Employment and the Workplace
Equal Employment Opportunity/Nondiscrimination
We believe that all terms and conditions of employment
should be based on an individual's ability to do
the job and not on the basis of personal characteristics
or beliefs. We provide employees with a working
environment free of discrimination, harassment,
intimidation or coercion relating directly or indirectly
to race, religion, sexual orientation, political
opinion or disability.
Forced Labor
We do not use any prison, slave, indentured, or
forced labor in the manufacture of any of our products.
Child Labor
We do not utilize child labor in the production
of any product. We do not employ any person under
the age of 15 (or 14 where local law allows), or
the age at which compulsory schooling has ended,
whichever is greater.
Hours of Labor
We maintain reasonable employee work hours based
on the limits on regular and overtime hours allowed
by local law, or where local law does not limit
the hours of work, the regular work week. Overtime,
when necessary, is fully compensated according to
local law, or at a rate at least equal to the regular
hourly compensation rate if there is no legally
prescribed premium rate. Employees are permitted
reasonable days off (at least one day off in every
seven-day period) and leave privileges.
Coercion and Harassment
We acknowledge the value of our staff and treat
each employee with dignity and respect. We do not
use cruel and unusual disciplinary practices such
as threats of violence or other forms of physical,
sexual, psychological or verbal harassment or abuse.
Compensation
We fairly compensate our employees by complying
with all applicable laws, including minimum wage
laws, or the prevailing local industry wage, whichever
is higher.
Health and Safety
We maintain a safe, clean and healthy environment
in compliance with all applicable laws and regulations.
We provide adequate medical facilities, clean
restrooms, reasonable access to potable water,
well lit and ventilated workstations, and protection
from hazardous materials or conditions. The same
standards of health and safety are applied in
any housing we provide for our employees.
Concern for the Environment
We believe it is our duty to protect the environment
and we do this by complying with all applicable
environmental laws and regulations.
Ethical Business Practices
Sensitive Transactions
It is our policy to prohibit employees from entering
into sensitive transactions -- business dealings
generally considered to be either illegal, immoral,
unethical or to reflect adversely on the integrity
of the Company. These transactions usually come
in the form of bribes, kickbacks, gifts of significant
value or payoffs made to favorably influence some
decision affecting a company's business or for
personal gain of an individual.
Commercial Bribery
We prohibit employees from receiving, directly
or indirectly, anything of value in return for
using or agreeing to use his or her position for
the benefit of that other person. Similarly, commercial
bribes, kickbacks, gratuities and other payoffs
and benefits paid to any customer are prohibited.
However, this does not include expenditures of
reasonable amount for meals and entertainment
of customers if they are otherwise lawful, and
should be included on expense reports and approved
under standard Company procedures.
Accounting Controls,
Procedures and Records
We accurately keep books and records of all transactions
and the dispositions of our assets as required
by law, as well as maintain a system of internal
accounting controls to ensure the reliability
and adequacy of our books and records. We ensure
only transactions with proper management approval
are accounted for in our books and records.
Use and Disclosure
of Inside Information
We strictly prohibit disclosure of material inside
information to persons within the company whose
positions deny access to such information. Inside
information is any data that has not been publicly
disclosed.
Confidential or Proprietary
Information
We take extra care to keep our customers' trust
and confidence in us. Thus, we prohibit employees
from disclosing confidential or proprietary information
outside the Company that could be harmful to our
clients, or to the Company itself. Such information
may only be shared with other employees on a need-to-know
basis.
Conflicts of Interest
We designed our policy to eliminate conflicts
between the interests of employees and the Company.
Since it is difficult to define what constitutes
a conflict of interest, employees should be sensitive
to situations which could raise questions of potential
or apparent conflicts between personal interests
and the Company's interests. Personal use of Company
property or obtaining Company services for personal
benefit may constitute a conflict of interest.
Fraud and Similar Irregularities
We strictly prohibit any fraudulent activity that
might injure our customers and suppliers, as well
as the Company. We follow certain procedures concerning
the recognition, reporting and investigation of
any such activity.
Monitoring and Compliance
We adopt a third-party monitoring program to confirm
the Company's compliance with this Code of Conduct.
Monitoring activities may include announced and
unannounced on-site factory inspection, review
of books and records relating to employment matters,
and private interviews with employees. We designate
one or more of our officers to inspect and certify
that the company's Code of Conduct is being observed.
Records of this certification shall be accessible
to our employees, agents, or third parties upon
request.
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