Ethics, compliance, and data security

Our Company is committed to operating ethically. Our ethics, anti-corruption and anti-bribery principles are embedded within our corporate culture and form the basis for a suite of policies, codes, and procedures that guide and inform our employees as they implement the Company’s business strategy.

We do not tolerate bribery nor corruption in any form, and we expect our employees and anyone acting on our Company’s behalf to comply with all applicable laws and regulations and uphold high standards of ethics.

We have implemented a Code of Business Conduct which provides guidance and controls applicable to directors, employees and contract employees of the Company and its subsidiaries and controlled affiliates, including addressing competition and antitrust, anti-bribery and anti-corruption, insider trading and compliance with applicable law. We also have a Supplier Code of Conduct, which obligates third-party suppliers to adhere to principles of acting responsibly.

The Conflict of Interest and Business Ethics Committee assists our executive leadership in applying the Company’s policies and procedures related to conflicts of interest and business ethics in a consistent manner and in compliance with applicable laws, regulations, and ethical practices.  The Committee is tasked with promoting a strong culture of ethical behavior and accountability within the Company through regular assessments, monitoring and enhancements of the conflict of interest and business ethics policies, systems, and controls.

 The Conflict of Interest & Business Ethics Committee duties, responsibilities and authorities include:

• Review investigative reports of actual, perceived, or potential cases of:
  • conflicts of interest or unethical business conduct by Company employees; and
  • security violations involving Company employees with the potential to result in significant legal, financial, or reputational harm.

• Disciplinary Actions:
  • place restrictions on the employee and impose disciplinary actions;
  • refer the case to authorities for investigation and potential criminal prosecution; and/or
  • direct other remedial actions.

• Monitor and re-enforce the Company culture of ethics and accountability
  Our Corporate Compliance Organization is tasked with overseeing the Company’s regulatory compliance including the areas of ethics, anti-corruption, and anti-bribery in a comprehensive and systematic manner. This oversight is accomplished primarily through developing, improving and implementing policies and procedures to address and mitigate regulatory compliance risks, and implementation of structural controls around activities that create a heightened potential for bribery and corruption risk.