
  • Bribery/Corruption/Fair Competition – Operating with integrity means avoiding corruption of any kind, including bribery. TurnPoint employees should never request, offer, or accept anything of value to give or get business, keep business, or gain an unfair advantage. This includes cash gifts, kickbacks, facilitation payments, free personal services, or special favors. We expect you to follow U.S. anti-bribery and anti-corruption laws wherever you do business, regardless of what foreign laws or local customs may permit.

    • We also pride ourselves on dealing honestly and fairly with our customers and our competitors.  You should follow fair competition laws everywhere we operate, and you should never act in a manner that could be seen as an attempt to exclude competitors or to control market prices.
  • Conflicts of Interest – You should avoid any activity or relationship that creates, or even appears to create, a conflict between your personal interests and TurnPoint’s business interests, including dealings with our vendors, customers, or competitors. Conflicts take many different forms, but often they involve:  gifts – you may not request or accept any gift that has greater than nominal value; entertainment – you may not request meals or entertainment, and you should only accept such invitations if they are customary, appropriate, occur infrequently, and are not expensive; relationships – you may not own or directly benefit from any interest in a vendor or competitor without explicit permission from TurnPoint.
    • It is also a conflict of interest to use Company assets or opportunities for personal gain. This can include (but is not limited to): using or personally benefitting from business opportunities that are discovered using Company property or information, or your position at the Company; using Company property (including personnel) or information, or your position for personal gain; and competing, directly or indirectly, with the Company.
  • Compliance with Laws – This Code cannot address every possible circumstance, especially when issues arise with local or federal laws. You should follow all laws, rules, and regulations of the United States and the states, counties, cities, and other jurisdictions where we business. It is important for you to understand the laws that apply to your job and our business.
  • Business Partner Expectations – We expect our vendors, suppliers, consultants, and other business partners to hold themselves accountable to the same ethical expectations as we do. This includes how they conduct their business and how they treat their employees and business partners. If you have concerns about the actions of one of TurnPoint’s business partners, you should report it right away.

Community Engagement

  • Our Commitment – In carrying out our mission to Turn Bad Days Into Good Ones, our goal is make a positive impact in every community where we operate, through employee time and support given to local organizations, as well as Company support for selected organizations. We also encourage individual participation in community and charity activities. Please keep in mind that all giving should be done in compliance with our anti-bribery policy above.

  • Personal and Political Activities – We encourage you to be involved in your community, but you must be careful not to represent your personal opinions as those of TurnPoint. You may not post on any blog, web page, social networking platform, or similar digital platform, at any time with Company emails or accounts.  Further, when posting something on your own blog, web page, social networking platform, or similar digital platform, you may not appear in uniform or identify the Company in any way.

How to Raise Concerns

If you believe that someone may have violated this Code, you have a duty to ask questions and report concerns immediately.  You can report concerns in any of the following three ways:

In Person

You can report the matter to your supervisor or any member of your management team. If you are unable to do so, or if you feel that your issue was not taken seriously, you should contact Human Resources.

By Telephone

You can call 502-214-3734.


You can email [email protected].

Every report of a violation of this Code will be investigated and corrective action will be taken where appropriate, up to and including termination of employment. Violations may also have legal consequences for violators personally, including penalties and fines.

TurnPoint will not allow any form of retaliation against individuals who report a Code violation in good faith or who cooperate in the investigations of such reports. If you are subjected to any such retaliation, you should report it right away.

Any questions about this Code or its applicability should be addressed to TurnPoint’s Chief Legal Officer.

For You

A fair price – We’re not looking for a fire sale. We only acquire solid businesses. And we pay fair market value for them.

We take care of your business the way you would.

Peace of mind – Turnpoint is committed to honoring the legacies of the entrepreneurs who’ve built their businesses from the ground up. 

More support – We provide state-of-the-art equipment and outstanding back-office support – and we’re continually innovating with new technologies, systems, and processes.