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- Failure to cooperate in any investigation of possible
violations of the Code or Company policy
- Retaliation against another employee for reporting an
integrity concern
- Failure to demonstrate the leadership and diligence needed
to ensure compliance with Company policies and applicable
law
- Knowingly reporting a violation of this Code or Company
policy that is false or misleading
Violations of the Code and certain Company policies can also
mean breaking the law, potentially subjecting you and the Company
to criminal penalties (fines, jail sentences or both) and civil
sanctions (damage awards or fines).
In very rare circumstances, situations may arise in which a
waiver may be appropriate. Waivers will be determined on a case-by-case
basis by the Company's senior management with the advice of
Company Legal Department. However, waivers for directors and
executive officers may only be granted by the Board of Directors
(or a committee of the Board), which shall have the sole and
absolute discretionary authority to approve any deviation or
waiver from this Code of Conduct. Any waiver for directors or
executive officers, and the ground for such waiver shall be
promptly disclosed to the extent required by applicable law,
SEC regulation or stock exchange requirement.
Your Personal Commitment
This Code is available in printed form and also on the Company
intranet. Every employee must read and understand the Code.
All existing employees are periodically required, as a condition
of employment, to provide the Company with a certification that
they have read, understand, know of no violations, and acknowledge
their commitment to the spirit and letter of the Code and Company
policies. All newly hired employees must also sign a certification.
When You Have a Legal or Ethical Compliance Concern
One of the most important responsibilities each employee has
is the obligation to raise a concern about a possible violation
of this Code or Company policy. Sometimes it may seem difficult
to raise such a concern. Some may feel that it is a breach of
personal ethical standards to do so. If you experience that
sense of conflict, it is important to remember the tremendous
harm that not raising a concern can cause, including: (i) serious
damage to the health, safety and well-being of you, your fellow
employees, the Company as a whole, our customers and the communities
in which we operate, (ii) the loss of confidence in the Company
by customers, shareholders, governments and neighbors, (iii)
fines, damage awards and other penalties against the Company,
and (iv) fines and/or prison sentence against individual employees.
Those are the reasons the Company requires that employees
not remain silent when they have a legal or ethical concern.
The point of raising a concern is not to get a friend in trouble,
but to protect a colleague or neighbor from potential harm.
How to Raise a Legal or Ethical Compliance Concern
The Company offers you many ways to get answers to your questions
about legal and ethical issues and to raise any concern about
what might be a violation of this Code or Company policy:
Locally Within Your Business
• Your supervisor or manager
• Your Human Resources Representative
• The Company Ethics Office
• Next level of management
• Company Legal Department |
Employee Hotline
1-877-888-0002
Toll free in the United States
1-770-810-1147
Collect from international locations
Interpreters available |
Generally, your supervisor or manager will be in the best
position to resolve the issue quickly. If after raising a
legal or ethical compliance concern the issue is not resolved,
raise it with one of the other contacts listed above.
You can raise your concern orally or in writing, and if you
prefer, you can do it anonymously through a compliance "hotline"
that is administered by an independent third party.
If you are employed by a European affiliate of the Company,
you should only use the "hotline" to report (i)
accounting matters; (ii) internal accounting controls; (iii)
auditing matters; (iv) anti-bribery matters; and (v) banking
and financial crimes. All references to use of the employee
hotline in this Code are qualified by this limitation regarding
employees of European affiliates of the Company.
The whole idea is to speak up. Ask questions. Get answers.
Bring the concern into the open so that any problems can be
resolved quickly and more serious harm prevented.
IN OUR WORKPLACE
The Company is committed to providing a diverse, safe and
healthy work environment. The Company is also committed to
maintaining a workplace free from discrimination, harassment,
and offensive, obscene or threatening behavior.
A Nondiscriminatory, Diverse Environment
The diversity of our employees is a valuable asset. We strive
to treat each other as we wish to be treated ourselves: with
dignity and respect. We strive to maintain an environment
free from discrimination on the basis of gender, age, race,
color, religion, marital status, national origin, ancestry,
veteran status, disability, sexual orientation or any other
status protected by law. We support equal employment opportunity
for all employees and applicants. We will not unlawfully discriminate
in hiring, termination, promotions or any other condition
of employment. In an ever-changing global market, we need
to embrace, respect and leverage our differences to foster
growth and innovation.
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