Ethics, Compliance and Corporate Social Responsibility in Supply Chain. Supply Chain Management and Procurement Legal & Compliance
|
|
- Edmund Dwain Chapman
- 5 years ago
- Views:
Transcription
1 Ethics, Compliance and Corporate Social Responsibility in Supply Chain Supply Chain Management and Procurement Legal & Compliance
2 Integrity is doing the right thing, even if nobody is watching. 2
3 JLL s Ethical Commitment JLL is in Ethisphere Institute s World s Most Ethical Companies list for 11 consecutive years Ethisphere recognizes companies commitment to ethical business practices linked to performance and profitability The list is comprised of 135 companies in 23 countries and 57 industries 2017 Jones Lang LaSalle IP, Inc. All rights reserved. 3
4 Achieving Ambitions the JLL Way Teamwork The JLL Way Excellence Ethics 2017 Jones Lang LaSalle IP, Inc. All rights reserved. 4
5 Ethics and Compliance Issues Add to Cost of Business Bribery Fraud Money Laundering Conflict of Interest Data Breach Modern Slavery Inappropriate Behaviour Health & Safety Violation Misuse of client property Lawsuits Regulatory Action Investigation Costs Penalties/Fines Contractual Liabilities Data Loss Loss of Business Terminations Reputational Damage 2017 Jones Lang LaSalle IP, Inc. All rights reserved. 5
6 Business Ethics and Supply Chain We expect our business partners to share our commitment to ethical conduct in business We are responsible for your conduct under client contracts Say Regulators also hold us accountable for ethical conduct in our supply chain Finally, your business practices impact our reputation and the JLL Brand which is one of our most important assets Believe Ethics Do 2017 Jones Lang LaSalle IP, Inc. All rights reserved. 6
7 Your Role as Business Partner Regulatory Compliance Compliance with laws and regulations on bribery and corruption, competition, environment, personal data, labor and employment, workplace safety, maintenance of accurate books and records and other matters Compliance with JLL s Vendor Code of Conduct In addition to regulatory compliance, JLL s expectations with respect to ethical business practices, clearance of conflicts of interest, commitment to health, safety, environment and ethical labor practices, management accountability, and ethics awareness and training for employees Compliance with Client s code of conduct Policies and processes mandated by JLL s clients which may be similar to JLL s Vendor Code of Conduct but with stricter requirements 2017 Jones Lang LaSalle IP, Inc. All rights reserved. 7
8 Fair Business Practices Bribery and Corruption Bribery or corruption is not only unethical but also illegal Do not offer or give any illegal, improper or questionable payment, benefit, service or anything else of value to any government or public official, or anyone at JLL or any third party, for getting business or any business advantage. Our policy prohibits even small facilitation payments to government officials even though they may be considered normal practice in some countries. Maintain accurate books and records that reflect the true nature of the transactions. Do not alter or falsify or backdate records. There must be full transparency regarding date, recipients and purpose of payments. JLL is a public company listed on the New York Stock Exchange with operations in over 80 countries Compliance by JLL (and the suppliers who act on our behalf) with the U.S. Foreign Corrupt Practices Act (FCPA), the U.K. Bribery Act, and the anti-corruption laws of the countries in which we operate is mandatory. Violation can result in civil enforcement suits as well as criminal prosecution by the relevant regulatory body Jones Lang LaSalle IP, Inc. All rights reserved. 8
9 Fair Business Practices Fraudulent Behavior Do not take advantage of customers or business associates through manipulation, concealment, abuse of privileged information, misrepresentation, fraudulent behavior or any other unfair-dealing practice. Comply with applicable antitrust and competition laws (including those relating to price discrimination, price fixing, and restraint of trade and monopolies). Comply with all applicable anti-money laundering laws, and never knowingly participate in a scheme to launder money, under-report the size of a transaction, or wrongfully avoid tax liability Do not use JLL or client information you come across in the course of providing services to JLL/clients for any personal benefit or gain (including purchasing or selling stock) Companies profit from a reputation of acting with honesty and integrity 2017 Jones Lang LaSalle IP, Inc. All rights reserved. 9
10 Conflict of Interest You may have multiple interests that conflict with each other or JLL employees making decisions for the firm may have personal interests. If not addressed, such conflicts can result in bribery, self-dealing or nepotism which undermine one s duty to stakeholders and clients. Business decisions and actions should always be driven by objectivity, transparency and integrity rather than personal gain. Conflicts can be cleared but require Transparency and Integrity JLL employees must not use their position for any improper benefit If a JLL employee or family member has any interest or influence in your company (as director, officer, shareholder, advisor etc.), disclose that relationship so that we can ensure that JLL s interests rather than that relationship drives decisions Disclose all other dealings (gifts/entertainment, loans, financial interests) by your company or employees with JLL employees or their family members Conflicts must be cleared if you wish to be engaged by, or continue providing services to, JLL 2017 Jones Lang LaSalle IP, Inc. All rights reserved. 10
11 Gifts and Entertainment Grow your business through fair means and not through gifts, entertainment, loans, favors or anything else that influences, or might influence, business decisions. JLL purchases goods and services on the merits of price, quality, performance and suitability. JLL employees cannot as a general rule accept gifts or entertainment from suppliers as they create a conflict of interest and may be viewed as bribery. The only exception is a token of appreciation that is otherwise appropriate in the circumstances. Gift or entertainment that is an acceptable token of appreciation: has a nominal value (between US$ depending on the country) and is not given in the expectation of any favor; and is not connected to a procurement decision (whether supplier engagement or assessment or monitoring); and is otherwise appropriate and reflects good judgment 2017 Jones Lang LaSalle IP, Inc. All rights reserved. 11
12 JLL and Client Systems JLL Vendor Information Security Requirements (based on ISO framework) establish role-based controls for suppliers accessing JLL/client systems or providing technology services. Comply with JLL s requirements on controls such as: security management, access management, asset protection, firewalls, cryptography, business continuity, network security, secure development, andsystem monitoring. Protect and use technology and systems provided by JLL/clients responsibly and only for authorized business purposes. Do not misuse JLL/client resources and facilities, whether physical or digital. Remember, all data stored or transmitted on JLL or client equipment is considered private and is the property of JLL or such client. Weak controls enable unauthorized access and cyber-attacks on systems leading to data leak or loss, ransomware, phishing and other theft or damage to systems and data. Any act compromising the security and integrity of systems or property will have significant implications for JLL and clients Jones Lang LaSalle IP, Inc. All rights reserved. 12
13 Information Security and Data Privacy Information on JLL s and clients operations, sites, customer lists, financial affairs, products and services, business strategy and such other information is proprietary and confidential You have a duty to protect JLL/clients confidential information against unauthorized access or disclosure, whether intentional or inadvertent Information breach can have significant consequences including: Regulatory action under laws/regulations governing data security and integrity Financial loss and loss of business due to contractual liabilities to third parties Loss of reputation and/or competitive advantage 2017 Jones Lang LaSalle IP, Inc. All rights reserved. Data Privacy Comply with data privacy laws governing the collection, use, storage and cross-border transfer of personal data of individuals Understand and control how your company and employees collect and handle personal data; even inadvertent access of personal data may result in data being captured and stored on your systems triggering violation of data privacy laws EU s General Data Protection Regulation (GDPR) has stringent requirements for protecting EU residents personal data. If you process personal data of EU residents in the course of providing services to JLL or our clients, then you must comply with GDPR regardless of whether you are based within or outside the EU 13
14 Labor and Employment Practices JLL respects and supports human rights principles as defined by the Universal Declaration of Human Rights, the International Labour Organization s Declaration on Fundamental Principles and Rights at Work, and the United Nations Global Compact We expect our suppliers to be equal opportunity employers and not engage in any discriminatory employment practices on the basis of race, caste, ethnicity or national origin, religion, age, disability, gender, sexual or gender identity or expression, union membership, political affiliation, covered veterans status or other such factors Suppliers must comply with all local minimum working age laws and requirements and meet, at a minimum, national or applicable local legal standards for payment of wages and benefits 2017 Jones Lang LaSalle IP, Inc. All rights reserved. 14
15 Workplace Health and Safety Create a safe and healthy work environment, whether in your own workplace or on JLL or client site Comply with all relevant health and safety laws and regulations as well as client, JLL and/or industry requirements Ensure that your employees are qualified, and equipped, to perform activities safely Develop appropriate health and safety procedures and provide resources to manage safety and ensure that your employees understand and properly apply safety standards and procedures Keep the workplace (whether your own or JLL/client premises) free of unauthorized drugs, weapons or devices Immediately inform JLL of any unsafe working conditions or any health or safety incidents that occur on JLL or client site 2017 Jones Lang LaSalle IP, Inc. All rights reserved. 15
16 Harassment and Abuse Workplace should be free of any abusive, harassing, threatening or offensive behaviour, whether verbal, physical or digital. Suppliers should not engage in or allow any physical discipline or abuse, or threats of physical discipline or abuse, or any sexual or other forms of harassment or intimidation. Behaviour should reflect civility and mutual respect and foster a safe and conducive working environment for your employees and third parties they interact with Suppliers should develop and implement a policy and measures that set a clear position on zero tolerance for harassment and management commitment to prevent and respond to any form of harassment 2017 Jones Lang LaSalle IP, Inc. All rights reserved. Key obligations of your company: Communicate JLL s Vendor Code of Conduct to your employees Investigate all reported cases thoroughly and take appropriate action Engage in an ongoing awareness and support campaign for all employees Train employees on workplace conduct and prevention of abusive behavior Report cases involving any incident on a JLL/client site to a senior JLL employee Do not retaliate against employees who report violations in good faith 16
17 Modern Slavery Modern slavery is illegal and a violation of human rights. These crimes share a common feature: exploiting vulnerable people for personal or commercial gain. It takes various forms, such as slavery, servitude, debt bondage, forced and compulsory labour and human trafficking. There are estimated 45.8 million people in modern slavery globally including in developed countries We are all legally, contractually and ethically bound to prevent modern slavery in our own operations and in our supply chain 2017 Jones Lang LaSalle IP, Inc. All rights reserved. Do Not: Ask your workers to deposit identity papers Restrict your workers movement Create abusive working / living conditions Impose or facilitate (through agents) debt obligations on workers for travel or accommodation You must also ensure that your supply chain does not engage in oppressive or unfair labor practices, including child labor, or knowingly engage a supplier or agent, that uses oppressive or unfair labor practices Vulnerable Sectors in JLL s Business Janitorial Food / Drink Landscaping Construction Security Services 17
18 Commitment to Sustainability People Promote health and well-being through safe, healthy workplace and conditions Embrace diverse skills and backgrounds and promote inclusion Communities Support disadvantaged, small and minority-owned businesses Volunteer time and money for charitable causes Planet Reduce greenhouse gas emissions Reduce environmental impact through recycling, waste management and acceptable levels of energy and water use Marketplace Champion fair business practices and healthy competition Foster transparency in supply chain 2017 Jones Lang LaSalle IP, Inc. All rights reserved. 18
19 Social Media Responsibility Exercise good judgment when dealing with social media. Do not intentionally or inadvertently post confidential or proprietary information (including pictures of client site) or anything that may negatively impact your relationship with JLL and its clients. Any social media communication on behalf of JLL or its clients must be authorized by JLL s communications department in writing. Do not use JLL or client systems or devices to create, access, store, print, or send any material that is intimidating, harassing, threatening, abusive, sexually explicit or otherwise offensive or inappropriate and/or send any false, derogatory or malicious communications Do not use the JLL logo or client logos without express written permission which may only be given for valid business reasons and in compliance with JLL s branding policies 2017 Jones Lang LaSalle IP, Inc. All rights reserved. 19
20 Three Pillars of Ethical Behavior Objectivity Client s/jll s best interests in mind No personal considerations Transparency Open dealings; no deception Good Judgment Does it fit with your and our values? How would it look in the newspaper? 2017 Jones Lang LaSalle IP, Inc. All rights reserved. 20
21 Report Unethical Behaviour If you see or suspect unethical behavior on JLL account, o o o o Report to a senior JLL person; or the JLL Ethics Officers at: Ethics.Officers@jll.com; or Report anonymously by calling the JLL Global Ethics Helpline at or logging a report on If the violation pertains to human trafficking, in addition to the above, you may contact the Global Human Trafficking Hotline at FREE or its address at help@befree.org JLL will keep all reports confidential to the extent permitted by law JLL practices a no retaliation policy for all reports made in good faith A Few Quick Tips If you know it s wrong, don t do it If you re not sure, ask your Legal Officer Remember, not reporting may also violate policies 21 Jones Lang LaSalle 2017
22 Questions? 22
23 2017 Jones Lang LaSalle IP, Inc. All rights reserved. 23
CODE OF CONDUCT A MESSAGE FROM OUR CEO. Dear Colleagues:
CODE OF CONDUCT A MESSAGE FROM OUR CEO Dear Colleagues: Few things are as important as your reputation. That s true for companies and individuals alike. Logitech s ethical reputation is the foundation
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 informationLiving Our Purpose and Core Values CODE. Code of Business Ethics and Conduct for Vendors
Living Our Purpose and Core Values CODE Code of Business Ethics and Conduct for Vendors December 2016 HCSC Vendor Code of Business Ethics and Conduct Since 1936, Health Care Service Corporation, a Mutual
More informationCODE OF CONDUCT FOR DOING BUSINESS WITH LINKEDIN
CODE OF CONDUCT FOR DOING BUSINESS WITH LINKEDIN TABLE OF CONTENTS INTRODUCTION 1 Expectations LINKEDIN VALUES 2 MAINTAINING BUSINESS INTEGRITY 3 Anti-Corruption Competition Laws PROMOTING TRANSPARENCY
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 informationOUR CODE OF BUSINESS CONDUCT AND ETHICS
OUR 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 cover every issue that may arise, but
More informationHAVYARD GROUP ASA Code of Conduct for Business, Ethics and Corporate Social Responsibility
Adopted by the Board of Directors of Havyard Group ASA on 17 March 2014, last amended on 26 February 2015. www.havyard.com 1. CORPORATE VALUES Havyard Group ASA (the Company ) shall enjoy an invaluable
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 informationBusiness Partner Code of Conduct
Policy Owner: Group Head of Procurement Effective Date: 31 October 2017 Business Partner Code of Conduct This Business Partner Code of Conduct defines basic requirements and responsibilities. VEON reserves
More informationASSOCIATED BANC-CORP CODE OF BUSINESS CONDUCT AND ETHICS
ASSOCIATED BANC-CORP 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 cover every issue that
More informationAppendix 8. M&T BANK CORPORATION CODE OF BUSINESS CONDUCT AND ETHICS
Appendix 8. M&T BANK CORPORATION CODE OF BUSINESS CONDUCT AND ETHICS Introduction. This ( Code ) covers a wide range of business practices and procedures. There are, of course, many corporate policies
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 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 informationCODE OF ETHICS AND BUSINESS CONDUCT
CODE OF ETHICS AND BUSINESS CONDUCT The Code of Ethics and Business Conduct ( Code ) outlines the expectations and ethical standards of LMI Aerospace ( LMI or the Company ) that each director, officer
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 informationCODE OF CONDUCT. Securing What Matters
1 WHY THIS CODE OF CONDUCT? At Betafence we believe our success depends on relations based on trust and professionalism. This Code of Conduct guides us in building and maintaining these relationships with
More informationGeneral Policies & Procedures. SV 5.0 Clean Harbors Vendor Code of Business Conduct and Ethics
1. Purpose This Code is intended to govern the conduct of Clean Harbors, Inc. and all of its subsidiaries Vendors when doing business with or on behalf of Clean Harbors, Inc. For the purpose of this Code,
More informationBusiness Conduct Requirements for Representatives and Channel Partners
Business Conduct Requirements for Representatives and Channel Partners www.qorvo.com Qorvo, Inc. and its affiliates ( Qorvo ) are committed to the highest standards of business conduct and ethics and expect
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 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 informationCEO Message. James J. Judge Chairman, President and CEO
CEO Message Embedded in Eversource s mission to safely deliver reliable energy and superior customer service is our commitment to conduct ourselves ethically, respectfully and honestly. Eversource s Code
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 informationSafety Integrity Excellence People and Citizenship
OPG Supplier Code of Conduct Safety Integrity Excellence People and Citizenship Ontario Power Generation is an Ontario-based electricity generation company whose principal business is the generation and
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
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 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 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 informationThis document articulates ethical and behavioral guidance for all NGA Human Resources companies, employees, and business partners (such as suppliers,
This document articulates ethical and behavioral guidance for all NGA Human Resources companies, employees, and business partners (such as suppliers, agents, vendors and sub-contractors). To help guide
More informationSUPPLIER CODE OF CONDUCT
SUPPLIER CODE OF CONDUCT Philip Morris USA U.S. Smokeless Tobacco Company John Middleton Ste. Michelle Wine Estates Philip Morris Capital Corporation Nu Mark Our companies are committed to responsibly
More informationComputershare Group Code of
Computershare Group Code of Conduct A Message from the President & CEO Underpinning everything we do as a business are our three core values: Certainty: to deliver our services and solutions right first
More informationLIFEBRIDGE HEALTH INTEGRITY PROGRAM CODE OF EXCELLENCE
LIFEBRIDGE HEALTH INTEGRITY PROGRAM CODE OF EXCELLENCE I. MESSAGE FROM THE PRESIDENT It is the mission of LifeBridge Health to provide a broad array of high quality, cost effective health and health related
More information"Finnair" and "Finnair Group" as used herein refer to Finnair Plc and its subsidiaries.
Code of Conduct 1 INTRODUCTION 1.1 Purpose and scope of this document Finnair is an iconic national airline and a respected member of the international aviation community with a solid reputation in safety,
More informationSupplier Code of Business Conduct and Ethics
Supplier Code of Business Conduct and Ethics Table of Contents 1. Definitions 2. Purpose 3. Policy Statement 4. Workplace Standards and Practices and Compliance with the Law 5. Health, Safety and Environmental
More informationJetBlue Business Partner Code of Conduct
JetBlue Business Partner Code of Conduct JetBlue s foundation is built on our Values Safety, Caring, Integrity, Passion and Fun. We use our Values to guide our actions, distinguish us from our competitors,
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 informationSKL International Code of Conduct
SKL International Code of Conduct I. Introduction SKL International s Code of Conduct provides a framework to guide ethical conduct in a way that upholds the integrity and reputation of SKL International
More informationOtsuka. Supporting. Supplier Code of Ethics and Professional Conduct
Supporting Otsuka Supplier Code of Ethics and Professional Conduct Otsuka America Pharmaceutical, Inc. (OAPI) Otsuka Pharmaceutical Development & Commercialization, Inc. (OPDC) Otsuka Maryland Medicinal
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 informationCode of Business Conduct and Ethics
Code of Business Conduct and Ethics (As last revised on December 12, 2017) Introduction Tesla aspires to be a do the right thing company in other words, engaging in conduct that your family would be proud
More informationCODE OF CONDUCT FOR HUHTAMAKI SUPPLIERS
CODE OF CONDUCT FOR HUHTAMAKI SUPPLIERS 1 Introduction Huhtamaki is committed to complying with laws and regulations, applying high ethical standards and respecting fundamental rights of employees when
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 CONDUCT. We Are Responsible For Our Own Success.
Business ethics and corporate social responsibility are issues that are extremely important to the ongoing success of any company. International Forest Products Limited s goal is to be a company that conducts
More informationIntuit Supplier Code of Conduct
Intuit Supplier Code of Conduct At Intuit we simplify the business of life. We invent solutions to important problems. We innovate. This is what we strive for every day, and we truly value the role our
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 informationBecause we care. Code of Business Ethics and Conduct HOLDING OUR STANDARDS HIGH
Because we care. Code of Business Ethics and Conduct HOLDING OUR STANDARDS HIGH ALL TEAMMATES Teammates, For over 100 years, Midmark has built its position as a leader on integrity and trust. We strive
More informationOur Business Partner CODE OF CONDUCT
Our Business Partner CODE OF CONDUCT EN INTRODUCTION Informa is an international business intelligence, academic publishing, knowledge and events Group, with high standards and values around how our businesses
More informationCSI tools bvba Code of Ethical Conduct
CSI tools bvba Code of Ethical Conduct CSIt_Code of Ethical Conduct_20161201_v05 CSI tools, 2016 P a g e 1 7 Contents Introduction... 3 A. Employment... 3 A1. Child labor shall not be used... 3 A2. Regular
More informationCODE OF BUSINESS CONDUCT
CODE OF BUSINESS CONDUCT We are responsible, safe and ethical. LETTER FROM OUR PRESIDENT AND CEO Fellow employees, Integrity is not new to Marathon Oil. Our commitment to do business honestly and fairly
More informationDOUBLE-TAKE SOFTWARE, INC. CODE OF BUSINESS CONDUCT AND ETHICS
DOUBLE-TAKE SOFTWARE, INC. CODE OF BUSINESS CONDUCT AND ETHICS This Code of Business Conduct and Ethics covers a wide range of business practices and procedures and serves as a guide to ethical decision-making.
More informationHilton Responsible Sourcing Policy
Hilton Commitment to Travel with Purpose Travel with Purpose is Hilton's corporate responsibility commitment to providing shared value to its business and communities in four areas - creating opportunities
More informationVOYA Financial CODE OF BUSINESS CONDUCT AND ETHICS
VOYA Financial CODE OF BUSINESS CONDUCT AND ETHICS Version 2.0 April 2014 Information Sheet ISSUED BY Voya Financial Compliance TARGET AUDIENCE All Voya Financial Directors and Employees OWNED AND APPROVED
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 informationPHILLIPS 66 BUSINESS PARTNER PRINCIPLES OF CONDUCT. Doing the right thing always. Phillips66.com
PHILLIPS 66 BUSINESS PARTNER PRINCIPLES OF CONDUCT Doing the right thing always. Phillips66.com 1 BUSINESS PARTNER PRINCIPLES OF CONDUCT At Phillips 66, we take great pride in providing energy and improving
More informationSUPPLIERS CODE OF CONDUCT
ENTERGY CORPORATION SUPPLIERS CODE OF CONDUCT Last Updated 1/8/2018 1 ENTERGY CORPORATION SUPPLIERS CODE OF CONDUCT TABLE OF CONTENTS I. INTRODUCTION... 3 II. ETHICAL EXPECTATIONS AND OBLIGATIONS... 4
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 informationCRONOS GROUP INC. CODE OF BUSINESS CONDUCT AND ETHICS. 2018A Approved. Legal Department (Xiuming Shum) Validator
Version Status (Draft or Approved) Scope of Application (Who Does This Apply To) CRONOS GROUP INC. CODE OF BUSINESS CONDUCT AND ETHICS 2018A Approved All employees of Cronos Group Inc. ( Cronos Group or
More informationINTERWORLD SRL FREIGHT FORWARDING CO. CODE OF CONDUCT
INTERWORLD SRL FREIGHT FORWARDING CO. CODE OF CONDUCT INTERWORLD SRL INTERNAL CODE OF CONDUCT INDEX A. Letter From Simone Rovida, Managing Director Page 3 B. International Code of Conduct Page 4. MANAGING
More informationMYOB Group Limited Code of Conduct. December 2016
MYOB Group Limited Code of Conduct December 2016 MYOB Group Limited Code of Conduct 1 MYOB GROUP LIMITED (THE COMPANY) 1. INTRODUCTION 1.1 Background The MYOB group ( MYOB ) is committed to maintaining
More informationAES Values Guide. From Words to Action STRIVE FOR EXCELLENCE THROUGH WORK HONOR COMMITMENTS ACT WITH INTEGRITY PUT SAFETY FIRST HAVE FUN
ve Fun Through Work AES Values Guide From Words to Action OUR CODE OF CONDUCT HAVE FUN THROUGH WORK STRIVE FOR EXCELLENCE HONOR COMMITMENTS ACT WITH INTEGRITY PUT SAFETY FIRST Dear AES People, At AES,
More informationCODE OF CONDUCT Version 3 August 2016
CODE OF CONDUCT Version 3 August 2016 Table of Contents 1. INTRODUCTION... 3 2. COMPLIANCE WITH LOCAL LAWS AND REGULATIONS... 3 3. FAIR COMPETITION... 4 4. ANTI BRIBERY AND ANTI CORRUPTION... 4 5. WORKING
More information(incorporating the Business Code of Conduct and the Managing Company Property Policy) Date issued/reviewed Effective from Next review
Date: June 2017 Ethics Code (incorporating the Business Code of Conduct and the Managing Company Property Policy) Policy owner/ issued by Group CEO Approved by Group Executive Team on behalf of the Board
More informationRatos AB Adopted by Ratos s Board on February 2018 (replaces previous version adopted 16 February 2017)
Code of Conduct Ratos is an investment company that acquires, develops and divests mainly unlisted Nordic companies. Over time, Ratos is to generate the highest possible return by actively exercising its
More informationBodycote s Core Values are Honesty and Transparency, Respect and Responsibility and Creating Value and are summarised as follows:
Bodycote s Core Values are Honesty and Transparency, Respect and Responsibility and Creating Value and are summarised as follows: Honesty and Transparency We are honest and act with integrity. Trust stems
More informationTAP AUTOMOTIVE HOLDINGS, LLC TAP WORLDWIDE, LLC / TAP MANUFACTURING, LLC Code of Conduct and Business Ethics
Revised and Reissued August 2015 TAP AUTOMOTIVE HOLDINGS, LLC TAP WORLDWIDE, LLC / TAP MANUFACTURING, LLC Code of Conduct and Business Ethics THIS POLICY DOES NOT CREATE AN EXPRESS OR IMPLIED EMPLOYMENT
More informationCode of Conduct. 1 P age
Code of Conduct 2013 1 P age Dear Colleagues, At INSYS, we believe in doing the right thing for our patients, customers, employees, communities and business partners. Our patients and customers trust the
More informationSupplier Code of Conduct
Supplier Code of Conduct Contents 1.0 Introduction 4 2.0 Definitions 4 3.0 Our Code of Conduct at a Glance 5 4.0 The Code 5 4.1 Living the LSEG Values 5 4.2 Environmental Management 6 4.3 Human and Social
More informationCODE OF CONDUCT. Document Management
CODE OF CONDUCT Document Management This document is available in multiple languages and may be updated from time to time. For the avoidance of doubt, it is therefore explicitly mentioned that the English
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 informationCorporate Governance: Sarbanes-Oxley Code of Ethics
Corporate Governance: Sarbanes-Oxley Code of Ethics Latest Update: December 14, 2016 CODE OF BUSINESS CONDUCT AND ETHICS TABLE OF CONTENTS Introduction 1 Purpose of the Code 1 Conflicts of Interest 2 Corporate
More informationPATAGONIA WORKS GLOBAL CODE OF EMPLOYEE CONDUCT
PATAGONIA WORKS GLOBAL CODE OF EMPLOYEE CONDUCT Photo: Mikey Schaefer Introduction Patagonia Works and all of its operating companies intend to be in business for a long time and operate in a way that
More informationSecuritas Values and Ethics Code
Securitas Values and Ethics Code 1. General Principles Abiding by laws, maintaining high ethical standards and upholding our shared values play a prominent role in all of Securitas operations and provide
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 CHARLES SCHWAB CORPORATION CODE OF BUSINESS CONDUCT AND ETHICS
THE CHARLES SCHWAB CORPORATION CODE OF BUSINESS CONDUCT AND ETHICS Table of Contents Page Introduction 1 Ethical Behavior and Legal Compliance 1 Ethical Behavior 1 Compliance with Laws, Rules, Regulations
More informationA Message from Michael Petras, CEO
A Message from Michael Petras, CEO Sotera Health, together with its affiliates and business units including Sterigenics, Nordion and Nelson Labs (collectively, the Company or Sotera Health ), is committed
More informationAdministrative Policy English original
Code of Conduct All units KONE s mission is to improve the flow of urban life. Our vision is to deliver the best People Flow experience, providing ease, effectiveness and experiences to users and customers
More informationRyanair Holdings Limited
Ryanair Holdings Limited Code of Business Conduct & Ethics 2009 1 TABLE OF CONTENTS 1. INTRODUCTION 3 2. WORK ENVIRONMENT 3 2.1 Discrimination & Harassment 3 2.2 Privacy of Personal Information 3 2.3 Internet
More informationCompliance Manual. If you have any questions regarding this Code or its application to you in any situation, please contact:
Policy Title: Code of Business Conduct and Ethics Policy Owner: Compliance Officer Approved By: Chief Legal Officer 1. Purpose Compliance Manual Effective Date: 15 August 2017 Review Date: 31 August 2018
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 informationSecuritas Values and Ethics
Securitas Values and Ethics 1 Message from the CEO Every day, everywhere where we operate, everyone at Securitas can help build our reputation and brand and promote long-term sustainability and growth.
More informationSecuritas Values and Ethics
Securitas Values and Ethics 1 2 Message from the CEO Every day, everywhere where we operate, everyone at Securitas can help build our reputation and brand and promote long-term sustainability and growth.
More informationOur Code of Conduct also applies to our directors with respect to his or her director-related duties.
Code of Business Conduct Our reputation as a company is one of our most important assets. Our reputation needs to be managed and developed with the same care we extend to our products. This means all of
More informationActing for responsible sourcing in our supply chain Code of Business Conduct for Suppliers
Acting for responsible sourcing in our supply chain Code of Business Conduct for Suppliers 02 Code of Business Conduct for Suppliers Table of Contents 03 Introduction to Sustainable Procurement at LafargeHolcim
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 informationWILLIAM LYON HOMES CODE OF BUSINESS CONDUCT AND ETHICS
WILLIAM LYON HOMES CODE OF BUSINESS CONDUCT AND ETHICS INTRODUCTION This Code of Business Conduct and Ethics (the Code ) contains general guidelines for conducting the business of William Lyon Homes (the
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 informationCode of Conduct INTRODUCTION
INTRODUCTION Kingspan Group plc is committed to acting responsibly in its business, and maintaining high standards of ethics and integrity in all its dealings with its stakeholders, be they investors,
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 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 informationJPMorgan Chase & Co. Supplier Code of Conduct
JPMorgan Chase & Co. Supplier Code of Conduct Current Effective Date: October 28, 2016 TABLE OF CONTENTS 1. Summary or Rationale... 2 2. Scope... 2 3. Changes from Previous Version... 2 4. Policy Statements...
More informationSupplier Code of Conduct
1. Purpose of Supplier Code of Conduct a. Ventura Foods, LLC ( Ventura Foods ) conducts business ethically and in a manner that respects individuals, their communities and the environment. Ventura Foods
More informationHUBER+SUHNER Business and Ethics Code
HUBER+SUHNER Business and Ethics Code Message from the CEO and the Head Corporate HR HUBER+SUHNER is committed to conducting its business in accordance with high ethical standards, integrity and compliance
More informationCODE OF CONDUCT April 2017
SODEXO SUPPLIER CODE OF CONDUCT April 2017 Sodexo Supplier Code of Conduct Summary Introduction... 3 1. Business integrity... 4 2. Human rights and fundamental rights at work... 5 Elimination of all forms
More informationve Fun Through Work AES Values Guide From Words to Action OUR CODE OF CONDUCT EXCELLENCE INTEGRITY SAFETY AGILITY FUN
ve Fun Through Work AES Values Guide From Words to Action OUR CODE OF CONDUCT EXCELLENCE FUN AGILITY INTEGRITY SAFETY Dear AES People, At AES, it s what brings us together that makes us unique as a company.
More informationMAKE AN INCREDIBLY SMART DECISION
Code of Conduct MAKE AN INCREDIBLY SMART DECISION At Real Matters, making an incredibly smart decision isn t just about helping our clients, it s about our culture, how we conduct business and the principles
More informationGUIDANCE FOR SUPPLIERS OF PURDUE PHARMA L.P.
GUIDANCE FOR SUPPLIERS OF PURDUE PHARMA L.P. PURDUE PHARMA L.P. PURDUE S GUIDING PRINCIPLES 1 Table of Contents PURDUE S GUIDING PRINCIPLES... 1 ETHICAL BUSINESS PRACTICES... 4 Business Integrity... 4
More informationMetso Code of Conduct
Metso Code of Conduct From the CEO Dear colleague, Metso is a big global company with more than 12,000 employees and operations in over 50 countries. It is important that we work as a team that shares
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 informationGlobal Supplier Code of Conduct
Global Supplier Code of Conduct Message from our Chief Executive Officer At Rolls-Royce our strategy focuses on customer, innovation and profitable growth to ensure a sustainable business. This includes
More informationSAS Code of Conduct ethical principles and guidelines
1 2 SAS Code of Conduct ethical principles and guidelines Introduction... 3 Our customers... 4 Employees... 4 The world around us... 5 Communication and dialogue... 5 Security, theft and loss... 6 Environment...
More information