Managing the Supply Chain
|
|
- Bethanie McDaniel
- 6 years ago
- Views:
Transcription
1 Managing the Supply Chain SCCE Regional Compliance & Ethics Conference Houston, TX November 5, 2010 Speakers Carolyn Egbert Senior Executive Vice President Compliance & Corporate Responsibility Solvay North America LLC Houston, TX Harry Britt Manager, Ethics & Compliance Corporation Houston, TX 1
2 Agenda Third Party reliance Who are third parties Third party risk exposure Managing, Mitigating Third Party Risk Red Flags Interface with suppliers / vendors Recent issue Working with suppliers & Supply Chain Management Solvay Solvay North America, LLC, the North American subsidiary of Solvay SA An international plastics and chemicals company headquartered in Brussels, Belgium with operations in more than 50 countries throughout Europe, North America, South America and Asia- Pacific Solvay introduced its Group Code of Conduct in 2006, setting forth uniform standards of behavior applicable to all employees globally 2
3 Third Parties Third Party Reliance Most companies are dependent upon third parties, e.g., suppliers, contract employees, agents, to conduct business. Businesses are particularly dependent upon third parties to create or expand their global markets. Joint ventures are becoming more common for financial reasons or because they are a condition for doing business in a particular country. In the past, utilizing third parties often meant reducing risks and responsibilities. Today, third party arrangements exposes companies to greater legal risks and damage to reputation. 3
4 Who are Third Parties? Third Party Types: Suppliers, Vendors Distributors, Resellers Contractors, Subcontractors, Licensees Temporary Services Agents, Sales Representatives, Marketing Intermediaries Consultants (Legal, Financial, HSE, Strategic Business, Regulatory Experts, etc.) Advisory Services, Industry Experts Joint Venture Partners Third Party Risk Exposure Because there are many types of third party relationships, the legal and reputational risk exposure can vary widely. Examples of risk exposure: Supplier of your goods violates child labor laws; Contract manufacturer substitutes toxic fillers for ingredients; Your agent inappropriately entertains government officials; Your distributor sells product to a legally prohibited market; Marketing consultant misuses customers private data; or Lobbyist bribes government official. 4
5 Managing / Mitigating Third Party Risk Definition of an effective ethics and compliance program under U.S. Sentencing Guidelines encourage companies to establish effective third party business standards. Caution: imposing ethics and compliance requirements carries legal risks, e.g., imputing third-party acts to the company, third party beneficiary rights. Many companies mitigate these risks by extending features of their ethics and compliance programs. Managing / Mitigating Third Party Risk (cont d) Conduct Risk Assessment U.S. Sentencing Guidelines suggest using three key factors in assessments: Nature and seriousness of potential misconduct to which the relationship could give rise Likelihood that such conduct could occur because of the nature of the relationship or the third party s business; and, The third party s prior history Identify and weigh corruption index assigned to prospective business location (Transparency International Corruption Perceptions Index) Conduct due diligence to identify levels of risk 5
6 Managing / Mitigating Third Party Risk (cont d) Provide training to ensure third party s knowledge of company s ethics and compliance standards. Ensure that third party contracts include terms that require compliance obligations and audit rights and right to contract termination for failure to perform obligations. Provide means for third party to report ethics and compliance concerns, e.g., Helpline, web reporting. Third party code of conduct. Ensure staff oversight Be vigilant in spotting red flags Red Flags U.S. Department of Justice Guidelines: Unusual payment patterns or financial arrangements History of corruption in the country Refusal to certify compliance Unusually high commissions Lack of transparency in expenses and records Apparent lack of qualifications or resources Third party recommended by a foreign official 6
7 Red Flags (cont d) Other red flags may include: Agency fees requested in cash Indication of facilitating payments Multiple agents for same scope of work Political contributions by agent Incomplete or inaccurate information in disclosures Request for payments to third party or third country Ethics & Compliance in Your Supply Chain 7
8 North America s premier natural gas pipeline system Corp. Pipeline System Mojave Pipeline Colorado Interstate Gas Wyoming Interstate Cheyenne Plains Pipeline Tennessee Gas Pipeline Natural Gas Elba Island LNG Southern Natural Gas Florida Gas Transmission 8
9 One of North America s largest independent natural gas producers Corp. Exploration & Production Egypt N I L E D E L T A W E S T E R N E S E R T D S I N A I G U L F O F S U E Z Brazil 9
10 Standards for Service & Material Providers 19 Ethics & Compliance Office Located in Houston Responsible for Ethics & Compliance program Available to help others (including suppliers) make appropriate decisions Answer questions Provide advice on issues Respond to possible violations 20 10
11 Code of Business Conduct Based on core values Spells out system for employee conduct Applies to all employees globally Issued to all employees and non-employee board members Reminds employees of high standards expected 21 Encourage Suppliers to Achieve High Standards Communicate expectations to suppliers Expect employees to act in accordance with the highest ethical and legal standards Also expect suppliers / vendors to interact with the company in a manner consistent with our Code of Conduct and our Values Expect business decisions made on company s behalf to be in the best interest of the company 11
12 Standards for Service & Material Providers Brochure describes El Paso's minimum requirements of its providers Want suppliers to be aware of s expectations 23 EP Standards for Service & Material Providers Conflicts of interest Compliance with laws and regulations Fair competition and antitrust Insider trading Transacting international business Safety and environmental Employment practices Prohibited items including drugs, alcohol and weapons Gifts and entertainment Accuracy of business records Confidential information and trade secrets Use of electronic media Federal Energy Regulatory Commission (FERC) standards of conduct 12
13 Standard Contract Language Company Handbooks. Contractor acknowledges that it has received, reviewed and is familiar with the Company Handbooks, including the Business Ethics Handbook. In addition to its other obligations under this Agreement, Contractor shall require compliance with the Company Handbooks by Contractor and its employees, agents, representatives, invitees, licensee and Subcontractors, and any other persons performing Work under Contractor s control. Supplier Personal Responsibility Work according to s core values and ethical principles Read s Standards for Service & Material Providers Conduct themselves in manner beyond reproach Bring concerns and issues forward promptly 26 13
14 Contact Options for Suppliers Confidential and anonymous toll-free telephone number Direct telephone number address Fax number Intranet form Regular mail address Walk-in 27 Working with Suppliers & Supply Chain Management to Address an Issue 14
15 Anonymous Allegation EP employee had conflict of interest with local suppliers / vendors Corporate Audit investigated and confirmed the allegation Employee was terminated Supply Chain Management Actions Four suppliers placed on probation by s Supply Chain Management (SCM) & local management SCM suspended suppliers from s approved vendor list Pending action by suppliers to implement some form of ethics and compliance program for their own employees 15
16 Ethics & Compliance Office Coordinated with Supply Chain Management Provided suppliers: Checklist / Federal Sentencing Guidelines : Standards and procedures (code) Governing body to maintain oversight Background checks Communication / training Helpline phone system Enforcement / disciplinary measures Ethics & Compliance Office Provided suppliers (continued): List of resources: The Conference Board Compliance & Ethics Leadership Council Ethics & Compliance Officer Association training sources consultants Helpline vendors etc. 16
17 Ethics & Compliance Office Suppliers submitted draft codes / employee handbooks to for review / comment Ethics & Compliance Office: reviewed / evaluated supplier materials met with suppliers and SCM to discuss / evaluate steps taken to develop materials, training, etc Coordinated with SCM on when to reinstate suppliers Established periodic program reviews and site visits by SCM, Ethics Office, management Comments by Suppliers Each of these contractors told SCM they were grateful for the development of these ethics and compliance programs Stated this is something they should have done long ago Could clearly see the value and credibility it added to their company 17
18 Where Do We Go From Here Where Do We Go From Here Supplier relationships can pose significant risk / exposure Initiate / continue focus with key suppliers Try to mitigate risks posed by suppliers / third parties Communicate intent to operate with integrity Develop relationships with suppliers that share similar values and conduct business in an ethical manner 18
19 Questions 19
CODE OF BUSINESS CONDUCT AND ETHICS
1 ST FRANKLIN FINANCIAL CORPORATION CODE OF BUSINESS CONDUCT AND ETHICS Introduction This Code of Business Conduct and Ethics ( Code ) describes the basic principles of conduct that we share as officers
More informationTopics for Discussion
Reviewing & Managing Third Party Compliance Marjorie W. Doyle, JD, CCEP-F, Managing Director, Aegis Compliance & Ethics Center, LLP with input from Diana Lutz SCCE Midwest Regional Conference, April 27,
More informationTHIRD PARTY OPERATORS
THIRD PARTY OPERATORS SCCE Utilities & Energy Compliance & Ethics Conference March 2, 2009 Marjorie W. Doyle, JD,CCEP Marjorie Doyle & Associates,LLC Alternative Titles No Company is an Island Oh What
More informationCode of Ethics. Table of Contents. Itziar Sisniega, with Piccolo
Code of Ethics Itziar Sisniega, with Piccolo Table of Contents A Message from our CEO.................2 Introduction............................3 How to use the IDEXX Code of Ethics 3 Who the IDEXX Code
More informationSOSi SUPPLIER CODE OF CONDUCT
» SOSi.COM SOSi SUPPLIER CODE OF CONDUCT OVERVIEW SOS International LLC, including each of its whollyowned or controlled subsidiaries (collectively, SOSi), is committed to excellence and to conducting
More informationANTI-BRIBERY AND ANTI-CORRUPTION POLICY
Amended to May 18, 2017 ANTI-BRIBERY AND ANTI-CORRUPTION POLICY Table of Contents Heading Page Number INTRODUCTION 1 PURPOSE 2 SCOPE 2 POLICIES 2 Bribery 2 Policy 2 Exceptions 3 Gifts 3 Meal and Entertainment
More informationSETTING POLICIES and GUIDELINES for CONDUCTING INTERNAL INVESTIGATIONS
SETTING POLICIES and GUIDELINES for CONDUCTING INTERNAL INVESTIGATIONS Al Gagne, CCEP Director, Ethics & Compliance Textron Systems Corporation SCCE Internal Investigations Workshop November 11-12, 2010
More informationATTACHMENT B CORPORATE COMPLIANCE PROGRAM. In order to address any deficiencies in its internal controls, policies, and procedures
ATTACHMENT B CORPORATE COMPLIANCE PROGRAM In order to address any deficiencies in its internal controls, policies, and procedures regarding compliance with the Foreign Corrupt Practices Act ( FCPA ), 15
More informationLIVING OUR CORE VALUES. Supplier Code of Conduct
LIVING OUR CORE VALUES Supplier Code of Conduct Introduction to Our Supplier Code of Conduct Chesapeake Energy is committed to living our core values of integrity and trust, respect, transparency and open
More informationAMETEK, Inc. Code of Ethics and Business Conduct
AMETEK, Inc. Code of Ethics and Business Conduct Code of Ethics and Business Conduct A Message from the Chairman of the Board and Chief Executive Officer Dear AMETEK Colleague: AMETEK has been in business
More informationJanus Henderson Group plc. Code of Business Conduct
Janus Henderson Group plc Code of Business Conduct This Code of Business Conduct (the Code ) has been adopted by the board of directors (the Board ) of Janus Henderson Group plc. The Code applies to all
More information2017 The Global ABB Integrity Program.
2017 The Global ABB Integrity Program www.abb.com/integrity Tone from the Top Don t Look the Other Way A culture of integrity is a prerequisite for a world-class business. Many valuable customers choose
More informationEach year, the Husqvarna Group reports on its sustain ability related work in accordance with Global Reporting Initiative s guidelines.
CODE OF CONDUCT Husqvarna Group s Code of Conduct is committed to the principles of the UN Global Compact, which aims at aligning businesses with human rights, labor, environmental care and anti-corruption
More informationSupplier Ethical Expectations
Supplier Ethical Expectations Training for Suppliers and Their Employees Revision 9, 2017 Course ID 00016572 1 Overview 1. What Intel Expects of Intel Employees Intel s Code of Conduct Intel s Anti-corruption
More informationCode of Business Conduct and Ethics
Code of Business Conduct and Ethics Table of Contents Purpose... 1 Scope... 1 Policy... 2 Responsibilities... 8 Enforcement... 8 Review and Revision... 8 PURPOSE Pursuant to the Sarbanes-Oxley Act of 2002
More informationCORPORATE COMPLIANCE PROGRAM
-- -- ~-1~ _ \ ~ CORPORATE COMPLIANCE PROGRAM In order to address any deficiencies in its internal controls, policies, and procedures regarding compliance with the Foreign Corrupt Practices Act ("FCPA"),
More informationWestRock is committed to honest and ethical business practices. All forms of bribery are forbidden.
POLICY NAME: DEPT/GROUP: POLICY SCOPE: POLICY REGION: ANTI-BRIBERY LEGAL DEPARTMENT ALL EMPLOYEES GLOBAL REVISION DATE: 4/13/2018 OWNER JOSEPH HUTCHISON WestRock is committed to honest and ethical business
More informationAcceleron Pharma Inc. Code of Business Conduct and Ethics
I. INTRODUCTION Acceleron Pharma Inc. Code of Business Conduct and Ethics (Amended & Restated as of March 1, 2018) This Code of Business Conduct and Ethics ( Code ) provides a general statement of the
More informationATTACHMENT C CORPORATE COMPLIANCE PROGRAM
ATTACHMENT C CORPORATE COMPLIANCE PROGRAM In order to address deficiencies in its internal controls, policies, and procedures regarding compliance with the Foreign Corrupt Practices Act ( FCPA ), 15 U.S.C.
More informationCode of Conduct & Ethics
Code of Conduct & Ethics Interfor Code of Conduct & Ethics Contents Page 1 CEO Message A Message from our CEO 2 Our Code of 2 Conduct & Ethics Our Code of Conduct & Ethics 3 3 Guiding Principles Guiding
More informationCODE OF ETHICAL CONDUCT
CODE OF ETHICAL CONDUCT COMPLIANCE WITH LAWS BorgWarner's over-riding policy is to conduct all of its business and operations in complete compliance with all applicable laws and regulations. You are expected
More informationGeneral Policy. Policies
CODE OF ETHICS. believes that honest, ethical and transparent business conduct is vital to the continued success of our Company. This Code of Ethics reflects the Company s core values and expresses the
More informationCODE OF BUSINESS CONDUCT AND ETHICS (Amended and Restated as of May 7, 2013)
CODE OF BUSINESS CONDUCT AND ETHICS (Amended and Restated as of May 7, 2013) Introduction One of Matrix Service Company's most valuable assets is its integrity. Protecting this asset is the job of everyone
More informationsupplier code of conduct
supplier code of conduct SUPPLIER CODE OF CONDUCT Page 1 of 4 Purpose Catalent is a leading provider of innovative development services, advanced delivery technologies and integrated supply solutions to
More informationANTI-CORRUPTION AND BRIBERY POLICY
ANTI-CORRUPTION AND BRIBERY POLICY Policy statement It is our policy to conduct all of our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and are
More informationIdentifying and Mitigating Third Party Risk Conducting Risk-Based Anti-Corruption, Anti-bribery Due Diligence
Identifying and Mitigating Third Party Risk Conducting Risk-Based Anti-Corruption, Anti-bribery Due Diligence Jennafer B. Watson Chief Compliance Officer Layne Christensen Diana M. Lutz, Chief Ethics and
More informationBridgestone Americas Code of Conduct
Bridgestone Americas Code of Conduct Suppliers and Service Providers Guide As an integral part of its corporate vision, Bridgestone Americas strives to build and maintain a meaningful, effective and practical
More informationALTISOURCE PORTFOLIO SOLUTIONS S.A. CODE OF ETHICS FOR SENIOR FINANCIAL OFFICERS
ALTISOURCE PORTFOLIO SOLUTIONS S.A. CODE OF ETHICS FOR SENIOR FINANCIAL OFFICERS Altisource Portfolio Solutions S.A. ( Altisource or the Company ) is committed to full and accurate financial disclosure
More informationFCPA COMPLIANCE PROGRAMS
FCPA COMPLIANCE PROGRAMS JIMMY S. PAPPAS INTERNATIONAL INTERNAL INVESTIGATIONS CONFERENCE FRANKFURT, GERMANY DECEMBER 7, 2012 FCPA COMPLIANCE PROGRAMS - OVERVIEW! An effective compliance program is: A
More informationINTEGRITY COMPLIANCE GUIDELINES
AFRICAN DEVELOPMENT BANK GROUP African Development Bank Group Integrity and Anti-Corruption Department INTEGRITY COMPLIANCE GUIDELINES 1 1. Prohibition of Misconduct A clearly articulated and visible prohibition
More informationProcurement Policy NORTH AMERICA
NORTH AMERICA October 2, 2017 Table of Contents 1. OVERVIEW...1 2. OVERALL PROCUREMENT PROCESS...3 3. SUPPLIER SELECTION PROCESS...4 4. CONTRACTING AND LEGAL REQUIREMENTS...8 5. PROCUREMENT CARDS...8 6.
More informationStandards of Business Conduct I N T E RM E D I A RY A N D S U P P L I E R E D I T I O N
Standards of Business Conduct I N T E RM E D I A RY A N D S U P P L I E R E D I T I O N OCTOBER 2015 Dear Valued Intermediary or Supplier: Harris has a strong ethics and business conduct program that helps
More informationVerisk Analytics, Inc. Code of Business Conduct and Ethics As Amended June 5, 2018
Verisk Analytics, Inc. Code of Business Conduct and Ethics As Amended June 5, 2018 1. Introduction This Code of Business Conduct and Ethics ( Code ) has been adopted by our Board of Directors and summarizes
More informationPOLICY The following are the principles of the Conduent Global Ethics Policy that govern all practices concerning business ethics:
SCOPE Conduent Business Services, LLC and its subsidiaries provide this policy as a guide for employees. This policy applies to all employees of Conduent Business Services, LLC and its subsidiaries and
More informationGlobal Supplier Code of Business Conduct & Ethics
Global Supplier Code of Business Conduct & Ethics Version 2.0 2/15/2017 Contents Document Statement... 3 Scope... 3 1.0 Related or Referenced Policies... 3 2.0 Compliance with Laws, Regulations and the
More informationEllucian Partner Code of Conduct
Ellucian Partner Code of Conduct UPDATED OCTOBER 2017 Section one: purpose and intent Ellucian Company L.P., and its related companies and affiliates ( Ellucian or the Company ) believes that good personal
More informationAllergan plc COMPREHENSIVE COMPLIANCE PROGRAM
Allergan plc COMPREHENSIVE COMPLIANCE PROGRAM 1. Compliance with Law All colleagues, officers and directors of the Company shall respect and comply with all applicable federal, state, local and foreign
More informationMiMedx Group, Inc. Code of Business Conduct and Ethics
MiMedx Group, Inc. Code of Business Conduct and Ethics 1. Introduction. 1.1 The Board of Directors of MiMedx Group, Inc. (together with its subsidiaries, the "Company") has adopted this Code of Business
More informationReport on Compliance and Ethics
AVANGRID, Inc. CORPORATE COMPLIANCE 14 / February / 2018 Report on Compliance and Ethics I. Introduction This report describes actions taken by Avangrid and subsidiary management in connection with the
More informationCompliance Auditing Done Right
Compliance Auditing Done Right SCCE 10 th Annual Compliance & Ethics Institute September 12, 2011 Scott Avelino Win Swenson Discussion Topics Rationale for Conducting Compliance Audits Identifying Risk
More informationCompliance with Laws, Rules and Regulations
R1 RCM Inc. (hereafter, R1 or the Company ) is committed to the conduct of its business in an ethical, legal, and transparent manner. In turn, the Company expects that all employees, contractors and vendors
More informationOilfield Service Co.
Oilfield Service Co. Peak Oilfield Service Company Code of Business Ethics and Compliance From the President Our role in supporting the oil and gas industry is simple: we provide capable, satisfi ed employees
More informationCODE OF CONDUCT. (As Amended June 11, 2015)
CODE OF CONDUCT (As Amended June 11, 2015) 1. INTRODUCTION Employees of Facebook, Inc., or any of its affiliates or subsidiaries, ( Facebook ) and others performing work for Facebook or on its behalf,
More informationI. GENERAL STATEMENT. Corporate Procedure Number: IMCP Subject: Ethics and Anti-Corruption. Date Issued: March 11, 2016
I. GENERAL STATEMENT Iochpe-Maxion S.A. is committed to the highest ethical standards and to conducting its business in accordance with all applicable laws and regulations. The terms established in this
More informationSUPPLIER CODE OF BUSINESS CONDUCT
SUPPLIER CODE OF BUSINESS CONDUCT August SUPPLIER CODE OF BUSINESS CONDUCT TABLE OF CONTENTS 1 INTRODUCTION... 3 2 LCBO CORE VALUES... 3 3 APPLICABILITY OF THE CODE... 4 4 RESPONSIBILITIES... 4 5 PRINCIPLES...
More informationProcedure: Sasol Supplier code Of Ethics
Procedure: Sasol Supplier code Of Ethics >Document number< Revision: 01 SAX-10029304 Purpose This Procedure is intended to govern the Conduct of Sasol and all of its subsidiaries, sub-contractors, consultants,
More informationBUSINESS ETHICS POLICY and GUIDING PRINCIPLES
BUSINESS ETHICS POLICY and GUIDING PRINCIPLES The Guiding Principles form the core of the culture of Kimball International, and transcends decades. Kimball International is committed to ethical practices
More informationSupplier Code of Conduct
Supplier Code of Conduct Supplier Code of Conduct In everything we do, Workday is committed to the highest standards of social responsibility, environmental responsibility, and ethical conduct. We expect
More informationIntel s Ethical Expectations for Suppliers and their Employees Supplier Ethical Expectations
Intel s for s and their Employees 1 Agenda Business Principles Intel s Code of Conduct EICC and Key Policies Bribes, Kickbacks and Commissions Gifts and Gratuities Conflicts of Interest Use of Intel s
More informationEdison International. Supplier Code of Conduct
Edison International Supplier Code of Conduct For more than 125 years, Edison International Company (Edison), and its predecessor companies, have worked hard to earn and maintain the trust of our customers
More informationCODE OF CONDUCT. At HITT, our focus goes beyond simply getting the job done; it s about how we conduct ourselves while we do it.
At HITT, our focus goes beyond simply getting the job done; it s about how we conduct ourselves while we do it. Our team members actions are a direct representation of the company an organization that
More informationGlobal Code of Business Conduct and Ethics
Global Code of Business Conduct and Ethics Message from the chairman Dear Colleagues: The Hay Group Global Code of Business Conduct and Ethics (the Code ) is our company s statement of commitment to the
More informationTHE TIMBERLAND COMPANY CODE OF ETHICS
THE TIMBERLAND COMPANY CODE OF ETHICS Code of Ethics MISSION AND VALUES STATEMENT We believe the honest and ethical conduct of our employees is an essential prerequisite to our success as a company. There
More informationETHICAL CODE OF CONDUCT
S E C U R I N G T H E F U T U R E ETHICAL CODE OF CONDUCT 1 TABLE OF CONTENT 1. THE ETHICAL CODE OF CONDUCT 4 1.1 Purpose 4 1.2 Commitment 5 1.3 Presentation of the Code of Conduct 5 2. GENERAL PRINCIPLES
More informationFOUNDATION BUILDING MATERIALS, INC. EMPLOYEE CODE OF CONDUCT
FOUNDATION BUILDING MATERIALS, INC. EMPLOYEE CODE OF CONDUCT Foundation Building Materials, Inc. (the Company ) conducts its business in accordance with the highest ethical standards of corporate leadership
More informationSupplier Code of Ethics
INTRODUCTION ATS is committed to conduct business in a professional, honest and ethical manner, and to comply with the law wherever it conducts business. ATS expects all Suppliers to conduct their business
More informationThe Company seeks to comply with both the letter and spirit of the laws and regulations in all countries in which it operates.
1. Policy Statement ROOT9B HOLDINGS, INC. CODE OF BUSINESS CONDUCT AND ETHICS The Nasdaq listing standards require that the Company provide a code of conduct for all of its directors, officers and employees.
More informationAnti-Bribery and Anti-Corruption Guide for Third Party Sellers working for or on behalf of Cardinal Health
Anti-Bribery and Anti-Corruption Guide for Third Party Sellers working for or on behalf of Cardinal Health Our COMMITMENT& EXPECTATIONS This guide is designed to help you understand our anti-bribery and
More informationCARNIVAL CORPORATION & PLC
CARNIVAL CORPORATION & PLC Business Partner Code of Conduct and Ethics A Letter from our CEO Building and maintaining trust in our business relationships and pursuing the highest standards of ethical behavior
More informationFINAL ASSESSMENT M.C. DEAN, INC.
FIL ASSESSMENT M.C. DEAN, INC. The following pages contain the detailed scoring for your company based on public information. The following table represents a summary of your scores: Topic Number of questions
More informationMETHANEX CORPORATE MANUAL
SUB- 1.0 Scope All directors, officers and employees of Methanex Corporation and its subsidiaries ( Employee(s) ). 2.0 Purpose To provide Methanex Employees with: a) a set of standards meant to assist
More informationGENTING MALAYSIA BERHAD (58019-U) CODE OF CONDUCT AND ETHICS
GENTING MALAYSIA BERHAD (58019-U) CODE OF CONDUCT AND ETHICS All rights reserved. No part of this publication may be reproduced, stored in a retrieval system, or transmitted in any form or by any means,
More informationSAP Partner Code of Conduct October 26, V2
SAP Partner Code of Conduct October 26, 2016- V2 Introduction Integrity and transparency constitute a cornerstone for the way in which SAP does business. SAP expects you, as a Partner, to do business in
More informationEXACT SCIENCES CORPORATION Code of Business Conduct and Ethics A MESSAGE FROM THE BOARD OF DIRECTORS
EXACT SCIENCES CORPORATION Code of Business Conduct and Ethics A MESSAGE FROM THE BOARD OF DIRECTORS At Exact Sciences Corporation (collectively with its subsidiaries, the Company ), we believe that conducting
More informationMV Transportation, Inc. Code of Conduct
MV Transportation, Inc. Code of Conduct This Code of Conduct ( Code ) has been adopted by the Board of Directors of MV Transportation, Inc. (the Company ) as the ethics and business code of conduct for
More informationThe Atlas Copco Group BUSINESS CODE OF PRACTICE
The Atlas Copco Group BUSINESS CODE OF PRACTICE Contents The Atlas Copco Group 1 First in Mind First in Choice 2 Core values 3 Relationships 4 Society and the environment 5 Employees 6 Customers 7 Business
More informationCODE OF BUSINESS CONDUCT AND ETHICS. FRONTIER AIRLINES, INC. Adopted May 27, 2004
1. Introduction CODE OF BUSINESS CONDUCT AND ETHICS FRONTIER AIRLINES, INC. Adopted May 27, 2004 The Board of Directors adopted this Code of Business Conduct ( Code ) to establish basic legal and ethical
More informationPRYSMIAN GROUP ETHICAL CODE
PRYSMIAN GROUP ETHICAL CODE the Prysmian ethical code Ethical Code Introduction pag. 1 Articles: Article 1 Article 2 Article 3 Article 4 Article 5 Article 6 Article 7 Article 8 Article 9 Article 10 Article
More informationCODE OF ETHICS AND BUSINESS CONDUCT
CODE OF ETHICS AND BUSINESS CONDUCT 1.0 SCOPE This Code of Ethics and Business Conduct (the Code of Conduct ) is implemented by the Board of Directors (the Board ) of Dominion Diamond Corporation and applies
More informationThank you, Mark Mirelez. VP Supply Chain Management. DynCorp International, LLC
Supplier Code of Ethics and Business Conduct It is DynCorp International s commitment to conduct business honestly, ethically, and in accordance with best practices and the applicable laws of the United
More informationSouthwest Airlines Co. Code of Ethics
Southwest Airlines Co. Code of Ethics Introduction Southwest Airlines Co. is committed to maintaining the highest standards of ethical business practices and legal and regulatory compliance. We place a
More informationAnti-Bribery Policy. for you for your community not for profit. Date: Head of HR. Author:
Anti-Bribery Policy Date: Author: 11.07.17 Head of HR for you for your community not for profit Control box : Document owner: Reviewed by: Claire Knight Claire Knight Approved by and date: Head of HR July
More informationSUNRISE TELECOM CODE OF BUSINESS CONDUCT AND ETHICS Overview Sunrise Telecom is committed to its customers, partners, employees and stockholders.
SUNRISE TELECOM CODE OF BUSINESS CONDUCT AND ETHICS Overview Sunrise Telecom is committed to its customers, partners, employees and stockholders. Accordingly, we believe that operating with integrity is
More informationOur Code of Ethics. Doing what s right, every day
Our Code of Ethics Doing what s right, every day Our Code of Ethics Message from the CEO 3 Our Code of Ethics and You 4 Our Commitment to Ethics 6 1. We respect each other 8 Human Rights and Equal Employment
More informationBritish Standard BS Specification for an Anti-bribery Management System. Summary
British Standard BS 10500 Specification for an Anti-bribery Management System Summary BACKGROUND BSI Standards is the UK's National Standards Body. It is the UK representative at the International Organisation
More informationTHE YANKEE CANDLE COMPANY, INC. Code Of Business Conduct And Ethics
THE YANKEE CANDLE COMPANY, INC. Code Of Business Conduct And Ethics This Code of Business Conduct and Ethics (the Code ) is designed to provide guidance and ethical standards of conduct for all directors,
More informationRELM WIRELESS CORPORATION (the Company ) CODE OF BUSINESS CONDUCT AND ETHICS
RELM WIRELESS CORPORATION (the Company ) CODE OF BUSINESS CONDUCT AND ETHICS Introduction This Code of Business Conduct and Ethics covers a wide range of business practices and procedures. It does not
More informationGuide to North America Healthcare Compliance 2016/2017
Guide to North America Healthcare Compliance 2016/2017 Dr. Reddy s Laboratories, Inc. NOTICE: this information is provided pursuant to the requirements of California Health & Safety Code 119400, 119402,
More informationTopaz Code of Business Conduct
Topaz Code of Business Conduct 01 January 2010 www.topazworld.com Introduction: This Code sets out the behaviours we expect of our employees, suppliers, contractors, agents and partners. Topaz is committed
More informationCode of Business Conduct
FANUC AMERICA CORPORATION Code of Business Conduct A Message from the President & CEO: Responsibility, trust, respect, and integrity these values represent the history and foundation of FANUC America Corporation.
More informationFinance Code of Conduct
Finance Code of Conduct Finance Code of Conduct Purpose and Scope of Code Conduent Finance personnel are relied upon by Company management to: Develop honest and accurate financial statements; Safeguard
More informationCONFLICT OF INTEREST POLICY
CONFLICT OF INTEREST POLICY Compliance & Ethics Version 3.1 January 5, 2018 CONFLICT OF INTEREST POLICY Compliance & Ethics Policy Owner: Emily Grymes, Director, Global Compliance & Ethics Policy Approver:
More informationCODE OF CONDUCT DESCRIPTION PRINCIPLES POLICIES AND DEFINITIONS
CODE OF CONDUCT DESCRIPTION Schneider has adopted the following Code of Conduct ( Code ) to apply to Schneider s directors, officers, managers and associates. While no code or policy can anticipate every
More informationCompliance with applicable governmental laws, rules, and regulations; Prompt internal reporting of violations of the Code;
CODE OF BUSINESS CONDUCT & ETHICS (Version 3.0) This Code of Business Conduct and Ethics (the Code ) describes the standard of ethical business conduct expected from all officers, directors and employees
More informationCODE OF ETHICS AND CONDUCT
CODE OF ETHICS AND CONDUCT PREFACE Green Mountain Power s Code of Ethics and Conduct is about doing the right thing acting honorably, treating each other with respect, and following the law. It s built
More informationCode of Business Ethics & Conduct
Code of Business HGA s success depends on conducting itself in accordance with the highest ethical standards and in full compliance with applicable law. Working with clients throughout the United States
More informationSTANDARD POLICY & PROCEDURE SP&P 382 Supplier Code of Conduct
Page 1 of 8 a STANDARD POLICY & PROCEDURE SP&P 382 Supplier Code of Conduct 1. Our Commitment (Policy Summary) IPG understands that suppliers are independent entities, but the business practices and actions
More informationOur Integrity Pledge 2013
Our Integrity Pledge 2013 The Pledge 5 Avoiding Conflicts of Interest 7 Preserving Confidentiality 9 Maintaining the Highest Standards of Professional Conduct 11 Providing Accurate Information Reporting
More informationComputer Programs and Systems, Inc. Code of Business Conduct and Ethics
(as of January 28, 2013) Introduction This sets forth the guiding principles by which we operate Computer Programs and Systems, Inc. (the Company ) and conduct our daily business with our stockholders,
More informationCODE OF BUSINESS CONDUCT AND ETHICS
CODE OF BUSINESS CODE OF BUSINESS INTRODUCTION At Cathedral Energy Services Ltd. and its subsidiaries (together, Cathedral ), we have always recognized the value of growing and developing trusting relationships
More informationOur vision. A company where the best people want to work.
Code of Conduct Our vision A company where the best people want to work. The world leader in chemical distribution, providing unparalleled connectivity between customers and suppliers. 2 Univar s guiding
More informationSupplier Code of Conduct
Samsung Telecommunications America, LLC Supplier Code of Conduct - Partners in Integrity STA Strategic SRM 10/1/2013 Rev. C Samsung Telecommunications America, LLC ( STA or Samsung Telecommunications America
More informationCODE OF ETHICS FOR CHIEF EXECUTIVE OFFICER AND SENIOR FINANCIAL OFFICERS UGI CORPORATION
CODE OF ETHICS FOR CHIEF EXECUTIVE OFFICER AND SENIOR FINANCIAL OFFICERS OF UGI CORPORATION Introduction The reputation for integrity of UGI Corporation (the Company ) is a valuable asset that is vital
More informationFINAL ASSESSMENT KOREA AEROSPACE INDUSTRIES, LTD.
FIL ASSESSMENT KOREA AEROSPACE INDUSTRIES, LTD. The following pages contain the detailed scoring for your company based on public information. The following table represents a summary of your scores: Topic
More informationESTERLINE ANTI-CORRUPTION PROGRAM CHARTER
ESTERLINE ANTI-CORRUPTION PROGRAM CHARTER Anti-Corruption Program Overview Introduction At Esterline, we win business based on the superiority of our products and services, and never as a result of bribery
More informationSTANDARD POLICY & PROCEDURE SP&P 382 Supplier Code of Conduct
Page 1 of 8 a STANDARD POLICY & PROCEDURE SP&P 382 Supplier Code of Conduct 1. Our Commitment (Policy Summary) IPG understands that suppliers are independent entities, but the business practices and actions
More informationSUPPLIER CODE OF CONDUCT
SUPPLIER CODE OF CONDUCT FOREWORD AND SUPPLIER CERTIFICATION CTS Corporation ( CTS ), founded in 1896, has built its reputation by producing quality products as well as by adhering to the highest ethical,
More informationENMAX CORPORATION PRINCIPLES OF BUSINESS ETHICS
ENMAX CORPORATION PRINCIPLES OF BUSINESS ETHICS This Policy applies to ENMAX Corporation and its Subsidiaries ( ENMAX ). The Board of Directors has the primary responsibility for the approval of this Policy,
More informationEmployee Handbook. Code of Conduct Acknowledgement
0 Employee Handbook Code of Conduct Acknowledgement A Message from Jay L. Geldmacher, Chief Executive Officer Dear Fellow Employee: The policy and historic practices of Artesyn Embedded Technologies have
More informationCODE OF ETHICS & CONDUCT
CODE OF ETHICS & CONDUCT 1 INTRODUCTION Integrity, responsibility and honest, ethical business conduct are core values of the Carlsberg Group. This Code of Ethics and Conduct (the Code ) supports our strategy
More information