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Harassment

Our work environment must be free from any form of intimidation or harassment, including by way of example, sexual, racial or religious harassment. Verbal or physical conduct by an employee that harasses or disrupts another person's work performance, or that creates an intimidating, offensive, abusive or hostile work environment will not be tolerated. The Company is committed to providing a workplace free of sexual harassment. This commitment reinforces our goal to create an environment that fosters mutual trust and respect. Examples of sexual harassment include, but are not limited to: unwelcome sexual advances, verbal statements, physical contact of a sexual nature, or the display of sexually suggestive objects or pictures. Employees are encouraged to speak out when a co-worker, member of leadership or any third party engages in conduct that makes them uncomfortable in connection with their job. Employees are also responsible for promptly reporting harassment to their immediate supervisor, manager, Human Resources representative, the Ethics Office, the Company Legal Department or employee hotline. Employees are responsible for reporting any sexual overtures or sexual harassment of any kind by suppliers, customers or contractors.

Impairment and Substance Abuse

The Company has a vital interest in maintaining a safe and productive work environment for all employees. Drugs, alcohol or other substances may hinder job performance or judgment. The Company requires a drug-free workplace. Using, possessing, distributing or being under the influence of alcohol or an illegal or illicit drug, while on duty, on Company premises or in Company vehicles is prohibited. Employees with problems related to alcohol or drugs are encouraged to seek assistance from the Employee Assistance Program or other qualified professionals. Employees, who are using prescription or non-prescription drugs that may impair their alertness or judgment, and therefore jeopardize their safety and that of their co-workers, should inform their supervisor or manager of this fact.

Preventing Workplace Violence

Being considerate of others and exhibiting appropriate behavior helps foster a workplace that is free from violence. Acts or threats of physical harm or violence, hostile physical contact (including intimidation, harassment, coercion), or any other actions that are threatening or hostile in nature that occur on Company property or affect Company operations will not be tolerated. The Company does not allow weapons (legally permitted or not) or explosives in Company facilities or on Company property, in Company vehicles, or while conducting Company business. Employees are expected to report any actual or potentially violent behavior that could cause risk to others immediately to their supervisor, manager, Human Resources representative, the Company Ethics Office, Legal Department or the employee hotline.

Promoting Health and Safety

The Company is committed to providing a safe and healthful workplace for all employees. To support this commitment, employees are responsible for observing the safety and health rules, policies, practices, laws and regulations that apply to their jobs and for taking precautions necessary to protect themselves, their co-workers and other persons present in Company facilities. Employees are also responsible for immediately reporting accidents, injuries, occupational illnesses and unsafe practices or conditions to their supervisor or manager. Questions about possible health and safety hazards at any Company facility should be directed to your supervisor or manager.

Protecting the Environment

We respect the needs and concerns of the communities in which we live and work. This is exemplified by the Company's tradition of caring about the quality of the environment and complying with all applicable environmental laws, rules and regulations in all countries in which we have business operations. The Company will operate in a way that safeguards the health, safety and general welfare of its employees and the surrounding communities. Let your supervisor or manager know immediately if you are aware of any improperly handled hazardous materials. Talk to your supervisor or manager if you are aware of any significant environmental issues that may be in violation of applicable laws, rules or regulations.

Product Quality

The Company is committed to providing quality products and services that meet or exceed the expectations of our customers. Quality issues that threaten the well-being of any person or put the financial security of the Company at risk should be immediately reported to senior management, thoroughly investigated, and subject to corrective action. Quality issues may involve product design, manufacture, installation, and maintenance.

Corporate Communications

The Company strives to be professional and consistent in its communication with others. To achieve this goal, all contact with investors, analysts and the media (newspapers, magazines, trade publications, radio, television or other external source), including requests for information and interviews, should be directed to the TriMas Vice President of Human Resources for handling by the appropriate corporate communications officer. Employees who may be exposed to media contact should be aware that the Company's standard corporate policy is not to comment on rumors or speculation regarding its activities.

In addition, senior management and others at TriMas, if any, who regularly communicate with securities market professionals and holders of TriMas debt or equity securities must comply with Regulation FD promulgated by the Securities and Exchange Commission. Regulation FD provides that whenever any such persons disclose material, non-public information to certain persons, the Company must also disclose that information to the general public either simultaneously (for intentional disclosures) or promptly (for inadvertent disclosures).

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